Non-Resident LLC Bank Account: What Banks Ask For

Bank account for a non-resident's LLC

Every US bank has to identify the company and the people behind it before it opens an account. For a non-resident's LLC that usually means the EIN notice, the formation document, the operating agreement and a passport for each owner. Whether a bank will do it without a visit is the bank's own choice.

Last updated 30 October 2026

US banks do not get to decide what to collect from scratch. A federal rule, the Customer Identification Program (CIP) rule, sets a minimum for every new account, and a second rule makes the bank identify who owns and controls a company customer. A non-resident's LLC goes through both. What the rules do not do is make any bank accept you. That part is up to each bank.

This page sets out what the rules say and the papers an LLC normally brings. Form the company first: our LLC for non-residents guide covers that, and state pages such as Wyoming and Florida list each state's filing fee.

What the CIP rule makes a bank collect

The bank rule is 31 CFR 1020.220, which you can read on eCFR. Before opening an account, a bank must get at least four things from the customer: a name, a date of birth for a person, an address and an identification number.

For a company, the address is "a principal place of business, local office, or other physical location." For the number, a US person gives "a taxpayer identification number." A non-US person may give "a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard."

The bank then has to check what you gave it. For a company, the rule lists "documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument." A bank may also check by other means, such as contacting the customer.

Why the LLC itself needs an EIN

An LLC formed in a US state is a US company even if every owner lives abroad. That matters, because FinCEN's interagency guidance on the CIP rule asks whether a bank can open an account for a US person with no taxpayer identification number. Its answer: "No, the bank cannot unless the customer has applied for a taxpayer identification number, the bank confirms that the application was filed before the customer opened the account, and the bank obtains the taxpayer identification number within a reasonable period of time after the account is opened."

So get the EIN before you go to a bank. If no owner has an SSN or ITIN, our EIN without an SSN guide walks through Form SS-4.

The guidance (it still cites the rule's old number, 31 CFR 103.121) also says the rule sets a floor, not a ceiling. Banks are expected to add "risk-based verification procedures, where appropriate, to ensure that the bank has a reasonable belief that it knows each customer’s identity." That is why two banks can ask you for different things.

The owners behind the company

A second rule, 31 CFR 1010.230, makes a bank identify the beneficial owners of a company customer "at the time a new account is opened." It names two kinds of beneficial owner. One is each person who "owns 25 percent or more of the equity interests." The other is "a single individual with significant responsibility to control, manage, or direct" the company, and the rule gives "Managing Member" as an example.

Expect the bank to ask for a name, date of birth, address and ID for each of those people, as it would for any customer.

The papers an LLC usually brings

The SBA's page on how to open a business bank account lists "some of the most common documents banks ask for," and adds "Some banks may ask for more." Its list is the EIN, "Your business’s formation documents," "Ownership agreements" and a business license. For a non-resident's LLC that normally means:

The IRS EIN notice. The letter the IRS sends when it assigns the number.
The formation document. The articles of organization or certificate of formation the state approved. Some banks want a certified copy, which the state filing office sells.
The operating agreement. It shows who the members are and who can sign. The SBA register your business page says it "defines how key business decisions are made, as well as each member’s duties, powers, and responsibilities."
ID for each owner and signer. Usually a passport, plus proof of a home address.
A business address. See the FAQ below on registered agent addresses.

A recent certificate of good standing helps if the company is not brand new. Our certificate of good standing guide shows each state's version.

Questions to ask a bank first

Ask these before you pick a state or pay any fee:

Do you open accounts for LLCs whose owners live outside the US?
Must an owner visit a branch, or can the account be opened by post or online?
Which ID and proof of address do you accept from my country?
Do you accept a registered agent's address, or do you need another US address?
Is there a minimum deposit or a monthly fee?

Get the answers in writing if you can. Rules on who a bank serves change, and nothing here promises that any bank will open an account for you.

Questions people ask

Can a non-resident open a US bank account for an LLC?

Some banks accept non-resident owners and some do not. Federal rules tell banks what they must collect and verify, but each bank sets its own policy on who it serves and how. Ask the bank before you form.

Does the LLC need an EIN to open an account?

In practice, yes. A US LLC is a US person, and FinCEN's guidance says a bank cannot open an account for a US person with no taxpayer identification number unless an application was filed first and the number follows within a reasonable time.

What ID will the bank accept from a foreign owner?

The federal rule lets a bank take a non-US person's passport number and country of issuance, an alien identification card number, or another government-issued photo document showing nationality or residence. The bank's own policy decides which it wants.

Who counts as a beneficial owner for the bank?

Each person who owns 25 percent or more of the LLC, plus one person with significant control, such as a managing member. The bank identifies them when the account is opened.

Can I use my registered agent's address as the business address?

Ask the bank. The rule asks for a principal place of business, local office or other physical location for a company, and banks differ on what they accept.