Opening a U.S. Bank Account as a Non-Resident: Steps and Practical Advice

You run an LLC registered in Delaware, you invoice in dollars from Paris, and your French bank refuses to process your incoming wires or charges prohibitive currency conversion fees. The question then becomes mechanical: how do you open a U.S. bank account when you are not a U.S. resident without flying over to sign at a branch? The answer is nuanced. It is legally possible, but customer identification rules have tightened considerably since the USA PATRIOT Act was adopted in 2001, with Section 326 requiring Customer Identification Program procedures at every American financial institution.

Two profiles coexist and follow distinct logics: the non-resident individual, who wants a personal account for investments or stays in the United States, and the owner of a U.S. entity (LLC, C-Corporation) who needs to open an account in the company's name. The required documents, the accessible banks and the tax constraints differ significantly between these two situations.

Is it possible to open a U.S. bank account without being a resident?

The short answer is yes. No federal law prohibits a non-resident foreign national from holding an American bank account. Operational reality is more mixed, because each bank applies its own acceptance policy beyond the regulatory baseline set by the Bank Secrecy Act and the USA PATRIOT Act. Many branch-network banks simply refuse remote account opening for a non-resident individual, judging the compliance risk disproportionate to the revenue the account generates.

The structuring distinction concerns the nature of the account holder. Opening a personal account as a non-resident with no physical presence in the United States remains the most difficult scenario: most large banks require an in-branch visit, a verifiable U.S. address, or an active immigration status and/or a Social Security Number. Conversely, opening a business account attached to an LLC or a C-Corporation incorporated in the United States is far more accessible, because the bank opens the account in the entity's name, identified by its EIN, and applies KYC rules to the company as much as to its beneficial owner.

Selecting the institution therefore becomes the decisive step. Targeting a bank whose internal policy explicitly accepts non-residents, or a neobank designed for foreign founders, avoids weeks of fruitless applications with institutions that will ultimately reject the file.

What documents and conditions are required for a non-resident?

The documentary baseline imposed by federal regulation (the Customer Identification Program required by the USA PATRIOT Act) rests on four pieces of information: name, date of birth, address and identification number. For a non-resident, the last item is satisfied by a valid foreign passport, supplemented, depending on the bank, by a second form of identification (driver's license, national identity card). Add a proof of address in your country of residence (electricity bill, landline bill or bank statement less than three months old), translated into English when the original document is not. An ITIN or an SSN, if available, smooths the process but is not a legal condition for opening. The initial deposit ranges from 25 to 3,000 USD depending on the institution, keeping in mind that it is often necessary to leave a certain amount in the account (1,500 to 2,000 USD) to avoid certain fees.

For a business account, the bank asks for the EIN issued by the IRS, the articles of organization (LLC) or articles of incorporation (C-Corp), the operating agreement or bylaws, a recent certificate of good standing and proof of filing of the Beneficial Ownership Information report with FinCEN as required by the Corporate Transparency Act.

The formal quality of the file determines acceptance: certified translations when the bank requires them, a Hague apostille on foreign civil status documents, digital signatures compliant with the FinCEN standard. A missing or improperly certified document leads to a rejection without further review, and forces you to restart the KYC process from the beginning. Romain Waiss-Moreau systematically reviews the documentary file before it is sent to the selected bank.

How can you open an account without an SSN or ITIN?

The Social Security Number is not a condition for opening an account in the United States. Federal banking law requires identification of the account holder under the USA PATRIOT Act, but accepts several equivalent tax identifiers. Three paths are open to a non-resident without an SSN, depending on whether the account serves a personal or business purpose.

• Business account through the EIN of the LLC or C-Corp: the Employer Identification Number issued by the IRS is sufficient for business neobanks such as Mercury, Relay or Wise Business. The opening is fully online, with no travel to the United States, provided the corporate file is complete and the Beneficial Ownership Information report has been filed with FinCEN beforehand.

• Applying for an ITIN with the IRS: the Individual Taxpayer Identification Number is obtained through Form W-7, accompanied by a 1040-NR tax return or a document supporting an exception. The processing time announced by the IRS is seven to eleven weeks outside peak periods. The ITIN opens access to traditional banks in branch (Bank of America, Chase, Wells Fargo) during a physical visit.

• International banks with cross-border offerings: HSBC Premier and Citi International allow you to open a U.S. account from an existing relationship in France, without a U.S. tax number, subject to thresholds of assets under management.

The choice between these paths depends on the purpose of the account and the operational timeline. Romain Waiss-Moreau frames this sequencing upfront, so that a late ITIN application does not delay invoicing for a business that is already up and running.

What are the practical steps to open the account remotely?

The typical remote opening process follows an ordered sequence, in which each step conditions the next. Any inversion (for example, approaching a bank before obtaining the EIN) results in an automatic rejection of the application.

1. Formation of the U.S. structure: incorporation of the LLC or C-Corp with the chosen Secretary of State, obtaining the EIN from the IRS via Form SS-4, filing the Beneficial Ownership Information report within the deadlines set by the Corporate Transparency Act.

2. Bank selection: choosing between a business neobank (Mercury, Relay, Wise Business) and a traditional bank, depending on the need for a physical debit card, check deposits or access to credit.

3. Preparation of the documentary file: Articles of Organization, Operating Agreement, EIN confirmation letter, passport of the beneficial owner, translated proof of address. A Hague apostille may be required for French documents.

4. Identity verification: KYC interview by video call or through the mobile app, with biometric capture of the passport.

5. Initial deposit by SWIFT wire from the French account.

6. Activation of debit cards and API access.

Observed timelines range from two to five business days for a neobank, and from two to six weeks for a traditional bank. Romain Waiss-Moreau can be engaged to manage the entire sequence.

Consistency between the declared legal structure and the account being opened is scrutinized at every KYC step: registered agent address, identity of the beneficial owner declared to FinCEN, corporate purpose. Any discrepancy triggers a suspension of the account, sometimes without notice.

Which banks and neobanks accept non-residents?

The American banking market splits into two distinct worlds for the non-resident. Traditional banks (Bank of America, Chase, Wells Fargo, HSBC, Citi) remain open to foreign clients, but in the vast majority of cases require a physical visit to a branch in the United States for signature and identity verification. HSBC offers an international gateway through its Premier program, provided you hold a sufficiently funded HSBC France account. Business neobanks (Mercury, Relay, Wise Business, Brex) accept a fully remote opening, but only for business accounts backed by a U.S.-incorporated LLC or C-Corp holding an EIN. No neobank offers a personal account to non-residents.

The choice revolves around three criteria: the need for a physical debit card delivered outside the United States, the volume of ACH versus SWIFT transfers, and access to credit (reserved for traditional banks once a track record is built). Romain Waiss-Moreau guides clients according to the business model and the trajectory of the structure.

What costs, fees and tax obligations should you anticipate?

The cost of an American bank account breaks down into three layers:

• Maintenance fees: 0 to 25 USD per month depending on the institution.

• SWIFT fees on incoming wires: 15 to 45 USD per transaction.

• Currency conversion fees: applied as a markup on the interbank rate.

Traditional banks also impose a minimum balance, generally between 1,500 and 25,000 USD, and falling below it triggers the monthly fees. Neobanks (Mercury, Relay, Wise Business) remove these thresholds but charge per use.

The decisive issue lies on the reporting side. In France, any tax resident holding an account opened abroad must declare it every year through form 3916/3916-bis (the French foreign account disclosure form) attached to the income tax return, under penalty of a 1,500 EUR fine per undeclared account (10,000 EUR if the account is located in a non-cooperative state). Income generated on the account (interest, dividends) is reported on form 2047, the French foreign income schedule.

On the American side, a non-resident receiving U.S.-source income files Form 1040-NR. An LLC owned by a single foreign member must file the combination of Form 5472 and a pro forma Form 1120, with a flat penalty of 25,000 USD per missed filing. Finally, FATCA requires the American bank to transmit the account holder's information to the French tax authorities: any reporting omission in France is mechanically detectable.

What to keep in mind before getting started

Opening a bank account in the United States without American residency remains perfectly legal and accessible, provided the operation is structured upfront. Going through an LLC incorporated in a suitable state (Delaware, Wyoming, Florida, New Mexico), combined with an EIN, the BOI filing with FinCEN and a complete KYC file, turns a process rejected by default into a smooth path. Neobanks (Mercury, Relay, Wise Business) open the remote route; traditional banks require a visit.

The main risk is not opening the account but the reporting architecture around it: French forms 3916-bis and 2047 on one side, Form 5472 with a pro forma 1120 and, where applicable, a 1040-NR on the American side. A qualification error (Effectively Connected Income, tax residency, physical presence) leads to disproportionate penalties. Romain Waiss-Moreau works on this transatlantic articulation to secure the structure before the account is opened. Contact Romain Waiss-Moreau to learn more.

Frequently asked questions

Do I have to report my French income to the IRS if I have a U.S. bank account?

No, holding an American account creates no reporting obligation to the IRS regarding your French income. U.S. tax liability is triggered only if you become a U.S. tax resident under the Substantial Presence Test (cumulative physical presence over three years, excluding exempt individual statuses: F1/J1 students, J1 teachers, A/G diplomats). As long as that threshold is not crossed, you remain taxed in France on your worldwide income and file no 1040 in the United States.

What should I do if I forgot to declare my American account in France for several years?

The account must be regularized through form 3916-bis, the French foreign account disclosure form attached to the 2042 income tax return, with amended filings for the years concerned. The standard penalty is 1,500 euros per undeclared account per year (10,000 euros if the account is held in a non-cooperative state). A voluntary disclosure to the French tax office, before any audit, significantly reduces the penalties and removes the criminal risk of tax fraud.

Is a refusal by an American bank final?

No. A refusal most often reflects an incomplete KYC file or a profile unsuited to the product requested (a personal account requested without any U.S. nexus, no EIN, BOI not filed). Repositioning the application through an LLC incorporated in a suitable state, with an EIN obtained, the BOI filing with FinCEN completed and an acceptable U.S. address document, is enough in most cases to unlock the opening with another institution.

Do you need a lawyer to open a U.S. bank account as a non-resident?

Not for the opening itself, which is handled by the neobanks or the chosen bank. Legal work is warranted for the upfront structuring: choice of the state of incorporation, drafting of the operating agreement, obtaining the EIN, the BOI filing, and the French-American reporting articulation (forms 3916-bis and 2047 in France, Form 5472 and pro forma 1120 in the United States). Romain Waiss-Moreau works across this transatlantic chain to avoid penalties tied to a mistaken qualification of income or tax residency.