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SEPA Banking AML BS and Opportunity Cost

Tax Cow

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Hello,

On occasion, I want to invest in good opportunities outside my company (via my personal portfolio). This is perfectly normal and I don't think it's fair to ask many, if any, questions about my intent. Much less probe me for documentation which does not exist.

Inevitably, any AML checks or back-office delays result in an opportunity cost. To give you a specific example, an investment opportunity that was available at 9.5% yield was available at 8.1% yield only 3 days later. By the time bank approved the payment, I was no longer interested in that particular investment opportunity.

Keep in mind, this is only half of the problem - getting funds from my company account to personal account. My personal bank could further add to pain by holding the payment to investment company with extended due diligence if they wanted to. This is not acceptable. There is no proof that any AML BS actually helped prevent terrorism but those buerauRats are in delusion that it can help.

Question:

From your experience, do you have recommendations to execute occasional time-critical large payments?... Payment amounts, splitting payments into multiple smaller ones - anything that could help with the odds of bypassing the back-office. Please PM, and I'm willing to give my advice in return when needed. I know more about online business and a little about tax. Banking is not my strong point.
 
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I think you have to build some history/relationship with the bank; show some activity on your account over several months or a year.
Then they won't block something or they will unblock it immediately after a quick call.

I think also if you find a smaller or a private bank, they may be more friendly and quicker compared to some large bank that preventively blocks everything.

What is your country / name of the bank? What was the destination country? That could be the biggest problem if you're sending money to somewhere suspicious (Russia, Ukraine, Iran, Balkans :D)
 
Hi,

Having the right bank is critical this day and age, opportunity cost is very real. I have first hand experience with banks, both when trying to send and receive funds. It's an absolute pain - banks are clearly overstepping and complicating matters.

I now hold an account in a private bank, I have had minimal issues - only when traveling they blocked a card as a precaution but was resolved with 1 email and 25 minutes. Having a private bank with a designated bank contact makes life so much easier. Getting a reasonable private bank is simple enough, they will ask for a larger deposit but it's well worth it.
 
. This is perfectly normal and I don't think it's fair to ask many, if any, questions about my intent. Much less probe me for documentation which does not exist.

Well actually it is fair. Once you put your money in any bank it is no longer your money :(. You lent it to the bank and the bank decides according to its term and conditions how the money you lent them is handled, what you can do with it and when they give it back....lol.

You may want to consider using a PSP instead.
 
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Well actually it is fair. Once you put your money in any bank it is no longer your money :(. You lent it to the bank and the bank decides according to its term and conditions how the money you lent them is handled, what you can do with it and when they give it back....lol.

You may want to consider using a PSP instead.
Agree, this sounds like something fishy!
 
So there's nowhere to go for reliable transfers.

On the one hand, I want a normal bank for stability. Now that I got one under the radar bank, a reputable one from France, they seem to be even more paranoid about occasional large transfers than small banks and EMIs I used to worth with before. I guess more reputation goes hand-in-hand with more paranoia.

They limited my account to EUR 200,000 per month. It's a joke. I'm wondering how large hedge funds manage their money and capital flows under such miserable banking conditions.

Let's hope that they will become normal after a year or two of banking with them...
 
So there's nowhere to go for reliable transfers.

On the one hand, I want a normal bank for stability. Now that I got one under the radar bank, a reputable one from France, they seem to be even more paranoid about occasional large transfers than small banks and EMIs I used to worth with before. I guess more reputation goes hand-in-hand with more paranoia.

They limited my account to EUR 200,000 per month. It's a joke. I'm wondering how large hedge funds manage their money and capital flows under such miserable banking conditions.

Let's hope that they will become normal after a year or two of banking with them...

These banks that are causing you issues - is my understanding correct that your personal banking and business banking are through separate banks? If you utilized the same bank for both (even if they weren't a 'primary bank' for both), it would likely help considerably - certainly with the first leg (moving funds from business to personal account), but also it would likely help with the second leg as well. Banks don't like seeing large amounts of money coming into an account and leaving immediately thereafter. If the funds are moving internally (from your business to personal account), it is bound to get a lot less scrutiny.

Is there something else that's raising red flags? i.e. citizenship/ties with a sanctioned country? Is your business considered somewhat high-risk? Are the amounts per transaction above 500k? Are the transaction amounts several multiples of the balance that you typically hold on the accounts? Any of these things could be drawing extra attention - some of them you can control, some of them not.

In case it's not otherwise obvious, having a relationship with the bank (especially people at the bank), will make a huge difference too - it sounds like for starters you may not be banking in the right places.

By the way, in today's day and age, especially in the EU, banks asking for supporting documentation for larger transactions has become pretty commonplace. (In 2017-2018, I began getting requests for documentation more often than 2015-2016, even though the activity in 2015-2016 was many times larger.)
However, if your docs are in order, I'd expect the bank to release the funds (or execute the transfer) same business day.
If they are taking longer than 1 business day, and the deals that you're getting in aren't shady and you don't have other reasons for red flags like above, I would be having a conversation with your banker and/or the branch manger tomorrow morning and depending on how that goes, looking for a new bank in the afternoon.
 
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@IntlOffshore Thanks for insights. Transactions I'm getting flagged for are much less than 500K, the one in question was in between 100 and 120 kilos. My main business activity produces about 200 kilos of monthly volume, and the monthly limit of 200K will basically not let me do anything out of scope.

Am I high risk? Somewhat. Online business is greenfield but I'm banking in France while having incorporated in Gibraltar. I have no notable ties to France but having real employees and office space in Gibraltar gives me just enough substance to not be classified as a shell company. Most French banks would not consider my profile unless I also had some employees or substantial client base in France. So in some ways, I am grateful for having this bank.

Previously, I used to bank with EMI's but they have other issues. Leopay for instance closed my account with no prior notice for months, and I had no option but to break the law and manage some business affairs via my personal account. In the end, I got my funds back but the damage they caused is substantial. I am determined to not use any EMI in the future, unless I see the regulators take action to tear down iCard AD (the entity that under-pinned Leopay) for unprofessional handling of client funds, illegal account closures without prior notice and multiple breaches of regulation.

Today I'm looking for another bank in a reputable country so I can split my flows in between 2 banks. I am aiming to reduce the AML BS risks by reducing the volume and deposits by 50%. If this does not help, I will get a third account and each bank will get just 33% of my business
 
I'm guessing you don't live in Gibraltar either, because as a Gibraltar resident and your business having a real presence there, I would have thought that you would easily be able to bank there.

Is your home jurisdiction not an option due to tax considerations? I'd guess part of your issue with the French bank is that your not easily able to get 'face time' with someone there. And, unless when you say France you mean Monaco, I'd assume that you may stick out - I'd be surprised if they have a significant number of non-resident companies (with non-resident UBOs) banking with them.

I just reread your initial post and figured I'd better check what you wrote re 'documentation that does not exist'. Just to be sure...you're only referring to the transfer between your business and yourself, right? But the 'investment opportunities' that you're going to be transferring to, you do have some supporting docs. Or no?
In my experience, except in cases that the bank is looking for a reason to kick you out (and typically, they'll just show you the door rather than look for the reason), when they're asking for docs, they're just looking to see something. Close to anything. If in the case your funds were held up you didn't give them any docs, I'd bet that showing the transfer as being a 'loan' from your company to yourself would have streamlined the process. Or if not a loan, a distribution of the company profit (or shareholder capital), whatever. But something.

All of this is just for working in your present setup/circumstances...but I'd assume you could probably improve your situation pretty easily.

Also, I'm not sure if there are advantages to having banking in France specific to your company, but I've never heard of a real bank (not EMI) limiting withdrawals before. At least not as low as 200k. Sounds like a French type of thing to do.

And for sure...splitting the activity across multiple accounts will help you (at least on the first leg of moving funds from the business to you personally). While you're anyways setting up a new account though, don't forget to open an account for you personally as well.
 
He may think about a Payment Service Provider?
 

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