Unexplained bank rejection how to structure a repeat onboarding

Nikita Veremeev

18.01.2026 | 6 min read

Updated: 18.01.2026

When an entrepreneur encounters a bank refusal without explanation for the first time, it is perceived as the personal decision of a particular manager or the bank’s “whim”. In practice this is almost always the result of a formalized risk-based approach, internal risk policies and the outcomes of automated bank compliance for businesses.

Over the years of COREDO‘s work with international banks in Europe and Asia I have seen that the key mistake businesses make is to treat a refusal as the final point. In fact, it is a signal: your profile in the bank’s eyes and your internal compliance system do not match its risk appetite. That means this can and should be managed.

In this article I will explain how to:

interpret a bank’s refusal to open a company’s current account and a subsequent refusal by the bank to service the business;
prepare for initial and repeat onboarding at the bank;
reduce the risks of a company’s account being blocked in the long term;
build systematic AML support for companies and an internal compliance that banks perceive as an asset rather than a problem.

Reasons a bank might refuse a loan

Illustration for the section “Why a bank refuses a loan: reasons” in the article “Bank refusal without explanation – how to structure a repeat onboarding”

The phrase “refusal without explanation” protects the bank from disputes and from revealing risk-management methodologies. But there are almost always reasons. In COREDO’s practice, five blocks are most common.

Jurisdictional and industry risks

The bank assesses:

the country of company registration;
the country of tax residency of the beneficiaries;
the countries of counterparties and the geography of payments;
the industry (fintech, crypto, gambling, forex, PSP, cross-border e-commerce, etc.).

If the jurisdictional risk during onboarding at EU and Asian banks and the industry are both considered high-risk, the probability that a bank will refuse to service an active company increases sharply.

In one COREDO case we structured a group where the holding was located in a neutral European jurisdiction, the operating companies were in Asia, and the clients were worldwide. Without explaining the logic of the structure and documenting the economic rationale of the operations for the bank, it looked like a set of “shell” companies. After preparing a detailed diagram of business processes, substance and tax logic, the bank not only approved the account but also expanded the limits after several months of operation.

Ownership and beneficiary structure

The bank considers important:

whether there is a clear ultimate beneficial owner (UBO);
whether there is an excessive number of ownership layers;
whether trusts, foundations, or nominee structures are present;
whether there are PEP / sanction risks, negative news.

If a transparent beneficiary structure is not established for the bank, the bank will assess the company’s reputational risk as unacceptable.

In such cases the COREDO team often adjusts the ownership structure for bank onboarding: we simplify levels, bring the UBO “into the light”, and document connections and sources of funds.

Business model and transactional profile

A bank’s scoring of a corporate client today relies not only on the industry but also on the expected transactional pattern:

payment volumes and frequency;
share of cross-border transfers;
currencies;
types of counterparties and jurisdictions.

If the model looks non-standard, banks may refuse service to companies with non-standard business models, particularly often when onboarding fintech and payment companies.

In COREDO’s practice there was a client: a payment intermediary with a history of high chargebacks and disputed transactions at the previous PSP. We conducted a legal audit of the company before submitting the bank application, rebuilt the contractual base with merchants, implemented an anti-fraud policy and prepared an evidence base to justify the legality of revenues. After that, reopening an account after a compliance refusal became possible at another European bank.

Client history and external signals

Banks widely use:

negative news screening and reputational risk;
public registers, court cases, media;
internal and external watchlists/blacklists.

If a company has already been delisted by a bank and offboarded, this affects how it is perceived by other banks.

We encountered the case “client on another bank’s blacklist: what to do”: we collected documents explaining the past case (an erroneous alert on a transaction, incorrect interpretation of a counterparty), and prepared a separate memorandum for the new bank, minimizing the risk of inclusion in the bank’s internal blacklist already at the application stage.

Bank risk appetite and scorecard

Even a legally perfect structure may not pass a bank’s internal scorecard for assessing corporate clients.

What applies here:

the risk-based approach in banks and client refusal if the total scoring score is below the threshold;
temporary restrictions by industry (for example, a bank “closes the window” to new crypto clients);
changes in country policies.

At COREDO, our bank-selection consultations always begin with an assessment: do the client’s business model and the potential bank’s risk appetite match by country and industry.

What to do in case of a bank refusal?

Illustration for the section 'What to do in case of a bank refusal?' in the article 'Bank refusal without explanation – how to build a repeat onboarding'

If a bank refusal occurs without explanation, the company has three key tasks:

record the consequences (and not worsen the situation);
understand what exactly triggered it;
set up a repeat onboarding after the bank refusal – either with the same bank or with another bank.

Maintaining control of the situation

Practical minimum:

do not argue emotionally with the bank and do not ‘press’ for disclosure of reasons;
request a written notice of refusal/account closure (if the bank issues one);
clarify the account closure timeframe and the procedure for withdrawing funds;
record in your system the date and circumstances of the refusal – this will be useful when analyzing the bank refusal and preparing for repeat onboarding.

At this stage COREDO usually steps in with legal support in cases of bank refusal: we assess whether there is value in a legal challenge strategy, or whether it is more appropriate to focus on onboarding with another financial institution.

Internal due diligence of the company

Before applying to a new bank, it is important to:

conduct a legal audit of the company before submitting the application to the bank;
assess how your company appears through the lens of AML/KYC:
- beneficiaries;
- contractual framework;
- counterparty policy;
- source of funds / source of wealth;
- transaction and blocking history.

The COREDO team often models a bank’s risk assessment of a client: we apply an approach similar to the bank’s logic, analyzing jurisdiction, industry, reputation, media screening, structure, and transactions. This allows us to see in advance which alerts will be triggered in a bank’s scoring of a corporate client.

How to create a transparent picture of the business

Internal package to prepare before contacting the bank:

corporate documents;
ownership structure with a visual diagram;
description of the business model and the value chain;
key contracts;
policy for working with counterparties;
financial statements.

It is at this stage that we at COREDO build transparency of cash flows for the bank: we document the economic rationale of operations, sources of receipts and expenditures, and explain why transactions go through specific jurisdictions.

Strategy for repeat onboarding

After the internal audit, the question arises: where exactly to undergo secondary onboarding after a bank refusal. Options:

the same bank (if the refusal is related to missing documents or incomplete disclosure of information);
another bank in the same jurisdiction;
a bank in another country, with a different risk appetite;
a combination of a traditional bank and EMI/fintech solutions (as part of a ‘multibanking’ strategy).

The solution developed by COREDO for clients with a history of refusals is a roadmap for repeat onboarding: we gradually change structure, contracts, and internal procedures, while simultaneously testing interest from various banks in the EU, the United Kingdom, Singapore, and other jurisdictions.

How to prepare for onboarding at a foreign bank

Illustration for the section «How to prepare for onboarding at a foreign bank» in the article «Bank refusal without explanation – how to build a repeat onboarding»

Onboarding of corporate clients in Europe and Asia today is not just filling out a form. It is a comprehensive check of KYC/KYB, transactional logic, substance and reputation.

Documents for bank onboarding

Standard package:

incorporation documents;
register of shareholders / UBO;
documents of directors and beneficial owners (ID, proof of address);
description of activities and business plan;
key contracts;
financial statements and tax filings (if there is a history).

For companies with elevated risk: additionally:

confirmation of economic substance (office, employees, real operations);
company policy & procedures on AML/KYC;
internal policies on counterparties and transactions;
description of transaction monitoring systems / transaction monitoring within the company.

The COREDO team regularly prepares KYC packages for clients for foreign banks: from corporate document templates to business description phrasing that is clear to a compliance officer.

KYC for legal entities and KYB

In KYC for legal entities and KYB procedures the bank checks:

who the ultimate beneficial owners and controlling persons are;
whether there are nominee shareholders without a real economic role;
whether the stated activity corresponds to the contract base;
whether there is confirmation of source of funds / source of wealth.

If discrepancies are identified: a high risk of refusal in the bank’s compliance check.

Therefore one of the key areas of COREDO’s AML consulting is the adjustment of contracts and business processes to AML requirements/KYC, so that the business appears to the bank exactly as it operates in reality.

How to prepare for digital onboarding

With the growth of digital onboarding / remote onboarding, banks’ requirements for the quality of data and documents have tightened. Automated systems:

analyze documents for forgeries;
cross-check data with external registries;
immediately run screening against sanctions lists and PEPs;
apply pre-configured risk scoring models based on transaction patterns.

To reduce the risk of rejection during remote onboarding, at COREDO we:

prepare documents in advance in formats that are easily read by systems;
fill out questionnaires so they are consistent with each other and with corporate documents;
prepare the client for possible re-identification by the bank, video interviews and follow-up questions.

Bank’s refusal to serve a company

Illustration for the section “Bank refusal to serve a company” in the article “Bank refusal without explanation – how to arrange a repeated onboarding”

Bank refusal to serve an operating company and the subsequent offboarding of the client (bank delisting) is one of the most painful scenarios.

It is often associated with:

triggering an alert in the transaction monitoring system and refusal of service;
activation of sanctions or negative media screening;
a change in the profile of operations without properly explaining it to the bank.

Reasons for blocks and offboarding

Typical triggers:

a sharp increase in turnover without prior notice;
a change in the geography of payments (for example, a mass entry into new markets);
an increase in the share of cross-border payments;
transactions atypical for the previously observed profile.

Internal alerts and triggers in AML systems initiate a manual review by a compliance officer. If the company cannot quickly and convincingly provide documents and explanations, the likelihood of a bank refusal following the AML check increases significantly.

How to communicate with the bank after a refusal

If a refusal has nevertheless occurred, at COREDO we almost always recommend that the client develop a communication strategy with the bank after the refusal:

record exactly which questions compliance raised;
prepare a structured package of responses and documents;
if possible, request a formal reconsideration (if there are grounds).

Sometimes this allows the scenario to be shifted from a “hard delisting” to a controlled exit or to postpone the account closure date, which is critical for operational activity.

How to reduce the risk of compliance rejections

Illustration for the section «How to reduce the risk of compliance rejections» in the article «Bank refusal without explanation – how to arrange a repeat onboarding»

Mature businesses today perceive banking compliance support services not as «additional expenses», but as an investment in access to the financial infrastructure.

Which internal policies do banks need?

From COREDO’s practice, the minimum looks like this:

AML policy and procedures (KYC/KYB, handling high-risk counterparties, sanctions lists);
transaction monitoring policy;
procedure for responding to requests from banks and regulators;
a documented policy on sources of funds and confirmations of beneficiaries’ incomes;
a retention policy for documents and the evidentiary record.

This way the company demonstrates to the bank that anti-money-laundering legislation for business is not a formality, but an integrated part of risk management.

How to manage a bank’s reputational risk

Banks pay special attention to:

beneficial owners’ public profile;
media mentions;
litigation and regulatory cases.

When the COREDO team helps clients manage reputational risk with a bank, we:

conduct negative-news screening in advance and view the company through the bank’s eyes;
prepare explanations for sensitive cases;
where necessary, structure communications so the bank receives context rather than fragments of information.

Multibanking strategy and choice of jurisdictions

One of the most practical takeaways we advise our clients is: don’t build your business relying on a single bank. Especially when it comes to an international group of companies.

Why do businesses need multibanking?

The strategic objective is to distribute:

operational payments;
reserves;
settlements with regulators and partners

across several banks and jurisdictions with different bank risk appetites by jurisdiction and industry.

With this approach, even a bank’s rejection of PSPs and payment intermediaries, or offboarding at a single bank, won’t paralyze operations.

How to choose banks in Europe and Asia

Our experience at COREDO has shown that for companies from the CIS operating in the EU and Asia, it’s important to consider:

real economic substance in the chosen country;
transparency of the tax model;
the presence of a direct and clear beneficial owner;
the bank’s sector policy.

We often structure things to combine:

company incorporation and subsequent bank onboarding in the same jurisdiction;
and opening additional accounts in other countries (for example, one account in the EU, another in Singapore).

How to minimize rejections during COREDO onboarding

I’ll outline, in practical terms, how the COREDO team typically gets involved in projects where there is already a refusal to open a corporate bank account or a risk of delisting.

Site audit and strategy

Legal and compliance audit: structure, contracts, beneficiaries, transactions.
Modeling bank scoring for a corporate client across different jurisdictions and types of banks.
Developing a strategy:
- we adapt the business model and structure to the requirements of target banks (restructuring the business model to meet the bank’s requirements);
- or we choose financial institutions whose risk appetite better matches the company’s current profile.

KYC dossier and onboarding: preparation

The COREDO team has carried out dozens of projects where the key to success was the careful preparation of the KYC package for a foreign bank:

we prepare a package of documents and business descriptions;
we work out responses to standard and complex questions from compliance officers;
we prepare a guide for an in-depth compliance interview with the bank;
we manage communications until a decision is reached.

In account-opening cases for high-risk companies (fintech, PSP, crypto), we almost always combine client preparation with adapting the company’s internal policies & procedures for AML/KYC so the bank sees not only the ‘documents submitted’ but also the maturity of internal controls.

AML support for companies

A separate area: support after account opening:

assistance in responding to regular queries about transactions and counterparties;
documenting changes (change of beneficiaries, changes to the structure, expansion of payment geography);
preparing for limit increases or the addition of new products.

COREDO’s experience shows: companies that invest in systematic AML support far less frequently encounter a bank’s refusal to service their business or a bank refusal following AML checks.

To summarize my experience since 2016, resilience to bank rejections is not about “finding the one right bank”, but about building your business, structure and processes so that banks see you as a predictable, manageable and understandable partner.

And it is exactly here — from registering legal entities abroad to obtaining financial licenses and supporting complex onboardings in banks across the EU, the UK, Singapore and other jurisdictions — that the COREDO team helps clients keep their focus: not merely to open an account, but to build a sustainable model for interacting with the financial system for years to come.