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The bank refused your company. What now?
A refusal is a decision about a file, not a verdict on a business. It is also, in most corporate cases, unexplained. There is no right to a business bank account in the European Union and no duty to tell a company why it was declined, which leaves founders guessing. Guessing is what turns one refusal into four.
Estonia's own government publishes the list of reasons. On 11 August 2025 the e-Residency programme set them out: the business does not fit the provider's risk profile, the sector is treated as high risk regardless of how legitimate the company is, the ultimate beneficial owner is resident in a sanctioned country or a jurisdiction on the FATF grey or black list, or the application itself was incomplete, vaguely described, structurally complex or inconsistent with its own documents. Each of those has a different remedy, and most of them are fixable in weeks rather than months.
The remedy is not a better cover letter. It is a rebuilt file, a provider chosen against its published policy rather than its marketing, and applications filed in an order that does not spend the best option on the weakest version of the case.
Why applications are refused, and what actually changes the answer
The reasons are the Estonian government's own list, published by the e-Residency programme on 11 August 2025. The remedies are ours.
| The reason | What it means in practice | What changes the answer |
|---|---|---|
| The business does not fit the provider's risk profile | The provider could not verify what the company actually does, where its customers are, or how the money moves, and priced that uncertainty as risk | A business-model memo and a transaction-flow diagram that answer the compliance question before it is asked, supported by contracts, invoices or order data showing the described business exists |
| The sector is treated as high risk | A published policy exclusion applied before anyone reads your file. Wise, for one, restricts crypto, gambling, adult content, weapons, prescription pharmaceuticals, tobacco, retail alcohol, CBD and nutraceuticals under its acceptable-use policy. The exclusion reaches affiliate marketers connected to those industries as well | Stop applying to providers whose policy already says no. The provider set for a restricted activity is a different set, it expects a licence and a working AML framework, and it prices for the risk instead of refusing it |
| The UBO's country of residence or citizenship | Sanctions screening, or a hit against the FATF grey or black list. The provider is managing its own exposure and will not negotiate it | An EEA or Swiss residence document for the UBO where one exists, source-of-wealth evidence proportionate to the sums involved, and a corporate chain with no unexplained layer. Where the constraint is genuinely legal rather than commercial, the answer is a different structure, not a different letter |
| The application was incomplete | Missing documents, or documents that contradict one another. The cheapest refusal there is, and the most common | A document audit before re-filing: register extracts, the ownership chain traced to a natural person, proof of address, source of funds, and every name, date and figure consistent across all of them |
| The business description was vague | Words like consulting, trading or IT services tell a compliance officer nothing, and an answer that explains nothing reads as concealment | A specific description: what is sold, to whom, in which countries, at what average ticket, through which payment rails, and at what expected monthly volume |
| The ownership structure is complex | Layers, nominees or offshore entities in the chain. LHV, for example, does not open accounts for companies registered offshore or owned through an offshore structure at all | Simplify before re-applying, or document the commercial purpose of every layer. Where an offshore entity sits in the chain, expect to remove it rather than to explain it |
How a remediation runs:
01
Read the refusal, including the silence
We ask the provider what it can tell us, and we read what it will not. The combination of which provider refused, at which stage, and after which question is usually enough to identify the reason from the list above even when nothing is stated.
02
Rebuild the file
The corporate chain to a natural person, the UBO file, source of funds and source of wealth, a specific business description, a transaction-flow diagram, and the contracts or invoices that prove the described business exists. Then a consistency pass, because contradictions between documents cause more refusals than any single missing paper.
03
Re-match the provider to the profile
We check the rebuilt profile against each candidate's published acceptable-use policy and eligibility criteria. Where the activity is restricted by policy, no version of the file will pass, and the shortlist changes to providers that underwrite the sector.
04
Re-apply in the right order
Applications go out one at a time, strongest fit held back until the file is ready. A provider that has already declined this company, this owner and this description will decline the same file again, so the re-application to a previous refuser goes last and only with something genuinely new in it.
05
Challenge where there is something to challenge
Where the refusal, the freeze or the closure looks like a blanket category rule rather than an assessment of your file, we put that to the institution in writing, escalate to the supervisor where the conduct warrants it, and pursue the release of funds through the courts where it does not resolve.
A frozen or closed account is a different emergency from a refusal, and a faster one. The company still has payroll, suppliers and tax deadlines, and the money it needs is sitting behind a compliance hold with no stated end date. We work those in parallel: a written demand for the funds and the reasons, escalation to the supervisor where the institution's conduct warrants it, an urgent second rail so that trading continues, and litigation where the money is not released.
Order matters more than speed. Every application you file is one you cannot withdraw, and a provider that has already declined this company, this owner and this description will decline the same file again. We fix the file first and keep the strongest-fit provider for last, rather than spending it on a version of the application that was never going to pass.
What we will not do is promise that a particular bank will say yes. No adviser sits on a compliance committee. What we can say is that most refusals we see are decided by the file rather than by the company, and a file is something you can change.
Services we provide after a refusal:
- Diagnosis of the actual refusal reason, including where nothing was stated
- A full rebuild of the KYB and KYC file, with a consistency pass across every document
- Business-model memos, transaction-flow diagrams and specific activity descriptions
- Source-of-funds and source-of-wealth files proportionate to the amounts involved
- Restructuring the ownership chain where a layer, a nominee or an offshore entity is the obstacle
- A provider shortlist checked against each candidate's published policy, in filing order
- Written challenges to a refusal, a freeze or a closure, and escalation to the supervisor
- Recovery of funds held after an account closure, including through the courts
- An urgent second banking rail so the business keeps trading during the remediation
- Licensing advice where the sector genuinely requires an authorisation before any provider will underwrite it
Frequently asked questions
We are ready to take on non-standard projects
Averium rebuilds refused bank applications, challenges freezes and closures, and will tell you in the first conversation whether the problem is your file or your profile.
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