Surviving a bank's periodic review of your account

Getting the account open is treated as the finish line. It is not. Banks re-examine existing customers on a cycle, and a review can end a relationship that has run without incident for years. The businesses that come through it are not the ones with the best arguments — they are the ones whose file still matches what they said at the outset.

Why the bank is asking again

Anti-money-laundering obligations do not stop at onboarding. Institutions are required to keep customer information current, monitor activity against the expected profile they recorded, and review higher-risk relationships more frequently. A periodic review is the bank discharging that duty, on a cycle keyed to how it risk-rated you when you joined.

That rating is the thing worth understanding. A low-risk customer may not hear from the bank for several years. A customer rated higher — because of ownership structure, sector, jurisdictions of activity, or transaction pattern — may be reviewed annually. You are rarely told your rating, but the frequency of contact reveals it.

What triggers a review outside the cycle

• Activity that does not match the expected profile. Volumes well above what you projected, counterparties in countries you never mentioned, or a pattern that changed without explanation.
• A change in ownership or control that the bank learns about from a register rather than from you.
• Adverse media naming the company, a director or a beneficial owner — including reporting that turns out to be wrong.
• A counterparty coming under scrutiny. Being paid by someone the bank has concerns about is enough.
• Sanctions and listing changes affecting a jurisdiction you deal with.
• Documents expiring — passports, certificates of incumbency, address verification.
• A policy change at the bank that reclassifies your sector. This one has nothing to do with you and is among the most common causes.

What the letter will ask for

Broadly the same categories as onboarding, brought up to date:

• Current constitutional documents and certificates of good standing.
• Confirmation of the current directors, shareholders and beneficial owners, often with fresh certified identification.
• Recent audited financial statements.
• An updated description of the business and its expected activity.
• Evidence supporting the source of funds flowing through the account, and sometimes the source of wealth of the owners. The distinction between the two is one banks care about and applicants routinely blur.
• Supporting documentation for specific transactions — invoices, contracts, shipping documents.
• Explanations for anything that looks anomalous.

The deadline is short and it is real

Review letters commonly give fourteen to thirty days. Miss it and accounts are frequently restricted first and discussed afterwards — outgoing payments blocked while the balance stays put. Restoring an account after that point takes considerably longer than answering the letter would have.

Two practical consequences. Make sure the bank has contact details that reach a person who will act, because these letters go to registered addresses and to email addresses nobody monitors. And if the deadline is genuinely impossible — a document must come from a foreign registry, an auditor needs three weeks — say so immediately and in writing. Requests for more time made before the deadline are usually granted. Silence is not.

How to answer well

1. Answer the question asked. If the bank asks about three payments, address those three specifically, with documents attached, rather than sending a general description of the business.
2. Be consistent with what you said before. The reviewer is comparing your answers to the onboarding file. Contradictions are the single most damaging thing you can introduce, and they are usually accidental — a business that evolved while the file did not.
3. Explain changes rather than hiding them. Businesses change. A clear account of what changed and why is unremarkable; a discrepancy the bank finds for itself is not.
4. Provide documents, not assurances. "These are payments from our distributor" is worth nothing without the distribution agreement and the invoices.
5. Keep it organised. A single covering letter that lists what is enclosed, indexed to the questions, gets read. Forty unnamed attachments across six emails does not.
6. Do not argue. The reviewer did not choose the policy and cannot waive it. Tone affects outcomes more than most people expect.

If the answer is exit

Banks close accounts, and they are generally entitled to do so without giving reasons. If it happens:

• Ask what notice period applies and get the date in writing. It is usually measured in weeks and it is usually firm.
• Do not assume it is about wrongdoing. Sector-wide de-risking closes many accounts belonging to businesses that did nothing at all.
• Open the replacement immediately, and expect to disclose the closure. Concealing it and having it discovered is worse than declaring it.
• Get your records out — statements, correspondence, confirmations — before access ends.
• Understand what went wrong, because the next application will meet the same questions. If the cause was an unexplained structure or an unclear rationale, that needs fixing before you reapply rather than after the second refusal. The patterns behind refusals apply equally to exits.

Staying ready

Keep a current file: constitutional documents, up-to-date ownership records, the latest financial statements, identification for everyone the bank has on file, and a written description of the business as it operates now rather than as it was pitched three years ago. Tell the bank about material changes when they happen instead of when asked. Keep activity within the profile you described, and if it is going to change, say so first.

A review then becomes an administrative task with a deadline. Without that habit it becomes a scramble to reconstruct several years of history under time pressure, which is how relationships end.