Bank account for NL company, large volumes

[mattmatt]

Hi,
I have a company registered in the Netherlands with a bank account at 3S Money (EMI), but due to their policy, I would like to change it. I'm based in Dubai, so many banks don't accept it. We are doing B2B trading of physical goods. We have 2-3M€ monthly incoming + outgoing. I had Wise, but they blocked our account as our business model is "high-risk."

I'm looking for any solutions.

 

[JohnnyDoe]

Hello,
Can you explain why 3S money is no longer suitable for your business?
Is there a reason why you don’t use a bank in NL?
What is the average balance on your account and are you willing to invest some money with the bank?

 

[Jerry1911]

Try Intergiro, Wittix, Finductive, Airwallex.

At those volumes I think it's safe to say you can negotiate on fees.

 

[mattmatt]

They are pretty slow, I've made a payment, and they release it after 5 hours. They also cancel my payment to XE.com because of their "internal policy." I had to use their rates and lost nearly 2k$ because of that.

Most banks in NL require a managing director located in NL. I've tried some and refused in a few of them.
The average balance is 100k€. So what do you mean by "invest some money" with the bank?

 

[Jerry1911]

You could hire a Dutch resident director, I'm sure your budget allows it?

Also don't forget you can use multiple EMIs at once to stay below limits for example.

 

[JohnnyDoe]

They are pretty slow, I've made a payment, and they release it after 5 hours. They also cancel my payment to XE.com because of their "internal policy." I had to use their rates and lost nearly 2k$ because of that.

Well, this is understandable, they need to make money not to help xe.com to make money. I guess you can negotiate fx rates.

Most banks in NL require a managing director located in NL. I've tried some and refused in a few of them.
The average balance is 100k€.

Too small balance for any big non NL bank.

So what do you mean by "invest some money" with the bank?

To make the bank happy by buying their (mostly shitty) investment products.

 

[mattmatt]

Well, this is understandable, they need to make money not to help xe.com to make money. I guess you can negotiate fx rates.

I've already negotiated with them. Only on exchanging 200k$ to EUR, I've lost 2k$ competitive to XE.

To make the bank happy by buying their (mostly shitty) investment products.

Yes, I can do that.

You could hire a Dutch resident director, I'm sure your budget allows it?

Also don't forget you can use multiple EMIs at once to stay below limits for example.

I rather stay as a director due to the company structure.

 

[Martin Everson]

We have 2-3M€ monthly incoming + outgoing.

The reality is those volumes are beyond the risk appetite of most decent EMI's except the laundromat ones. Your business will be of no interest to most EMI's hence.

Furthermore you are based in a country grey listed (UAE) by FATF for money laundering. This will not help either for anyone to accept your Netherlands business.

I had to use their rates and lost nearly 2k$ because of that.

As you are also price sensitive your attractiveness to a tradiional bank or keeping the relationship will not be easy.

Also don't forget you can use multiple EMIs at once to stay below limits for example.

This is what you should be doing as @Jerry1911 said.

 

[Rain0241]

Hi,
I have a company registered in the Netherlands with a bank account at 3S Money (EMI), but due to their policy, I would like to change it. I'm based in Dubai, so many banks don't accept it. We are doing B2B trading of physical goods. We have 2-3M€ monthly incoming + outgoing. I had Wise, but they blocked our account as our business model is "high-risk."

I'm looking for any solutions.

Ya, when I was looking for a bank for one of our clients doing import and export ,I emailed them and they just said they dont do high risk and they steer clear of providing bank accounts for unregulated Financial services, while in reality we are a consultancy and the bank account is for our client.Luckily we found another solution for them.

 

[Forester]

Hi,
I have a company registered in the Netherlands with a bank account at 3S Money (EMI), but due to their policy, I would like to change it. I'm based in Dubai, so many banks don't accept it. We are doing B2B trading of physical goods. We have 2-3M€ monthly incoming + outgoing. I had Wise, but they blocked our account as our business model is "high-risk."

Wise sucks in general (for any more complicated, complex or anyway non-average case); but it is generally important: what is your business exactly about, what do you trade (if you can share)?
As I see in the posts above, the account balance should not be the problem for an EMI. The turnover is high; but it need not necessarilly be a pain.

I'm looking for any solutions.

Try Intergiro, Wittix, Finductive, Airwallex.

I have no experience with Wittix; but Intergiro, Finductive, Airwallex can work for you. Currenxie IMO too.
Especially as a NL based company, did you try/check Bunq Business? (I do not know how they fine are with UAE director, unfortunately.)

Also don't forget you can use multiple EMIs at once to stay below limits for example.

Yes, it is a good advice; and not only for the reason of staying below limits – having a backup is extremely important, I would say even a must nowadays; and with your business model probably even more.

At those volumes I think it's safe to say you can negotiate on fees.

I think so, too. For example, with the Intergiro Enterprise package it is an expected behaviour (although Intergiro is not expensive in general). I might be able to help you there, if necessary.
Another important factor, I have forgotten about it above: what are the destinations of your payments, both in and out?

 

[GPT]

You could hire a Dutch resident director, I'm sure your budget allows it?

Also don't forget you can use multiple EMIs at once to stay below limits for example.

Word of warning.

Using multiple EMI’s is structuring is smurfing is triggering a lot of AML questions at the tax authorities.

 

[Jerry1911]

Using multiple EMI’s is structuring is smurfing is triggering a lot of AML questions at the tax authorities.

AFAIK smurfing (structuring) is when you split a _single_ transaction into multiple smaller ones.

Using multiple bank accounts, EMIs included, is perfectly legal.

 

[GPT]

AFAIK smurfing (structuring) is when you split a _single_ transaction into multiple smaller ones.

Using multiple bank accounts, EMIs included, is perfectly legal.

It will still require a lot of information to be provided per transaction. Contracts, invoices and emails disclosed upfront to the bank before they accept / release payments.

Your definition of smurfing is right yet it’s a lot stricter than it originally was intended nowadays. The umbrella articles cover basically everything to justify an investigation and banks are the sentinel for the tax authorities.

I would therefore not blindly say that it doesn’t trigger anything.

Thinking in solutions is to get a Dutch director and open a “normal” bank account. Also from cost perspective a more “ok” solution.

 

[Forester]

It will still require a lot of information to be provided per transaction. Contracts, invoices and emails disclosed upfront to the bank before they accept / release payments.

Yes – but it is almost a general standard nowadays. (Or you must have it continuously at hand, at least.)

Your definition of smurfing is right yet it’s a lot stricter than it originally was intended nowadays. The umbrella articles cover basically everything to justify an investigation and banks are the sentinel for the tax authorities.

No objections. Unfortunately.

I would therefore not blindly say that it doesn’t trigger anything.

Well, regardless of abovementioned, using multiple accounts is still a common practice. In many, many cases it is necessary for various reasons, beginning from ability of a bank to handle a particular currency/region, via costs for particular operations, ending with a risk management.
And frankly, I did not hear about any case when usage of more than one account triggered any investigation. You did? (Of course, if some of used accounts is with a dubious institution, it can trigger questions perfectly but it is another case.)

Thinking in solutions is to get a Dutch director and open a “normal” bank account.

I agree that it looks very straightforward. But I understand well that (as @mattmatt mentioned) it simply does not fit into the business model. (It is definitely not strange when someone wants to manage his company personally and exclusively.)

Also from cost perspective a more “ok” solution.

It depends. For example, managing an another account can be much less expensive than hiring an appropriate person as NL director...

 

[GPT]

Yes – but it is almost a general standard nowadays. (Or you must have it continuously at hand, at least.)

Compliance is a bitch and in the case where it becomes international it slowly starts to look like a fulltime position to fulfill all requirements.

No objections. Unfortunately.

Well, regardless of abovementioned, using multiple accounts is still a common practice. In many, many cases it is necessary for various reasons, beginning from ability of a bank to handle a particular currency/region, via costs for particular operations, ending with a risk management.
And frankly, I did not hear about any case when usage of more than one account triggered any investigation. You did? (Of course, if some of used accounts is with a dubious institution, it can trigger questions perfectly but it is another case.)

Unfortunately I am aware and experienced some situations where it triggered questions.

Proactive vs reactive seems to be the solution nowadays. If you proactively can inform your bank / EMI etc then you have a bigger / better change of remaining in good standing. When informing happens reactively then I have seen institutions close accounts with a 2-3 months notice.

Specifically in NL this has led to a court case which was won by the client. The problem is that the damage was done already and consequently the problem not solved. A typical “too little to late”.

I agree that it looks very straightforward. But I understand well that (as @mattmatt mentioned) it simply does not fit into the business model. (It is definitely not strange when someone wants to manage his company personally and exclusively.)

Owh I completely agree. The problem however seems not to be what is legally allowed anymore. It seems to be what banks allow you to do. Thank the bis / Basel agreements for all this bs.

We haven’t seen the end of it I am afraid.

It depends. For example, managing an another account can be much less expensive than hiring an appropriate person as NL director...

Normally I would agree on the above, specifically because of an Dutch based director having to earn a certain income.

The current problem imo is not that cost as the director also will then be responsible for the ongoing compliance. If you have to manage compliance from a distance I can assure you that it all of sudden becomes a factor 10 more complicated compared to having boots and language on the ground.

Don’t get me wrong. It is not what people want to hear nor is this what law dictates. Unfortunately life / regulations / bilateral agreeements have brought us here.

If you then are not a UHNWI you just have to suck it up. Many HNWI know from experience already that life has become very very complicated.


Ill give a very practical example on how fucked up banks are right now. Commercial party in country A has a contract with a municipality in country B. Commercial party banks in the country of incorporation (country A). In order to receive funds from the municipality of country B contracts have to be disclosed. Given that its a governmental institution the process differs slightly from a commercial contract. Result.. funds initially returned to sender. A second transaction they were blocked. Upon providing all information they were again returned to sender. Reasoning from the bank “who is the ubo of the municipality?”. In the end it got solved. It wasn’t easy… just one example. I can write an encyclopedia with examples all from the last 12 months…

 

[Jerry1911]

I can write an encyclopedia with examples all from the last 12 months…

Feel free to make a post/thread about it. I'm interested and I'm sure I'm not the only one.

 

[GPT]

Feel free to make a post/thread about it. I'm interested and I'm sure I'm not the only one.

Let me think about it for a bit and see if I can keep the stories interesting without jeopardizing relationships with clients and banks.

Some banking examples that immediately coming to mind;

- bank not willing to execute a transfer based on a loan agreement. Had to be changed to invoices which led to creative rewriting the loan agreement as it otherwise had unwanted tax implications.

- bank not willing to execute a transfer in a group of companies (between mother - daughter or daughter - daughter) unless invoices provided. This is outrageous as there is no law in the world mandating that.

The above two (three of you include the previous post example) all happened with European banks in 2022.

 

[aage]

Thinking in solutions is to get a Dutch director and open a “normal” bank account. Also from cost perspective a more “ok” solution.

it will require a lot of excises to get such an account for a Dutch company. Travelling and talking skills included.

 

[Forester]

Compliance is a bitch and in the case where it becomes international it slowly starts to look like a fulltime position to fulfill all requirements.

I agree

Unfortunately I am aware and experienced some situations where it triggered questions.

... ... well, with respect to the stories that you posted – I believe

Proactive vs reactive seems to be the solution nowadays. If you proactively can inform your bank / EMI etc then you have a bigger / better change of remaining in good standing.

I am in line with you (altough if someone intends to break/fool TOS, it will not help )

When informing happens reactively then I have seen institutions close accounts with a 2-3 months notice.

... better than the practice of blocking/closing the account immediately, as it is common with many institutions beginning with Revolut and Wise.

Specifically in NL this has led to a court case which was won by the client. The problem is that the damage was done already and consequently the problem not solved. A typical “too little to late”.

A compensation for damages was not sufficient, I presume?

Owh I completely agree. The problem however seems not to be what is legally allowed anymore. It seems to be what banks allow you to do. Thank the bis / Basel agreements for all this bs.

We haven’t seen the end of it I am afraid.

Well, yes.

Normally I would agree on the above, specifically because of an Dutch based director having to earn a certain income.

It was one of reasons backing my rebuttal.

The current problem imo is not that cost as the director also will then be responsible for the ongoing compliance. If you have to manage compliance from a distance I can assure you that it all of sudden becomes a factor 10 more complicated compared to having boots and language on the ground.

Oh, I see. And perhaps I understand. The situation with NL banks (and probably not only NL, it probably concerns more European countries) is really complicated, wrt the stories you posted.

Don’t get me wrong. It is not what people want to hear nor is this what law dictates. Unfortunately life / regulations / bilateral agreeements have brought us here.

I understand what you mean – although many of this bs is unfortunately really founded in law.

Ill give a very practical example on how fucked up banks are right now. Commercial party in country A has a contract with a municipality in country B. Commercial party banks in the country of incorporation (country A). In order to receive funds from the municipality of country B contracts have to be disclosed. Given that its a governmental institution the process differs slightly from a commercial contract. Result.. funds initially returned to sender. A second transaction they were blocked. Upon providing all information they were again returned to sender. Reasoning from the bank “who is the ubo of the municipality?”. In the end it got solved. It wasn’t easy… just one example. I can write an encyclopedia with examples all from the last 12 months…

Some banking examples that immediately coming to mind;

- bank not willing to execute a transfer based on a loan agreement. Had to be changed to invoices which led to creative rewriting the loan agreement as it otherwise had unwanted tax implications.

- bank not willing to execute a transfer in a group of companies (between mother - daughter or daughter - daughter) unless invoices provided. This is outrageous as there is no law in the world mandating that.

The above two (three of you include the previous post example) all happened with European banks in 2022.

OMG. It really looks like a few of jokes. Really, when you have such experience, I completely understand your position. Fortunately, my experience differs a little – but it can be caused just by fact that I do not deal with EU commercial banks very often. And private banks, reasonable EMIs and Asian banks are IMO (still) not so stupid.

 

[Cryptohodler]

bank not willing to execute a transfer based on a loan agreement. Had to be changed to invoices which led to creative rewriting the loan agreement as it otherwise had unwanted tax implications

How exactly can a loan agreement be turned into an invoice that too without tax implications. Invoice involves paying sales tax or vat or GST or whatever it's called in the country where sales are shown whereas loan transfers usually are tax free

Hi,
I have a company registered in the Netherlands with a bank account at 3S Money (EMI), but due to their policy, I would like to change it. I'm based in Dubai, so many banks don't accept it. We are doing B2B trading of physical goods. We have 2-3M€ monthly incoming + outgoing. I had Wise, but they blocked our account as our business model is "high-risk."

I'm looking for any solutions.

Why would trading of physical goods be high risk ? What are these goods ? Try currenxie . Split your volumes across multiple emis if volume is the issue