How it all began
For more than 10 years, our company has been successfully opening bank accounts for our clients. During this time, we have accumulated a vast experience in this sphere, allowing us to guarantee of opening new bank accounts in a range of various jurisdictions.
There was a time when opening of bank accounts was very simple. I can give some examples of how everything was in the past and utter a nostaglic sigh: “Ah, those were the times!”.
Eltoma Corporate Services opened its first office in Cyprus which started in 2002 by chance; i was changing workplaces from a Sakhalin-2 project to work in a small cozy office overlooking the sea in the Cypriot city of Limassol. So somehow, talking with former employees of the Cypriot Laiki Bank which has now sunk into oblivion; it turns out that Eltoma Corporate Services was one of the largest introducers of the bank. For example, during the pre-crisis year of 2012, we opened about 400 bank accounts with Laiki Bank for our clients. Most of the companies for which bank accounts were opened were from “tax-free harbours”.
From this moment on, a lot of time has passed and many things happened that dramatically changed the Cyprus banking system. The banking crisis of March 2013; the implementation of a law on licensing the activities of service providers who open and maintain offshore companies; the introduction of the 4th AML Directive which led to the sophistication of bank account opening procedures, etc.
It is worth noting by the way, that all service providers maintaining offshore companies already created Beneficial Ownership registries (not the Shareholders whose names and addresses were always publicly available in many jurisdictions). The 5th EU Anti-Money Laundering Directive will make these registers transparent like other offshore companies registries (for Directors and Shareholders).
Previously, opening accounts in Hong Kong was also a quickly concluded case: a client needed to visit Hong Kong, should have had basic level of English and “business links with Asia.” Service providers in Hong Kong had the status of introducers and could organise meetings with the bank in their office. To open a bank account for the people who are just off the street wasn’t a problem either. Similarly, we opened accounts for our companies and customers with whom we regularly flew to Hong Kong.
In Hong Kong, bank accounts opened mainly with UK banks such as HSBC and Standard Chartered Bank. Sometimes it was Singaporian DBS and US Citibank. Unfortunately, opening accounts at the Chinese banks never really worked out somehow.
However, some time ago, Hong Kong went belly-up. HSBC and Standard Chartered Bank began to close customers’ accounts for overseas companies and did not rush to fill the void and open new ones. Now, opening a bank account in Hong Kong faces certain difficulties: companies are required to open an office and recruit employees in Hong Kong and this is a big expense, practically depriving the offshore company of profit.
If we are talking about opening a bank account in Singapore, historically it has always been a simple matter. From the very beginning, Eltoma Corporate Services established good relations with local banks, allowing us to open bank accounts even without visiting Singapore. Unfortunately, this did not last long: the fight against tax evasion quickly spread to Singapore which is obvious, as Singapore is the fourth financial centre in the world after New York, London and Tokyo.
Along with the fact that the struggle against offshore companies has been increasingly active, it becomes more difficult to open a bank account in Singapore. One bank employee told me that instead of one department, there are four compliance departments now. And to open a bank account it is necessary to get the permission of at least two departments.
Currently in Singapore there are about 200 registered banks. However, only a small number of Singaporean banks actually have a banking license for all services, which gives the right to open corporate bank accounts for offshore companies. A full list of Singapore banks can be found on the MAS website (Monetary Authority of Singapore, or the Central Bank of Singapore).
The situation with Cyprus has taught us to focus more on local banks, because procedures of bank account opening for foreigners are much easier there than in foreign banks. Now we mainly work with OCBC, UOB and DBS. (The only exception is the Malay banks in Singapore Maybank, CIMB and US Citibank).
British banks HSBC and Standard Chartered Bank in Singapore differs a lot from those in Hong Kong. Previously we actively cooperated with Standard Chartered Bank – until it began to demand offshore companies have an office in Singapore. Although at that time no Singaporean bank required this, and so we had to refuse services from Standard Chartered Bank.
In its turn HSBC requires companies to report on the turnover figures, i.e. the client must provide an extract from the bank where it would be indicated that at the time of opening an account the offshore company’s turnover is at least USD $3 billion. Due to these conditions, relations with HSBC in Singapore also did not work out.
What guarantees can be given to an offshore company when opening a bank account in Singapore?
Very often you hear from clients asking: “Do banks in Singapore have no need for customers?” Previously we also asked bankers of Singapore similar questions. And one woman frankly replied: “I could open 500 bank accounts a day.” Such an answer indicates that demand far exceeds supply so the bank can afford to choose potential clients.
People often ask us: “Do banks open accounts for customers from Russia and Ukraine?”. Answering this question we may use one of the bankers words: “The opening of a bank account to a greater extent depends on the structure of the offshore company and the business that this offshore company conducts.”
I would like to note that we started the process of opening our own office in Hong Kong, which began with the registration of an offshore company in Hong Kong called Eltoma (Hong Kong) Limited; after that we have put an advertisement for employees on the JobDB website. Now we are on the way to obtaining a work visa for one of the employees from the Singapore office.
The decision to open our own office in Hong Kong has two main objectives: entering the Chinese market where the services we supply are in high demand and solving the problem of opening bank accounts for offshore companies of our existing and potential customers. Eltoma Corporate Services already has offices in Singapore, Cyprus, Moscow, Kiev, St. Petersburg and there is also a representative office based in London.
In September I’m moving to the UK. Now we have already had Eltoma (UK) Limited as well as an open bank account with Barclays Bank. We are going to open the main office in Glasgow UK, where I am going to move. By the way, I will have then lived in three foreign countries: in the UK, Cyprus and Singapore.
So, in this article let’s focus on the key points regarding opening bank accounts in Singapore.
Companies from which jurisdictions can successfully open a bank account in Singapore?
It should be noted that opening a bank account in Singapore is easier for local companies. The only exception that we have made for ourselves are offshore companies from Hong Kong. Theoretically, we could open bank accounts for offshore companies from other jurisdictions. The only obstacle so far is that we do not know how to justify why, for example, a Cypriot company needs a bank account in Singapore. In other words we still can not give an exact answer to the simple question: “Why do companies from other jurisdictions need a bank account in Singapore?” In such instances, banks require the foreign company to have business links not only with the Asian companies in general but Singaporian ones as well.
It’s interesting that for an offshore company from Hong Kong, the legalisation of corporate documents are not required. This significantly reduces the cost of opening a bank account for an offshore company from Hong Kong.
Business links with Southeast Asia
To date, this item has become one of the most fundamental points regarding bank accounts opening for an offshore companies in Singapore. What does this mean in practice? The answer is quite simple: suppliers or buyers of an offshore company must be from Southeast Asia. Ironically in this case, Chinese companies meet with rather strict requirements. As I mentioned above to help customers cooperate with companies from China, we decided to open our own office in Hong Kong.
Evidence of such links to Southeast Asia may include contracts with suppliers or buyers or in extreme cases, letters or agreements of intent. We always tell our customers about this issue and ask them at least to reach out to potential customers or suppliers from Southeast Asia. However, unfortunately, very few people listen to us and after an interview with a Singaporean bank, clients have already understood that those were not just empty words but an obligatory requirement of Singaporean banks. After that, most offshore companies establish business connections with Southeast Asia.
If the client has already had real or potential suppliers from Singapore, then it’s just an ideal situation. In this case, a bank account in Singapore can be opened in only 2-3 weeks.
What types of businesses are viewed favourably by Singapore banks to successfully open an account?
Simply speaking, Singapore banks are most loyal to companies that trade in goods. In this situation, opening a bank account in Singapore is easy and simple. Opening an account for an offshore company that provides services to customers in Southeast Asia is also not problematic. Again, the thing is whether you have links with the region or not.
ICO and cryptocurrencies are very popular now. I’ll tell you straight away that any bank in Singapore will not open accounts for companies planning ICOs or conducting trading in cryptocurrencies in Singapore. The only solution we have found for our customers is to obtain a licence from the Registered Fund Management Company (RFMC) in Singapore. I would also like to note here that the implementation of this solution requires regular investment (for the renewal of the licence, you need to have a real office in Singapore and two employees). It will cost at least EUR 10,000 per month. Unfortunately, we do not have a low cost solution for smaller companies or start-ups.
It should also be noted that banks are in no hurry to open accounts for start-ups. In order to open a bank account for an offshore company, the bank will ask to furnish it with the proof of any existing client’s business while the location of the company isn’t relevant unless the company is located in North Korea or Iran, of course!
Opening a bank account for a holding company even registered in Singapore poses a problem unless the client himself wants to move to Singapore and become the Director of a Singaporian offshore company. Banks in Singapore like in other jurisdictions except Switzerland and countries similar to it do not like passive bank accounts. This is due to the fact that under anti-money laundering legislation such accounts are recognised as high risk accounts; and bankers do not want to risk.
If you need to open a bank account for an investment company that trades in securities, then it is more prudent to do it within the investment bank unit. In order for securities trading in Singapore not to be taxed, it is necessary for the Singapore company to keep these securities on its balance sheet for at least 24 months. For securities trading, Cyprus is the most suitable jurisdiction where income from such trading is excluded from taxation.
Offshore company structures
We are profoundly aware that most clients prefer to remain in the background. There may be many reasons behind this. Nevertheless, we live in an age of increased transparency and this must be taken for granted. Now, you can no longer hide behind the nominee beneficiaries anymore.
I would like to remind you that the main elements of offshore company structures are Directors and Shareholders. So Singaporean banks want to see the companies ultimate beneficiaries and at the very minimum one Shareholder of the company. We understand that taking into cosideration legislation on CFC and currency residency, this creates certain problems for Russian citizens. However as the saying goes: it is indeed a different ball game.
A small relief which we received from the banks, is the opportunity to put a Belizean company behind the wheel (there is no open register of Directors and shareholders in Belize). Therefore data of the final Beneficiary are ultimately kept secret. The only thing is that such a Singaporean company loses certain tax benefits in Singapore.
According to the Companies Act of Singapore, one of the Singapore Company Directors must be a resident of Singapore (and not necessarily a citizen of Singapore). For this reason, in the structure of the Singapore offshore company, there will still be one nominee unless the client himself wants to obtain a work permit in Singapore and become a resident of Singapore himself.
Integral business features
Everyone should remeber that we live in the 21st century when technological progress is marching across the planet at rapid-fire pace. Singaporian bankers simply do not understand why the company doesn’t have its own website, because nowadays it’s a type of business card for the company; or why the client doesn’t have a personal business card. Small “tricks” of the clients when they say they “left” it in the hotel or did not have time to create a website usually lead to a prejudiced attitude towards the potential banking client and sometimes even leading to a refusal to open a bank account at all.
Arriving in Singapore, the client must understand who needs to open a bank account: he himself or the bank. If there is no urgent need for a bank account in Singapore then, probably, you should not compete with Singaporean banks. It is much better to come to Singapore as a tourist and enjoy its dynamic character and originality.
Minimal knowledge of English
The Singapore bank will immediately refuse to open a bank account for an offshore company if the company representative shows up for the interview with an interpreter. In this situation, we can not blame the bank because even the client will not be able to communicate with the bank directly if there is such a necessity. In this instance, we do not even schedule a meeting with the bank.
What are the ways out of this situation? Apparently, there is only one way out: to appoint one of the relatives, employees or authorised person to be a bank account signee as long as their English is fluent.
Another pecularity is the bank’s communication with customers: as a rule, Singaporean bankers call clients at 10 am local time and considering the time difference (5-6 hours to Russia), it’s very early in Moscow or Kiev. Therefore, clients should be available to communicate with the bank at these times. Among other issues it should be mentioned that the Singaporeans speak English with a very strong accent. In other parts of the world it was even coined “Singlish!” So it can be concluded that knowledge of English is one of the most important requirements for opening a bank account in Singapore.
Estimated turnover of the account & average balance on the Singapore company bank account
Trying to open a bank account for a company that has an annual turnover of USD $100,000 is simply not worth it – no bank will do it. We recommend contacting us for opening a bank account for an offshore company in Singapore if the annual company turnover is at least USD $1,000,000, however even this figure seems to be small for Singaporean bankers. Nevertheless, we can always choose a bank in Singapore that agrees to work with smaller clients (with an annual income of USD $400,000). Banks in Singapore consider that an optimal company turnover starts at USD $10,000,000.
Also you should remember that banks make profit from effecting bank payments. The more payments they carry out, the bigger the profit of the bank is. Obviously, for the bank it is important to know how much money will be being transferred in and out of the offshore company’s corporate bank account.
Another point is how long money remains in the bank account or the so-called weighted average daily balance on the offshore company’s bank account. This is again connected with anti-money laundering legislation. According to AML laws, the rapid movement of money through a bank account indicates a high risk of money laundering. Therefore, it’s no wonder that if the bank notices such transactions then it will remove such a client from its books with immediate effect.
What are Singapore banks trying to avoid?
Below you may find a list of obstacles of a bank account opening in Singapore:
- Holding companies receiving income only in the form of dividends.
- Financial companies receiving income only in the form of interest on loans.
- Euro accounts. Ironically, Singaporean banks are of the opinion that the euro is a very volatile currency so many banks charge a commission for holding this currency.
- A full nominal structure of the offshore company where only nominees are serving as Directors and Shareholders.
- Usage of a bank account as a so-called transit one.
- Inactive bank accounts.
- Lack of business ties with Southeast Asia.
Eltoma Corporate Services approach to the bank account opening in Singapore for an offshore company
Eltoma Corporate Services unique approach to opening bank accounts in Singapore for offshore companies lies in the preparation of our clients, in order for them to pass the interview with Singaporean banks successfully. To prepare our clients for the interview we ask them to file a Bank Summary, a document that Eltoma Corporate Services has developed and is actively using.
In its turn, we often hear compliments from Singaporian bankers because they like our approach to opening bank accounts. As a rule, the clients’ meeting with the bank is rather formal (in the form of signing bank forms, client’s passport and signature verification by the banker). To achieve this, a sufficiently detailed description of the business in the Bank Summary is required. A detailed description of the business provided in the Bank Sumarry allows us to achieve this.
The Bank Summary developed by Eltoma includes the following sections:
- Company name.
- Structure of the company (Directors and Shareholders).
- Business address (i.e. the place where the real activity of the company is carried out).
- Description of business and business model:
- The branch of trade or industry where business is conducted.
- History of creation and development of business, its size and features (specialisation, etc.).
- Description of goods and services.
- Suppliers and buyers.
- Description of the alleged cash flow of the offshore company through the Singapore bank account:
- Annual turnover.
- Amount of the incoming and outgoing funds.
- Estimated weighted average daily account balance.
- Jurisdictions where payments will come from and go to.
- The currency of the bank account, etc.
I would like to specify some of the important points from the above list regarding the following sections:
Do not name the address of our office in Singapore for the company business address. Hundreds of Singaporean companies we provide services for using this address as the registered address of the company.
Description of business and business model
It may be surprising to hear that many clients can not actually describe their business. In most cases, it is a hard task to get the information out of the clients and then structure it to make an appropriate Bank Summary. We sometimes even think that we are in more need of opening the bank account than the client himself!
Risks associated with opening Singapore bank accounts under a Singaporean service provider’s name
Even we’ve gone through the opening of bank accounts under the local service provider’s name; there was a time once when we tried to speed up the process of opening an account for an offshore company in Singapore by opening it under our Singapore nominees’ names. We stopped doing that in 2015 after the banks strongly recommended us to no longer do it.
I have already written that sometimes we have to see people who took such a risk and came back with their tail between their legs after losing all their money. I’ve already written about this and will not repeat it again; it’s easier to read this article here.
Those who taught physics should remember the law of the conservation of energy. Applicable to offshore companies, we can say that if the risks in one place have decreased then in another place they will necessarily increase. Do not be like a small child who closes his eyes with his hands and sincerely believes that no one sees him!
How can Eltoma Corporate Services help you?
We are of the opinion that firstly the client should be introduced to the bank, then independently develop relations with it except for the cases when clients pays us for their bank account maintaince. In all cases, the client should become the final beneficiary in the bank and a named account holder himself.
What issues do Eltoma Corporate Services solve? We open bank accounts in Singapore on a weekly basis both for external customers and offshore companies we provide services for.
In order to open a bank account in Singapore, we take the following steps:
- We fill out the Bank Summary together with the client.
- We send the Bank Summary to the Singaporian bankers whom we closely cooperate with.
- We agree on the date of the client’s arrival in Singapore.
- Based on the Bank Summary we conduct a preliminary interview with the client in English – this is done to make it easier for the client to pass the interview with Singaporean bankers successfully.
- We provide assistance to the client during the interview and answer the questions of the bankers if the client finds it difficult to answer them or if the client is off the track.
- We communicate with Singaporean banks to complete the procedure of a bank account opening for an offshore company.
- The client names our Singapore office as an office for correspondence with the bank. For this reason, we get tokens and passwords and then send them to the client via courier service.
- For the accounting purposes we scan bank statements.
- If a client pays us for being a contact person in a Singapore bank then the bank calls us on all the issues and we contact the client at a convenient time to resolve all the issues.
One of the most important advantages that we have in Singapore has been establishing personal relationships with bankers since 2009, as they allow us to discuss complex issues and find compromises for the sake of our clients’ businesses.
For more information about the organisation of businesses in Singapore, you can click on the links below:
- Offshore companies in Singapore: myths, reality and common practice.
- Fee schedule for registration and maintenance of Singaporean offshore companies.
- Company registration and formation process in Singapore.
- Tax and accounting regulations in Singapore.
- Opening a Bank Account in Singapore.