As CEO and founder of COREDO, I often encounter situations where investment companies lose access to bank accounts due to strict anti-money laundering checks such as 115-ФЗ.
Important to understand: a bank refusal under 115-ФЗ is not a subjective decision of a particular manager and not a “failure with the bank”. It is a systemic signal that the business model, transactional logic or the company’s AML contours do not fit the risk profile of the credit institution.
Imagine: your investment company is growing, contracts with partners from the EU and Asia are pouring in, but suddenly the bank refuses service. An account freeze paralyzes the company’s payments, and the bank’s motivated refusal refers to risks under 115-ФЗ, lack of an economic purpose for transactions or suspicions of one-day companies.
COREDO’s practice confirms: in 2025 such cases have increased due to strengthened KYC procedures (Know Your Customer) and the banks’ risk-based approach. The bank’s financial monitoring service records the slightest inconsistencies, and the account is blocked for up to 30 days.
If the model looks unconvincing, the bank blocks transactions preventively, even without a direct violation of the law.
But let’s analyze why banks refuse investment companies. Main reasons:
- weak internal AML control of the investment company,
- insufficient counterparty checks under 115-ФЗ,
- lack of transparent business accounting.
For example, if counterparties’ due diligence is not documented, the bank will deem the transactions risky. In the EU and Asia local equivalents apply: FATF recommendations require evidence of a real economic purpose for transactions, and sanctions risks for investment companies increase scrutiny.
- turnover inconsistent with the declared activity;
- absence of a documented economic purpose for transactions;
- the transit nature of payments (rapid “in-and-out”);
- counterparties without a transparent structure or with a negative media footprint;
- formal AML without real control procedures;
- absence of management reporting explaining the movement of funds.
Even one of these factors can become grounds for refusal.
The COREDO team has developed a clear action plan for such scenarios. The first step is analyzing the bank’s motivated refusal. The critical mistake is to act chaotically: submit applications to dozens of banks, change the accountant or “hide” transactions. This worsens the company’s profile. After a refusal a structured response is important with fixation of causes and corrective actions.
It should be understood: even a perfect explanatory note does not always lead to unblocking. If the company’s risk profile exceeds the bank’s internal limits, it will not continue the relationship — regardless of the correctness of the documents. In such cases the goal is not to “break” a specific bank, but to clean the history and prepare for the next stage: appeal or migration.
If all banks refuse the investment firm, we move to appealing the bank’s refusal under 115-ФЗ: we file a complaint with the Central Bank about the refusal, with a full package of documents for the Central Bank’s interdepartmental commission (MVK).
The interdepartmental commission at the Central Bank evaluates evidence, not emotions. The key is to show that the company understands its risks and manages them.
In our cases the MVK responds positively to:
- a formalized AML framework;
- a risk matrix;
- a review of business processes;
- staff training;
- adjustment of contracts and transaction logic.
What to do if no bank accepts the investment company? We move to rehabilitation under 115-ФЗ. The steps to rehabilitate a business after a bank refusal are simple but require expertise: collect evidence (contracts, invoices, certificates of residency), conduct an audit and submit to the MVK at the Central Bank.
On the other hand, relying only on local banks is risky. An international structure today is not an attempt to evade oversight, but a risk management standard. Investors and EU banks accept holding models with distributed functions: an operating company, an investment SPV, a payment structure. The main thing is transparency and alignment of the AML approach across all jurisdictions.
A solution developed at COREDO is registering a legal entity abroad to open an account for the investment company.
InThe UAE, especially in Free Zones, registration takes 3 days, with 100% foreign ownership and zero corporate tax for many operations.The differences in banks’ approaches are fundamental:
- in the EU banks analyze the economic logic and business structure more deeply;
- in the UAE – focus on the source of funds and substance;
- in Asia – special attention to sanctions and PEPs.
COREDO designs the structure so that one rejection does not “infect” other banks through a negative profile.
To scale an investment business after a banking rejection the COREDO team recommends Estonia or the Czech Republic in the EU. In Estonia e-Residency allows online registration of an OÜ in 1–3 days, with a focus on fintech and crypto licenses. We helped an investment firm obtain a payment license by passing KYC and substance requirements (a real office, local staff), which opened accounts in European banks without rejections. In Slovakia and the Czech Republic COREDO’s practice confirms success with bank accounts for investment companies: low bureaucracy, residence permits through business and integration with EU AML standards.
AML consulting, key to preventing repeat rejections. We implement internal AML control: a risk-based approach, automated counterparty checks and staff training. For investment firms this means due diligence according to FATF, transaction monitoring and reporting that convinces banks of reliability.
After implementing full AML control companies gain not only access to accounts, but also:
- faster payments;
- increased counterparty trust;
- reduced operational pauses;
- the ability to scale without repeat rejections.
obtaining financial licenses strengthens positions. The COREDO team supports everything from crypto licenses in Cyprus (CySEC) to forex and banking in Singapore. The process: document submission, substance-proof and compliance audit. In Dubai a VARA license for crypto investments opens doors to Asian PSPs, bypassing local blocks.
Strategic planning of banking relationships is our priority. After a rejection we assess migration of accounts to alternative jurisdictions, including Africa (for niche investments), but we focus on the EU and Asia. Transparent business accounting and risk management compliance help avoid sanctions risks for investment companies.
How to pass a bank’s counterparty reliability check? We conduct due diligence: PEP check, sanctions lists, analysis of the ownership chain. This is the standard for opening an account for an investment company in the EU.
The conclusion is simple: a bank rejection under Federal Law 115-FZ is not a sentence, but an audit of the business model in a strict format. Companies that use this moment for rehabilitation and restructuring come out stronger and more resilient.
At COREDO we support this process fully – from analyzing the rejection to a new banking architecture.