So you’ve found a bank or EMI willing to consider your high-risk business — now comes the hard part: compliance.
Bank compliance is the gatekeeper between your company and a functioning account. And for businesses in crypto, gambling, adult, or forex, the hurdles are higher. Even if you’re fully legal and well-structured, your application will be scrutinized more closely than most.
The good news? You can pass compliance — but only if you understand what banks expect, how to prepare, and how to avoid red flags.
This guide explains what compliance teams look for in 2025, and how to successfully navigate the onboarding process as a high-risk company.
Why Compliance Is So Hard for High-Risk Sectors
Compliance is not the enemy — it’s a legal shield for banks. But if your company operates in a high-risk sector, banks need to show regulators that they:
- Understand what you do
- Can monitor your transactions
- Know who controls the company
- Know where the money comes from and where it’s going
If your answers are vague, inconsistent, or incomplete, your application will either be denied or stalled indefinitely.
What Compliance Officers Are Actually Looking For
They don’t expect you to be perfect — but they do expect:
✅ A clear and logical business model
✅ A documented corporate structure
✅ A declared (and reasonable) transaction flow
✅ Proof of KYC/KYT measures
✅ A clean, verified UBO
✅ Transparent use of crypto (if applicable)
✅ No attempt to hide or mask the industry you’re in
In short: they want to trust you — and trust is built through documentation.
Core Documents Required for High-Risk Bank Onboarding
Here’s a standard checklist for compliance in 2025:
| Document | Required? | Notes |
| Passport of all UBOs | ✅ | Notarized preferred |
| Proof of address (utility bill) | ✅ | Dated within 3 months |
| Company incorporation docs | ✅ | COI, M&AA, share certs |
| Tax number or registration proof | ⚠️ | Optional offshore |
| Business plan or summary | ✅ | Short + clear |
| Website or live platform | ✅ | Especially if digital |
| Compliance policy (AML/KYT) | ✅ | For crypto/gambling |
| KYT provider agreement | ⚠️ | Expected for crypto |
| Source of funds for UBOs | ✅ | Bank statement, declaration |
| Previous bank reference | ⚠️ | Not always mandatory |
| Proof of operational activity | ✅ | Invoices, contracts, screenshots |
How to Prepare a Clear Business Description
This is one of the most underestimated parts of the onboarding process.
✅ DO:
- Write a 1–2 paragraph summary that explains what your business does
- Name the jurisdictions involved
- Describe your clients and how they pay
- Include expected currencies and volumes
❌ DON’T:
- Use generic terms like “digital services” if you’re a gambling affiliate
- Claim “consulting” when you offer crypto liquidity
- Say “we don’t handle crypto” if your wallets are publicly tied to you
A strong description removes friction and avoids unnecessary follow-up questions.
Continuing the post:
KYT Tools: The #1 Secret to Passing Crypto & Gambling Compliance
If your business touches crypto or gambling payments, you must demonstrate transaction monitoring. That’s where KYT (Know Your Transaction) tools come in.
✅ Popular KYT Solutions in 2025:
- Chainalysis KYT – Most bank-recognized
- Elliptic Navigator – Strong for EU EMIs
- Crystal Blockchain – Light, fast integration
- Coinfirm – Widely used by PSPs
- Scorechain – Preferred by French-speaking banks
You don’t need to build your own compliance stack — just show you’ve integrated or subscribed to one of these. Not using KYT = application rejection for any serious crypto or gambling flow.
UBO and Source of Funds: What You Must Show
The UBO (Ultimate Beneficial Owner) check is a core part of onboarding. Banks want to know:
- Who really owns and controls the business
- Whether that person has clean financial and legal history
- How they acquired the funds to start or scale the business
✅ Accepted Proofs:
- Bank statements showing savings or transfers
- Declarations of investment from known entities
- Legal sales or asset disposals (crypto, real estate)
- Past business income or dividends
If your UBO is involved in other risky ventures, has undisclosed ownership, or can’t explain their wealth, expect rejection.
Flow of Funds: How to Make It Easy for Compliance
Banks aren’t just interested in your structure — they want to understand where money comes from and where it goes.
✅ Create a simple “flow of funds” diagram or summary:
- What currencies are used
- What countries you send/receive funds from
- What PSPs or wallets are involved
- How you monitor clients and transactions
- What the average and maximum transfer size is
This is especially important for:
- PSP onboarding
- SEPA account opening
- Crypto-to-fiat ramps
- Gambling payout structures
💡 The more transparent your flow is, the more confident compliance officers will be.
Common Reasons High-Risk Applications Are Rejected
- ❌ Business activity not clearly declared
- ❌ Documents submitted are outdated or fake
- ❌ Mismatch between declared industry and public website
- ❌ Crypto exposure not mentioned but visible via public wallets
- ❌ UBO from a sanctioned or high-risk jurisdiction
- ❌ No KYT tool or AML policy in place
- ❌ Flow of funds looks suspicious or unrealistic
- ❌ Applying directly to bank instead of through an introducer
How BankMyCapital Helps You Navigate the Compliance Process
We don’t run KYC desks — but we know exactly what banks and EMIs look for when onboarding high-risk clients.
Here’s how we help:
- ✅ Pre-screen your documents and structure
- ✅ Write or refine your business summary
- ✅ Assist with flow-of-funds explanations
- ✅ Recommend KYT or compliance tools
- ✅ Introduce you to vetted, high-risk-friendly providers
- ✅ Communicate with compliance teams on your behalf
- ✅ Fix red flags before submission
We don’t promise approvals — but we don’t waste time applying to places where you’ll be rejected.
Final Thoughts: Think Like a Compliance Officer
Banks don’t say “no” because they dislike your business — they say no because the risk of onboarding you outweighs the reward (unless you explain otherwise).
So:
✅ Think like a compliance officer
✅ Provide clarity, not mystery
✅ Package your structure properly
✅ Don’t go it alone — use an introducer
📩 Ready to pass compliance and finally open that account?
Contact BankMyCapital for a pre-approval screening — and let’s make sure your business is presented in a way banks will accept.