If you’re in a high-risk industry — crypto, gambling, forex, adult, or affiliate marketing — opening a business bank account isn’t just tough.
It’s a minefield.
The biggest issue? Most rejections aren’t because of what your business does — they’re because of how you present it.
In this guide, we outline the 17 most common mistakes high-risk businesses make when applying for a bank or EMI account — and how to avoid each one.
Using Vague or Misleading Business Descriptions
Bad:
“We offer consulting services and digital marketing.”
Worse:
“Our services vary by client.”
Good:
“We operate a B2B crypto OTC desk that facilitates fiat-to-crypto transactions for regulated clients in the EU. Clients are onboarded via KYC, and transactions are screened with KYT tools.”
💡 Clarity builds trust. Vague = rejection.
Hiding Crypto, Gambling, or Adult Exposure
Many founders think hiding “risky” elements will help them get approved.
It won’t.
- Crypto wallet? Declare it.
- Gambling affiliate commissions? Mention them.
- Adult subscription content? Be transparent.
✅ Banks may accept your model if they understand the controls.
❌ They will reject you if you lie.
Overestimating Monthly Volume
Claiming you process “€5M per month” as a brand-new business raises flags.
Instead:
- Be realistic
- Include a clear growth forecast
- Back up numbers with PSP, wallet, or invoice screenshots
💡 Banks aren’t impressed by big numbers — they prefer traceable, believable flows.
Not Declaring All UBOs
If a shareholder owns more than 25% of the company, they are a UBO.
Failing to declare all UBOs — or hiding behind nominee structures — results in rejection.
✅ Tip: Include notarized passport, PoA, and source of funds for all UBOs — even if they’re passive.
Using a Badly Structured Corporate Setup
Mixing offshore entities, nominee directors, and unrelated activities (e.g., an adult site under a “real estate LLC”) creates red flags.
💡 Structure matters:
- Operating entity in a banking-friendly jurisdiction (e.g., Cyprus, Czechia, Malta)
- Holding entity offshore only if justifiable
- Activities segmented by vertical
Submitting Poor-Quality or Incomplete Documents
Banks don’t tolerate:
- Blurry passport scans
- Expired proofs of address
- Incomplete corporate documents
- PDFs with missing pages or inconsistent information
✅ Submit:
- Notarized and apostilled passports (when offshore)
- Recent utility bills (under 90 days)
- Properly labeled, high-resolution PDFs
- All company formation documents (COI, AoA, shareholder registry)
💡 Pro tip: Bundle your documents into folders with clear names and a cover index.
No AML/KYT Policy for Client Transactions
If you touch client funds, crypto, or run a platform:
- Banks want to know how you screen users
- Without a basic AML policy, you’ll be rejected
Even a 3-page internal document is better than nothing.
✅ Include:
- How users are onboarded
- KYT tools used (Chainalysis, Notabene, etc.)
- Thresholds for alerts, blacklists, sanctions
Having No Website or a Placeholder Site
Your website is one of the first things compliance checks.
❌ Sites with:
- “Under construction” pages
- No Terms & Conditions
- No contact info or legal notice
→ Get flagged or rejected.
✅ Include:
- T&Cs, AML/KYC disclosures, business model explanation
- Legal imprint with entity name, address, and registration
No Declared Source of Funds for the UBO
Even if your company is fine, if your UBO is:
- Under 25
- Based in a high-risk country
- Has no visible income trail
— you will need to provide source of funds.
✅ Acceptable documents:
- Bank statements showing savings
- Sale of company contracts
- Crypto wallet logs + off-ramp records
- Investment income or dividends
Mixing Multiple Risk Activities in One Account
Don’t combine:
- Crypto + adult
- Gaming + escort directory
- Forex + unlicensed NFT platform
Each of these may be legal alone, but together they trigger rejection.
✅ Solution: Segment activities into different legal entities and EMIs.
Cold Applying Without an Introducer such as BankMyCapital
Most high-risk-friendly banks and EMIs only onboard via:
- Versed Introducers
- Compliance consultants
- Tiered referral programs
💡 9 out of 10 cold applications go unanswered.
✅ Use vetted introducers (like BankMyCapital) to present your file directly to a decision-maker.
Ignoring the “Flow of Funds” Requirement
Banks need to understand:
- Who pays you
- How they pay you (crypto, PSP, card?)
- In what currency
- How often
- Where the money goes
✅ Solution: Create a flow-of-funds diagram or 1-page explanation.
💡 This document alone has helped dozens of high-risk companies get approved.
Submitting Personal Wallets or Accounts
If you send personal wallets, unlinked to a KYT process, your application will likely be rejected — especially in crypto.
✅ Instead:
- Use corporate wallets
- Show wallet screening history
- Explain how personal wallets were phased out or separated
Using Free Email Domains for Corporate Contact
Emails like @gmail.com or @protonmail.com scream non-professional or non-compliant.
✅ Always use:
- @yourdomain.com
- Match your website and incorporation documents
Not Preparing for a Video KYC Interview
Most onboarding processes include a video KYC call with the UBO or director.
Mistakes:
- Taking the call in a noisy place
- Not knowing key details of your business
- Having mismatched documents
✅ Solution:
- Treat it like a visa interview
- Know your business and be transparent
- Dress professionally and ensure ID matches the file
Taking Too Long to Respond to Compliance Requests
Delays = distrust.
Banks and EMIs operate under ticking regulatory clocks.
✅ Respond to requests within 24–48 hours
✅ Provide full explanations, not vague replies
✅ Escalate with your introducer if clarification is unclear
Applying to the Wrong Type of Provider
Not every EMI or bank accepts:
- Gambling
- Adult
- Crypto
- Forex
- Unlicensed PSPs
If your introducer sends your file to the wrong fit, you’ll be rejected even with a clean file.
✅ Work with someone who knows who is onboarding what in 2025.
Final Thoughts: Precision Wins in High-Risk Banking
Rejection isn’t random — it’s usually the result of avoidable mistakes.
If you’re structured, transparent, and prepared, your onboarding will not only succeed — it will last.
📩 Want to avoid these mistakes and increase your odds of approval?
Contact BankMyCapital to build a bank-ready application — structured, vetted, and submitted to the right providers who still support your business model in 2025.
