Imagine: in 2025, 65% of investment companies from Asia and the CIS face AML account freezes at the bank onboarding stage, losing up to 6 months to restarts and fines of millions of euros according to FATF reports. As a compliance officer, I see every day how investment companies fail to open accounts in the EU or Singapore because of a weak KYC process and ignoring the source of funds. Are you willing to risk the sustainability of your business? In this article I will analyse the triggers that make an AML audit mandatory, give a step-by-step bank onboarding plan for investment firms from Asia to the EU and show how to calculate the ROI of a compliance audit before opening an account in Europe. Read to the end: receive a ready-made checklist and strategies that reduce the risk of account freezes to zero.
Banking onboarding for investment companies
Onboarding components: KYC, CDD, UBO, SOW/SOF
The KYC process starts with Customer Due Diligence (CDD), a questionnaire that discloses the business structure. Ultimate Beneficial Owner (UBO) verification requires documents for ultimate owners with more than a 25% share. Source of funds (SOF) and source of wealth (SOW) verification document the origin of assets: contracts, audits, tax returns. The COREDO team recently optimized KYC for investment firms, reducing document collection by 30% through standardized templates.
Roles of the bank and the investment company’s compliance officer
Account freezes, fines and denial of service
AML audit triggers prior to bank onboarding
Client risk profile: high-risk PEPs and UBOs
Large transactions and opaque sources of funds
Regulatory and banking requirements: EU, MAS
eIDAS onboarding in the EU mandates digital identification, MAS Digital Onboarding requires biometrics according to the 2025 guidelines. FATF compliance requires audits for cross-border transactions. Singapore banks (ACRA) reject 35% without the MAS Digital Onboarding Framework for Asian investment companies.
Bank onboarding for an investment company (compliance)
Step 0: risk self-assessment and AML risk map
Document preparation and the CDD/Customer Due Diligence questionnaire
Fill in the CDD questionnaire (Customer Due Diligence questionnaire): business plan, licenses, UBO verification. For KYC, investment firms should add the offering prospectus.
Step 2: Collection and verification of Source of Funds / Source of Wealth
Document the source of funds: bank statements, contracts. For source of wealth verification, provide tax returns for the past 3 years. Automate via API.
PEP, sanctions screening and EDD where necessary
Perform PEP screening using databases like World-Check and sanctions list screening. If there are risks, conduct EDD: interviews, additional audits.
Step 4: External AML audit: when and how to commission it
How to carry out an AML audit before the bank onboarding of an investment company? Order an external compliance audit in cases of PEPs or complex UBO structures. An AML audit for investments checks transactions over one year; ROI is 5x due to avoided fines.
Digital onboarding and integration of eIDAS / MAS
Integration with the bank: agreements, SLAs, monitoring
| Checklist of documents and verification criteria | Basic CDD | Enhanced (EDD) | External Audit |
|---|---|---|---|
| Articles of association, business plan | |||
| UBO verification (passports, addresses) | + supporting evidence | + audit | |
| SOF/SOW (bank statements, contracts) | Recommended. | ||
| PEP declaration, sanctions screening | + EDD |
EU vs Asia vs CIS Cases
COREDO’s experience spans 50+ cases: from onboarding investment firms from Asia into EU banks to CIS structures.
Onboarding of Asian investment firms into EU banks
Singapore MAS: risk-based approach and onboarding
CIS risks when negotiating with European banks
Metrics and KPIs for assessing onboarding and AML
Track onboarding conversion metrics for optimization.
Key KPIs: onboarding, conversion, rejections
How to calculate ROI from an AML audit and KYC
Formula: ROI = (Benefit – Cost) / Cost × 100%.
Example: Costs 15k, Benefit 120k (fines + delays) = 700%.
| KPI before/after AML audit | Before | After |
|---|---|---|
| Onboarding time (days) | 90 | 35 |
| Rejection rate (%) | 25 | 4 |
| Blocks | 3 | 0 |
| ROI (%) | – | 650 |
Reporting for management and the bank: compliance dashboard
Dashboard: operational efficiency, client retention strategies, transaction monitoring metrics. Monthly, onboarding conversion rate.
Tools to accelerate onboarding
Tools increase onboarding conversion up to 95%.
Automated KYC, biometrics and eIDAS
Setting up risk-based scoring and alerts
Risk-based approach in scoring: the AML risk map generates alerts for transaction monitoring.
Verification of eKYC/AML providers’ competencies
Choose based on MAS guidelines and eIDAS regulation. Verify FATF compliance.
Compliance officers’ mistakes in bank onboarding
Underestimated SOF/SOW and an incomplete documentation package
Ignoring PEP and the lack of EDD
Strategic consequences of ignoring the PEP declaration for scaling the business: loss of licenses. Implement EDD in a timely manner.
eID issues and verification delays
EU eIDAS onboarding requires qualified signatures; test in advance.
Template of the СДЛ questionnaire (key fields):
- UBO data
- SOF/SOW evidence
- PEP status
- Risks (download from COREDO).
How to build sustainable banking relationships
Focus on the long term.
Contract terms and SLAs with the bank and compliance service providers
Chief Compliance Officer vs external consultant
The compliance officer oversees internally, external: AML legal support for complex cases.
Strategies when accounts are frozen
Account freezes (AML): appeal with an audit, strategies to reduce AML fines during bank onboarding.
Checklist for launching secure onboarding
Brief checklist for negotiations with the bank (must/higher/optional):
- Must: Self-risk assessment + AML risk map.
- Must: Questionnaire for related parties (СДЛ) + UBO.
- Must: AML audit before onboarding for PEPs.
- Higher: Source of funds verification.
- Higher: PEP screening + EDD.
- Higher: Digital onboarding (eIDAS/MAS).
- Optional: Biometrics to speed up.
- Must: SLA for monitoring.
- Higher: KPI dashboard.
- Must: Document testing.
- Optional: External ROI audit.
- Must: Annual update.
| Step | Timeframes | Responsible |
|---|---|---|
| 0: Self-risk | 3 days | Internal team |
| 1-3: Documents | 10 days | Compliance officer |
| 4: AML audit | 15 days | External provider |
| 5-6: Integration | 7 days | Bank + CRM |
FAQ from the compliance officer
When is an AML audit mandatory before bank onboarding for an investment company with a PEP?
How to reduce the onboarding rejection rate to 5% using a compliance audit?
Which metrics should be tracked to assess the effectiveness of digital onboarding under eIDAS?
How to calculate ROI from implementing AML compliance for investment firms in the EU and Asia?
What account-blocking risks do investment companies face without source of funds checks?
Is it worth investing in an external AML audit for long-term banking relationships?
Key findings and recommendations for executives
- Conduct a risk self-assessment in the first week.
- Order an AML audit before PEP onboarding to assess PEP risk.
- Collect the full source of funds in advance.
- Implement digital onboarding for EU‑Asia with eIDAS/MAS.
- Track the onboarding conversion rate monthly.
- Calculate the compliance ROI before investing.
- Sign an SLA for sustainable banking relationships.
- Scale up with transaction monitoring systems.