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Scott Letourneau | | 0 Comments

Non-Resident U.S. Bank Accounts: How Compliance Rules Are Shaping Account Options in 2025

Today, non-resident founders must thread three very different needles when looking to establish some “bank account” for their U.S. entity formation.

Payout rails used by the marketplaces themselves (Amazon’s Currency Converter for Sellers, TikTok Shop Seller Wallet, Walmart Payoneer).

  1. Transfer services and neo-banks that sit between you and the customer, such as Wise, OFX, Payoneer, Mercury, and Relay.

  2. Full-service banks, such as Citibank, Chase, and U.S. Bank, as well as regional or community institutions, often require merchant processing (Stripe, Shopify Payments) or a true operating line of credit.

Each tier now runs on far stricter know-your-customer rules than in 2023, and the addresses, IDs, and utility bills you supply must line up across every tier if you want stress-free payouts.

Regulators are making the point with billion-dollar and million-dollar fines.
FinCEN’s record $1.3 billion action against TD Bank in October 2024 jolted every compliance officer in the country. FinCEN.gov This July, regulators followed by hitting Wise with a $4.2 million multi-state penalty for “serious AML deficiencies,” underscoring that even transfer services face bank-level scrutiny. Finextra Research expects every neo-bank and its correspondent partners to over-correct, more document requests, and more account holds, until they feel safe.
step-3-us-banking-verified-expansion-playbook-2025

KYC itself has changed.
In June 2025, FinCEN allowed banks to retrieve a customer’s full Tax ID from trusted databases, collecting only the last four digits at onboarding. FinCEN.gov. That sounds easier, but it also removes any doubt about whether you are really operating from the United States. The form now asks:

  • Legal address (in some cases) can be a registered agent, non-CMRA location.

  • Physical (operating) address, must be where management or fulfillment actually happens, inside or outside the U S., CMRA or registered-agent address “legal address”, or make a mistake between the legal address and operating address, that may trigger a “please upload a business utility bill” request, which most e-commerce sellers cannot satisfy.

  • Mailing address is the only field where a CMRA or forwarding suite is usually safe.

Some mainstream banks go further, requiring a traditional lease and on-site utility bill for the business address before they will open the account.

Why this matters for marketplace sellers.
Marketplace payout tools do not thoroughly verify your address; merchant acquirers and banks do. If your Stripe application lists a Nevada office you do not control, while Amazon sees you shipping from Shenzhen, and your neo-bank sees only a Wyoming registered agent, one of them will eventually freeze funds.

Get the hierarchy right (unfortunately, there are exceptions to each one of these below):

  • Use a non-CMRA registered-agent address for formation and EIN paperwork (but not for TikTok Shop).

  • Use your real operating address, foreign HQ, or personal foreign address for the “physical address” field.

  • Keep a professional forwarding address (CMRA) in the U.S. for mail and debit-card shipments, but never list it as “operating.”

Set those pieces correctly on day one, and you usually get only one round of identity requests, not three.

Why Non-Residents Are Facing More Scrutiny

The primary challenge for non-residents is proving the legitimacy of their U.S. business. Banks are being required to verify both ownership and whether the business has a real operational presence in the U.S.

Here’s what this means for you:

  • Personal Utility Bills: Banks increasingly request a personal utility bill to verify the individual’s home address against the one on file. This adds an extra layer of verification.
  • Business Lease and Utility Bill: Many banks require a business lease agreement or utility bill tied to a U.S. office. These documents confirm your company’s operational presence in the U.S.
  • Operational Presence at Both Personal and Business Levels: Some banks are raising the bar by requiring a U.S. presence at both the personal and business levels, increasing costs for non-residents as maintaining a physical U.S. location is expensive.

The Cost of Compliance for Establishing Non-Resident U.S. Bank Accounts

For non-residents, these new compliance demands add up. You might need to:

  • Lease office space in the U.S. to satisfy operational presence requirements.
  • Set up utilities in both your personal and business names to meet verification standards.
  • Handle increased tax compliance triggered by a more substantial operational presence in the U.S.

This isn’t just extra paperwork. The financial costs and tax obligations can deter many non-residents from expanding into the U.S.

What Compliance Looks Like in 2025 for Non-Resident U.S. Bank Accounts

In 2025, neo-banks like Mercury, Relay, and Wise are facing increased pressure to comply with CDD regulations. As a non-resident business owner, expect heightened scrutiny when opening or maintaining a U.S. bank account.

Here’s what compliance looks like today:

  • KYC (Know Your Customer) Checks: To verify operational presence, more detailed information about you and your business, including personal utility bills and business leases, will be requested.
  • U.S. Presence Requirements: Banks prefer businesses with a legitimate U.S. presence, both at the individual and corporate levels. Failure to meet these requirements may result in account closure.
  • Increased Account Closures: Many non-residents are reporting sudden account closures due to banks’ conservative approach to compliance.

How to Protect Your Business and Avoid Account Closures

If you’re serious about expanding into the U.S., you must stay ahead of these changes. Here’s how to protect yourself and your business:

  • Establish a Verifiable U.S. Presence: Secure a physical office, set up utility bills in your name, and ensure your home address matches the paperwork. Solid proof of a U.S. operational presence is crucial.
  • Stay Up to Date with CDD Requirements: Ensure you understand the latest Customer Due Diligence rules. Banks are under increasing pressure to comply, and your business must meet transparency standards.
  • Work with Compliance Experts: Navigating U.S. banking regulations as a non-resident is complex. Working with experts helps you avoid mistakes that lead to account closures or penalties.

The Future of U.S. Banking for Non-Residents

As compliance standards continue to evolve, non-resident business owners must adapt. Virtual offices and mail forwarding services are no longer sufficient. Banks now want proof that your business is legitimate and requires both personal and business ties to the U.S.

That’s why working with professionals who understand these challenges and can guide you through them is essential.

Why You Need Expert Help

At Nevada Corporate Planners (NCP), we specialize in helping non-residents navigate the complexities of U.S. banking and compliance regulations. With our years of experience, we offer tailored solutions to help you meet the new compliance requirements without the risk of unexpected account closures.

Here’s how we can help you:

  • Secure your U.S. operational presence and meet the latest CDD standards.
  • Keep your accounts compliant with both personal and business verification requirements.
  • Avoid costly account closures by staying ahead of regulatory changes.

Ready to Stay Compliant? Let’s Talk

With increasing regulatory demands from banks like Mercury, Relay, and Wise, non-residents face more formidable challenges. However, with the right strategy, you can avoid these pitfalls and continue to grow your business in the U.S.

Book a free call with our team, and let’s discuss how we can help with your situation, as well as our service options and fees, to ensure you’re prepared for these changes, without the frustration of account closures or compliance hurdles.