Over the past year, all US banks (traditional banks, online banks, Neobanks, Fintech platforms, and Electronic Money Institutions) have tightened their requirements and gotten much more strict regarding non-US resident LLC bank accounts. Unfortunately, at this time, we don’t have any solid recommendation. Please check out the conversations below in the comment section. If anything changes, we will update this page. Thank you for your understanding.
How non-US residents can apply for a bank account for an LLC
Here are our top 2 recommendations for bank accounts (online) for non-US residents:
Wise is the easiest account to get approved for, followed by Relay.
Wise
Wise is great for:
getting an account setup (approval is the easiest)receiving USD from clients/customers/sales
Wise is not a bank. They are technically an Electronic Money Institution (EMI). And while they hold customer funds in various (and separate) bank accounts, your money is not FDIC-insured (like it is with Relay).
However, many people transfer (most of) their money from the Wise account to their bank account in their home country. And this can help avoid the risk of losing your funds if Wise were to go out of business.
Wise has good reviews and most people enjoy their services. We pay many vendors via bank transfer to their Wise account, and they are all happy with their accounts.
Relay
Relay is not a bank either (neither is Mercury). They are both Financial Technology (FinTech) companies. Meaning they partner with other banks (and those banks hold your funds). Relay and Mercury both provide an “overlay”. It’s like a new UI (user interface) “on top” of the banks. This means they are able to offer FDIC insurance.
We don’t have a lot of experience with Relay yet, however, some colleagues in the industry recommends them for non-US residents.
What about Mercury?
It used to be easier to open an account with Mercury (and they used to be our top recommendation), however, many of our readers have had issues getting approved recently. And Mercury is now asking for US addresses (and no longer accepting a Registered Agent address).
We think this is because Mercury has increased their compliance requirements and is more strict about who they approve and don’t approve.
We’re not saying not to open an account with Mercury, however, it seems more non-US residents have both been denied accounts and have had issues after opening accounts (such as request for proof of US address).
Documents needed to open a US bank account
1. LLC approval documents
Depending on the state where you form your LLC, this will be either:
- Articles of Organization
- Certificate of Organization
- Certificate of Formation
2. Identification
Most people use a passport from their home country. This is the best and most common option.
If you also have US ID, like a US driver’s license, you can use that too.
3. LLC/business address
For Wise, you’ll enter your LLC’s “registered address”. This can be your Registered Agent address.
You’ll also enter your “trading address”. This is where you work. This can be in the US or in any country. It can be a home address or office address. It can also be a co-working space, shop, studio, or factory.
And then you’ll enter your home address.
(Note: The process is similar at Relay, but the names of the addresses are slightly different.)
4. Employer Identification Number (EIN)
If you need an EIN for your LLC, please see how to get an EIN without an SSN.
You will need to show proof of your LLC EIN Number (aka Federal Tax ID Number).
Some banks let you just enter the EIN Number. And others want proof.
If the bank wants proof, you can use:
- Approved SS-4 fax application (with EIN written on it)
- EIN Confirmation Letter (CP 575)
- EIN Verification Letter (147C)
Traveling to the US and opening an LLC bank account in person
You can also open a U.S. bank account for your LLC by traveling to the U.S.
You will need to open an LLC bank account in the same state where you formed your LLC.
The bank that is the most “foreigner-friendly” is Wells Fargo. They are used to opening accounts with non-US residents who don’t have an SSN or ITIN. However, you should call the bank and check on their requirements. Some banks will require you to have an actual US street address.
You can also try calling Chase as well, although, minimum balance requirements and monthly fees are usually higher at Chase than at Wells Fargo.
Call the bank ahead of time
Since all banks have different policies, the most important thing to do is call ahead of time and ask to speak to the branch manager.
Tell them you have a U.S. LLC, that you are a non-US resident, and that you don’t have an SSN or ITIN.
Ask them for all the documentation they require to open an account and take detailed notes.
Ask the branch manager if you can email them your documents to review before you come in.
If everything is good, ask the branch manager if you can make an appointment to meet with them to open the account. This is much better than just showing up at the bank.
We recommend staying in the U.S. for at least 1 to 2 weeks just in case there are any delays or extra things you need to get in order to open your bank account.
Small local banks
You can also open an LLC bank account with any small or local bank.
You can google: “business bank account + (name of city that matches LLC address)“.
Again, just make sure to call the bank to check on their requirements.
Documents needed to open U.S. LLC bank account
- LLC approval (Articles of Organization, Certificate of Organization, or Certificate of Formation)
- EIN Confirmation Letter (CP575) or EIN Verification Letter (147C) from the IRS
- LLC Operating Agreement
- 2 forms of identification (foreign passport and foreign driver’s license)
There may be additional documents that some banks require. Make sure to call the bank ahead of time and ask.
Proof of address
With some banks, you may be able to use your LLC’s address as listed in your state documents and EIN Letter from the IRS.
However, other banks require additional documentation to show “proof of address”. Things like a lease, utility bill, or phone bill are sometimes required by certain banks.
Make sure you call and fully understand what’s needed before you visit the bank.
If you need to open a bank account in person and need proof of address, Northwest offers a Virtual Office service that includes a business address and lease.
U.S. phone number
Having a U.S. phone number will make the bank feel more comfortable doing business with you.
You can get a U.S. phone number and use it as both your cell phone number and your LLC’s business phone number.
You can get a U.S. SIM Card when you visit or you can get a digital phone number that forwards calls to your cell phone (a U.S. cell phone or a non-U.S. cell phone).
The service we recommend is Phone.com. They have good customer service and their plans are only $10-13 per month. You get a U.S. telephone number, call forwarding, and get voicemail messages sent to your email.
You can also use Google Voice or any other VOIP provider.
Beneficial Ownership
In 2018, the Financial Crimes Enforcement Network (FinCEN) rule about “Customer Due Diligence Requirements” went into effect.
This rule (also called Beneficial Ownership Rule) is required for all banks opening business bank accounts. They must identify the true owners of business before they can open a bank account.
The purpose of the Beneficial Ownership rule is to prevent illegal financial activity, like money laundering, fraud, and tax evasion.
The bank will provide you a Declaration of Beneficial Ownership form to complete before they open your account.
OFAC Restricted Countries
Because of U.S. sanctions, you won’t be able to open a bank account if you reside in:
- Belarus
- Burundi
- Central African Republic
- Cuba
- Democratic Republic of Congo
- Iran
- Iraq
- Lebanon
- Libya
- Nicaragua
- North Korea
- Somalia
- Sudan
- South Sudan
- Syria
- Ukraine/Russia (Crimea)
- Venezuela
- Yemen
- Zimbabwe
The U.S.-sanctioned countries list changes from time to time, so you will need to check the Sanctions Programs and Country Information issued by the U.S. Department of Treasury.
LLC Banking Resolution
A Banking Resolution is a document that describes which LLC Member(s) have the authority to open a bank account.
The bank will provide you with their own Resolution form, so you don’t have to prepare one ahead of time.
Tip: If you see a website charging extra money for a Banking Resolution, it’s not going to be very helpful, since the bank will just use their own form.
Monthly banking fees
Most banks have different “levels” of business bank accounts. They all have different names (depending on the bank), but they are usually as follows:
- basic account (works for most people)
- intermediate account
- advanced account (for large commercial businesses)
The intermediate and advanced accounts require you to keep more money at the bank (deposits) and they charge higher monthly fees.
Most of our readers just stick with a basic business checking account for their LLC.
Usually, banks will not charge a monthly fee if you keep a $1,000 – $2,500 balance in the bank at all times.
If a bank does have monthly fees, they are usually $10 – $15 per month.
Initial deposit amount
Ask the bank ahead of time about the initial deposit requirement. This is how much money you must put into the account when you open it.
For non-US residents, we recommend using cash (USD) when making the first deposit. However, if you already have a US checking account, then you can write a check to your LLC for the initial deposit.
Some banks want $500 or $1,000 for the initial deposit. However, other banks only require you to deposit $100 to open an account.
Minimum balance requirements
Some banks charge a monthly fee if your balance goes below a certain amount.
For example, for most LLC bank accounts, you must keep $500 to $2,500 in the account (at all times) to avoid monthly fees.
This minimum balance requirement varies among banks, so just call the bank ahead of time and ask.
Again, if there are monthly fees, most banks charge $10 – $15 per month.
Note: Chase and CitiBank have higher balance requirements; $2,500 or $5,000. These banks also have higher monthly fees. On the other hand, Wells Fargo and TD Bank have lower monthly fees, or no fees at all.
Business debit card for your LLC
Call the bank and ask when you will get a debit card for your LLC bank account.
Most banks will give you a debit card right after they open your account.
However, some banks will mail your debit card in 1 to 2 weeks.
If the bank will mail the debit card, ask them which address it will be sent to. Make sure you can receive mail there. Or ask the bank if they can mail your debit card to your address outside of the U.S.
Do I need an SSN to open an LLC bank account?
No, you don’t need a Social Security Number (SSN) to open a U.S. LLC bank account.
Do I need an ITIN to open an LLC bank account?
No, you don’t need an Individual Taxpayer Identification Number (ITIN) to open a U.S. LLC bank account.
In fact, you can’t even apply for an ITIN unless you have a U.S. tax reporting requirement. If you do need an ITIN or have questions about U.S. taxes, we recommend talking to GW Carter. They specialize in working with non-US residents.
References
Wikipedia: Know your customer
LexisNexis: The USA Patriot Act
FINRA: Anti-Money Laundering (AML)
Wikipedia: Customer Identification Program
FinCEN: History of Anti-Money Laundering Laws
US Department of the Treasury: Where is OFAC’s Country List
Electronic Privacy Information Center: USA Patriot Act (HR 3162)
CFPB: Can I get a checking account without a social security number
Department of the Treasury: 31 CFR Part 103 (Billing Code: 4810-02)
US Code: 31 USC 5318, Compliance, exemptions, and summons authority
US Department of the Treasury: Sanctions Programs and Country Information
US Code: 31 USC 5318A, Special measures for jurisdictions, financial institutions
US Code: 31 U.S. Code § 5318. Compliance, exemptions, and summons authority
National Association of Securities Dealers: Special NASD Notice to Members 02-21
US Department of the Treasury: Office of Foreign Assets Control – Sanctions Programs and Information
GPO: CFR 2010 Title 31 Volume 1 Section 103-121 (Subpart I—Anti-Money Laundering Programs)
FinCEN FIN-2016-G003: FAQs Regarding Customer Due Diligence Requirements for Financial Institutions
Matt holds a Bachelor's Degree in business from Drexel University with a concentration in business law. He performs extensive research and analysis to convert state laws into simple instructions anyone can follow to form their LLC - all for free! Read more about Matt Horwitz and LLC University.
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