Wolfsberg Principles

The Wolfsberg Principles give the owner of an international company a clear logic for preparing to work with a bank. A structured description of the business, source of funds and payment scheme helps to combine documents into one consistent history. This preparation speeds up the application and makes further work with the business bank account more predictable.

How the Wolfsberg Principles apply to a corporate client

For the owner of an international company, the Wolfsberg Principles are useful as a practical map of a bank review. They explain why a bank requests information about the ultimate owner, source of wealth, source of specific funds, purpose of the account and expected transactions. The more consistently these data are connected, the easier it is for a bank or payment system to understand the business and its normal payment activity.

A modern bank approach is not limited to a formal questionnaire. An international bank or payment system assesses the activity of the client company, ownership structure, countries of operation, products, payment channels and actual activity. Therefore, when preparing to open a business bank account, we treat the bank document package as one set: the company, owners, contracts, turnover, currencies and payment scheme should describe the same real business.

It is especially important to distinguish the source of the owner’s wealth from the source of specific funds. Source of Wealth shows how the owner accumulated wealth as a whole. Source of Funds relates to the origin of the specific money received into the account or used in a transaction. For an entrepreneur, the source of wealth may be many years of business, sale of a share, investment activity or professional income, while the source of funds for a particular payment may be a dividend, loan, payment under a contract or sale of an asset.

The bank also assesses whether actual activity corresponds to the declared data. If a company stated that it receives payments from European B2B clients for IT services and then starts regularly receiving large transfers from another geography and for another purpose, the bank or payment system will naturally request an explanation. We therefore recommend building a consistent payment history in advance and keeping documents for key transactions.

The Wolfsberg logic is also useful after the account is opened. If owners, directors, activity, turnover or settlement geography change, the bank document package should be updated. For a business, this is a normal part of supporting a company business bank account: the bank needs to understand how the company is developing and why the nature of its transactions changes.

For an international company, proper preparation does not mean an excessive set of documents for every transaction. The task is different: determine in advance which documents confirm the key elements of the business and keep them current. These are corporate documents, ownership structure, contracts, invoices, financial reports, evidence of Source of Wealth / Source of Funds and information about major counterparties.

When choosing a bank or European payment system / EMI, we compare these data with the criteria of the specific bank or payment system. One bank may be more suitable for a trading company with SWIFT payments, another for a European service business using SEPA, and a third for a company that needs several currencies and a reserve account. As a result, the Wolfsberg Principles become not a theoretical document but a useful basis for opening a company business bank account.

For private banking and corporate servicing, the role of intermediaries and authorised persons is important. If documents are submitted to the bank by a professional adviser, corporate secretary or another representative, the bank or payment system still identifies the client itself and the ultimate beneficial owner. Therefore, the power of attorney, authority of the signatory and the role of each participant in the corporate structure should be clear from the documents.

A separate part of the review relates to PEPs and other relationships that the bank classifies as higher risk. In practice, this means a more detailed set of data, not a different commercial status for the client. If the relevant information is disclosed in advance and supported by documents, it can be included in the general KYC package together with information about the business and source of funds.

Transaction monitoring after the account is opened is also based on comparing an actual payment with company information. The bank analyses not only the transfer amount but also transaction frequency, countries, purpose, counterparties and the connection between the payment and the company’s normal activity. It is useful for a company to have a clear payment scheme and determine in advance which documents support the main types of receipts and expenses.

A risk-based approach allows a bank to apply different depths of checking instead of the same set of procedures to every client. For the business owner, this gives an advantage: good company information helps the bank or payment system understand more quickly which transactions are normal and which require additional explanation.

When supporting a business bank account, TAXC treats KYC/KYB as a continuation of corporate work. If the ownership structure changes, a new market appears, turnover increases or the company launches a new product, we update the bank information and align the documents with the new payment scheme. This helps maintain a consistent history of the relationship with the bank or payment system.