Last reviewed October 7, 2026 · By the NYBACS advisory team
Short answer
Banks typically ask a foreign-owned US company for its formation certificate, operating agreement or bylaws, IRS EIN letter and ownership records identifying every individual who owns 25% or more, plus a passport and proof of residential address for each of those owners and for the person who controls the company. Where a foreign company owns the US entity, expect parent registry extracts, shareholder registers and sometimes certified translations or apostilles.
Key takeaways
- Documents fall into four groups: the US entity, its ownership chain, the individuals involved and the business itself.
- The IRS EIN letter (CP 575, or a 147C verification letter if the original is lost) should show the company's name exactly as on the formation certificate.
- When a foreign parent owns the US company, banks follow ownership up the chain until they reach the individuals who own 25% or more indirectly.
- Non-English documents usually need a certified translation, and some institutions ask for apostilled copies of foreign corporate records.
- Most institutions want recent documents: an old registry extract or an address proof from last year is a frequent reason for resubmission.
Company documents: proving the entity exists and who can act for it
The first group establishes that the US company is real, in good standing and authorized to open the account:
- Certificate of formation or incorporation stamped or issued by the state, with the articles if filed separately.
- Operating agreement (LLC) or bylaws (corporation), signed, showing members or shareholders and management.
- EIN confirmation letter from the IRS. If the original CP 575 is lost, the company can request a 147C verification letter.
- Certificate of good standing, often requested when the company is not newly formed or is applying in a state other than its state of formation.
- Resolution or written consent authorizing the account and naming the signers, particularly for corporations and multi-member LLCs.
Check that the legal name is identical on every document. "Acme Global LLC" on the certificate and "Acme Global, LLC" on the EIN letter can be enough to stop automated verification.
Ownership documents from the US company up to the individuals
Banks must identify each individual who owns 25% or more of the company, directly or indirectly, and one individual with significant control. For a founder who owns the LLC directly, the operating agreement may be sufficient. For layered structures, expect to provide:
| Ownership situation | Documents commonly requested |
|---|---|
| Individual owners only | Operating agreement or stock ledger and share certificates showing percentages |
| Foreign parent company | Parent's certificate of incorporation, current registry extract, register of shareholders and register of directors |
| Several layers of companies | An ownership chart showing every entity and percentage up to the individuals, with documents for each layer |
| Trust or foundation in the chain | Trust deed or foundation charter and details of trustees, settlors and beneficiaries |
Some institutions also accept or request a certificate of incumbency for a foreign parent, and many collect ownership below 25% for higher-risk relationships, which the CDD rule allows.
Personal documents for owners, controllers and signers
Every beneficial owner, the control person and each authorized signer is usually asked for:
- A valid passport, scanned in color with the photo page fully legible. US persons provide their Social Security number instead of or in addition to it.
- Proof of residential address, typically a recent utility bill, bank statement or government letter in the person's name.
- Date of birth and residential address entered on the application exactly as they appear on those documents.
- Identity checks — fintech platforms in particular often require a selfie or live video check matched to the passport.
A signer who owns nothing is still verified. Founders sometimes add a relative or adviser as a signer without realizing that person must go through the same checks.
Business documents that explain the account's purpose
Identity documents show who is behind the company; business documents show what the account is for. Institutions commonly ask for:
- the company website and a business email on the same domain;
- a written description of products, customers and suppliers;
- signed contracts, invoices or purchase orders, where trading has started;
- expected monthly deposits and withdrawals, typical transaction sizes and the countries involved;
- the source of the initial deposit, such as the parent company or the founder's own funds.
For a subsidiary of an established foreign group, the parent's recent financial statements and a short explanation of the US expansion often carry more weight than anything the brand-new US entity can show.
Translations, certification and freshness
Foreign-owned applications are slowed more by document quality than by missing categories. Before submitting:
- Translate non-English documents through a certified translator and keep the originals alongside.
- Certify where asked. Some institutions request notarized or apostilled copies of foreign registry documents; the Hague Apostille Convention applies between member countries, while other countries use consular legalization.
- Check dates. Registry extracts and address proofs are often expected to be issued within the last few months.
- Match names. Transliterated names on passports, registry records and utility bills should be consistent, or explained.
- Check expiry. A passport close to expiry may be rejected or trigger a request soon after opening.
Common mistakes to avoid
- Submitting an unsigned or template operating agreement that does not show actual ownership percentages.
- Providing the parent company's documents but no chart showing which individuals ultimately own it.
- Using a registry extract or address proof that is many months old.
- Sending non-English corporate documents without a certified translation.
- Entering a company name on the application that differs in punctuation from the EIN letter.
- Adding a signer at the last minute who has not prepared a passport and proof of address.
Documents and records to prepare
- Certificate of formation or incorporation and filed articles
- Signed operating agreement or bylaws
- IRS EIN letter (CP 575) or 147C verification letter
- Certificate of good standing, if requested
- Resolution or consent authorizing the account and signers
- Ownership chart down to every individual owning 25% or more
- Parent company registry extract, shareholder and director registers, and certificate of incumbency where applicable
- Passport and recent proof of residential address for each owner, the control person and each signer
- Business description, website, contracts or invoices, and expected activity summary
- Certified translations and apostilled or legalized copies where the institution asks for them
NYBACS 360° support
How NYBACS helps
- Assembles a complete, bank-ready document pack for the US company and checks names, dates and percentages for consistency.
- Builds an ownership chart that traces a foreign parent structure up to the individual beneficial owners.
- Obtains EIN verification letters, good standing certificates and other US records you are missing.
- Coordinates translations and apostilled copies of foreign parent documents with your home-country advisers.
Frequently Asked Questions
Do I need to send original documents?
Usually not. Most institutions accept clear scans or photocopies for documentary verification and may ask for certified copies where a document's authenticity needs extra support. Keep originals available in case they are requested.
What if I lost my EIN confirmation letter?
The IRS can issue a 147C letter confirming the EIN and the name on file. Request it before applying, because banks generally want written IRS confirmation rather than a number typed into a form.
Does the bank need my company's tax returns?
Not for a newly formed company. Established companies may be asked for recent returns, especially when applying for credit or when a review questions how activity compares with reported income.
Will the bank ask about owners with less than 25%?
It may. The 25% threshold is the federal minimum, and institutions may collect information on smaller owners when their risk assessment calls for it, which is common for complex or higher-risk structures.
Do documents need to be apostilled?
Only when the institution asks. Apostilles are most often requested for foreign parent-company records and certificates of incumbency, and countries outside the Hague Convention use consular legalization instead.
