Opening a U.S. Bank Account as a Non-U.S. Resident

For a foreign founder, the U.S. bank account is the first stepping stone. Without it there is no payroll, no merchant processing, no customer payments and no investor wire. Dilendorf Law Firm, a New York-based firm, guides non-U.S. residents and foreign-owned companies through account opening, entity formation and U.S. tax planning. This is what the process actually looks like in 2026 and how to avoid the delays that catch most newcomers.

Step one: the EIN, and why it sets the timeline

Every U.S. company needs an Employer Identification Number before a bank will open an account.

The IRS online tool issues EINs immediately, but only to applicants whose principal place of business is in the United States and whose responsible party has a Social Security number or ITIN [1].

A company owned and run by non-U.S. residents does not qualify. It must apply by telephone to the IRS international line, or submit Form SS-4 by fax or mail to the EIN International Operation in Cincinnati, and only one EIN may be issued per responsible party per day [2].

The IRS publishes faster processing targets for fax applications [3], but in our current experience international applications are taking six to eight weeks from submission to receipt of the EIN confirmation letter.

Because the bank account cannot be opened without the EIN, that wait defines the overall timeline. We file the SS-4 on the day the company is formed so that the clock starts immediately.

Step two: proving a physical presence

Federal anti-money-laundering rules require every bank to run a Customer Identification Program.

Before opening an account for a company, the bank must obtain “a principal place of business, local office, or other physical location”; for an individual, “a residential or business street address” [4].

For a non-U.S. person, acceptable identification includes a passport number and country of issuance [4]. The bank must also identify each individual who owns 25 percent or more of the company and one individual who controls it, and verify their identities [5].

How a bank applies these rules to a brand-new foreign-owned company is a matter of its own risk policy, and the policies have tightened.

Banks we work with generally ask for an executed office lease showing that the company actually operates from a U.S. address.

A WeWork membership or other coworking arrangement is usually rejected. A virtual office is rejected. Dilendorf Law Firm arranges physical office space for clients through partners in New York so that the lease is in hand before the bank meeting.

Step three: the bank meeting, in person or remote

Most of the large national banks require the account signer to appear in person at a U.S. branch, bringing the formation documents, EIN letter, office lease, passport and ownership chart.

Some of the banks we work with will open accounts for foreign-owned companies remotely, with verification by video and notarized documents, and we match clients to the right institution based on their travel plans, industry and expected transaction flows.

For a personal account, the documentation shifts to proof of residence: a residential lease, utility bills or similar records tied to the address the bank will record. Most large banks again require physical presence for personal account opening by a non-resident.

Why we recommend two accounts

U.S. banks periodically review their customer base, and accounts held by non-U.S. residents receive close attention. Federal regulators confirm that it may be lawful for a bank to close an account “without providing prior notice,” with the specifics governed by the deposit agreement signed at opening [6], and the CFPB states plainly that “a bank or credit union can close your account without your permission” [7].

A company that loses its only account mid-month loses payroll and vendor payments with it. We therefore advise opening two business accounts at different banks from the start, so that a closure becomes an inconvenience rather than an emergency.

Before the bank: choosing the right entity

The entity you form determines how the IRS taxes you and how your home country treats the income.

A single-member U.S. LLC is disregarded for income tax purposes by default; a multi-member LLC defaults to partnership treatment; either may elect corporate treatment on Form 8832 [8].

A foreign-owned single-member LLC is not exempt from reporting: it must file a pro forma Form 1120 with Form 5472 attached to disclose transactions with its foreign owner [9].

The right answer depends on the treaty. Under U.S. income tax treaties, residents of treaty countries “are taxed at a reduced rate, or are exempt from U.S. taxes on certain items of income” [10], and whether a company can claim those benefits turns on its classification, its residence and the treaty’s limitation-on-benefits article [11].

A structure that works for a founder in Germany may be the wrong choice for a founder in Brazil or the UAE. We review the applicable treaty before recommending an LLC or a C corporation, because the entity decision is far cheaper to make correctly at formation than to unwind later.

This article is for general informational purposes only and does not constitute legal or tax advice. Bank requirements vary by institution and change over time. Reading it does not create an attorney-client relationship with Dilendorf Law Firm. Attorney Advertising.