Banks ask for more than they did two years ago. A plain list of what to have ready before you start talking to anyone.
Every cross-border transaction now runs into the same question, and it is asked earlier and more forcefully than it was two years ago: where did the money come from, and how do you know?
The question is not an accusation. It is a bank, a notary or a counterparty being asked to take responsibility for an answer they cannot check themselves. The people who move fastest are the ones who can hand over a complete answer on the first request rather than assembling it over six weeks of email.
Here is what a complete answer usually contains.
- Audited accounts for the last three years, signed, in the language of the jurisdiction and in English if that is not the same thing.
- A corporate structure chart that reaches actual human beings, not another holding company.
- Evidence for the specific funds in question — the sale, the dividend, the facility — rather than evidence that the business is generally profitable.
- Bank statements covering the movement, from an account in the name of the entity that is party to the transaction.
- Identification for every beneficial owner above the threshold that applies where the transaction lands, which is not always the threshold that applies where you are.
Two things go wrong more often than the rest.
The first is a gap between the entity that signs and the account that pays. A payment from a related company, a director's personal account or an entity in a third country will stop a file even when the underlying money is entirely clean, because the person reviewing it cannot connect the two without documents nobody has prepared.
The second is a structure that was efficient when it was built and is now simply opaque. If it takes three hops to reach a person, expect the review to take three times as long, and expect at least one counterparty to decline rather than spend the time.
The practical advice is unromantic. Assemble the pack before you need it, keep it current, and have one person who owns it. When a transaction moves, it moves quickly, and the file that is already complete is the one that gets to sign.
We run this check on every party we introduce, in both directions. It is the least popular thing we do and the reason introductions from us tend to survive contact with the other side's compliance department.