Cyprus: Bank Account Opening In Cyprus And In Other EU Countries

Last Updated: 11 August 2017
Article by Shanda Consult Ltd

Originally published 10th March 2017

This article informs about necessary documents and information required for the opening of a bank account in Cyprus or elsewhere.

We often hear that some service providers like consultancy firms, corporate service providers, accountants and others advertise "guaranteed bank account opening" in Cyprus and in other countries. This is, indeed, not true.

It is important to know that the decision to open or to reject the opening of a bank account is in the absolute and sole discretion of the bank applied to. Nobody else, no third party can "guarantee" the opening of a bank account in Cyprus or in any other country.

Documents and information generally requested for Cyprus bank account opening

Documents and information generally requested as minimum requirement for due diligence and compliance procedures in context of the application for a Cyprus bank account are listed below. The requirements may slightly vary from bank to bank. The documents and information requested is based on the provisions of the 4th Anti Money Laundering Directive (the 4th AML Directive).

Certified copy of a valid international Passport or national Identification Card.

Applies for all individuals involved in a company or in company structures, including shareholders, ultimate beneficial owners (UBO), etc.If the shareholder of a Cyprus company is a company where the client is shareholder, then, for example, passport or national identification card and all other following documents of the director of that company is required as well. If that company has other individual shareholders, the same applies for those other shareholders.

Proof of Address - Original or certified copy

Must be not older than 3 months, bearing the full residential address (including postal code) and the full name of the person as stated in the passport. Following types of documents are accepted as proof of address:

  • Utility bills (electricity, gas, water, fixed phone bills or municipality service bills, but not mobile phone bill)
  • Confirmations of Residence issued by Office for Registration of Residents.

The Proof of Address must be in English language. If it is issued in another language, an official and testified translation must be provided. Testified translations can also be arranged by Shanda Consult, against an additional fee.

Bank Reference Letter - Original

Must be not older than 3 months and must bear the individual's address as stated in the Proof of Address.Most banks have standard reference letter templates in their systems; account balance do not need to be mentioned.

The Bank Reference Letter must be in English language. If it is issued in another language, an official and testified translation must be provided. Testified translations can also be arranged by Shanda Consult, against an additional fee.


Curriculum Vitae (or résumé), in English language, showing the professional career of the individual.Note: In order to assess the risk that a particular customer or client may bear for the bank, the bank has to understand how experienced and/or educated the individual is in the field of business planned or carried out.

Additional documents in case the shareholder is a legal entity:

Certified and recent core documents of the legal entity

This generally includes the corporate documents of a legal entity, such as excerpt from the registrar of companies, Memorandum and Articles of a company etc. The documents must provide evidence regarding the shareholders, directors, registered address and registration number of the legal entity. It must also be proven that the legal entity is currently existing.

Note on Certifications

Please note that the passport copies and the address proofs need to be certified as a true copy, in English language.Documents may be certified by an independent lawyer, accountant, notary, bank manager or embassy official, who should provide their name, address, status on the certified document.

The certification shall have the following wording:

I hereby certify that this is a True Copy of the Original document which I have seen, and that I have met with the individual and confirm the photograph is a true likeness.

Name of the Certifier:
Contact Details:

Detailed description of business

A detailed description of planned or currently undertaken business must be provided. The business description must provide names (with addresses, if possible, but at least mentioning the countries involved) of suppliers and customers (or future suppliers and future customers), and a clear picture of the flow of goods or services, and flow of payments (in both directions (suppliers/customers). The description shall also include domain names of websites of the company, the beneficial owner's company (if applicable), and of (planned) suppliers and customers).

In case that (planned) customers are retail customers, the current or targeted group(s) of customers must be described.

Consequently, an appropriate business description consists of minimum half a page of text.

Source of Wealth

The ultimate beneficial owners are obliged to declare the source of their wealth, including a listing of their wealth.Considered as wealth are owned real estate property, substantial funds on bank accounts, investments in securities or shares of companies, owned luxury cars, yachts or planes, etc.

If an ultimate beneficial owner does not have any wealth, then this must be declared as well.

Business Plan

Some banks may require a business plan. This is not common for Cyprus bank account opening, but obligatory for example for Hong Kong bank account opening.

Additional information, in the normal course of procedures

In the context of Cyprus bank account opening (or elsewhere) banks will ask for additional information, which will be covered by the application forms of questionnaires of banks or service providers. Such information generally includes:

  • purpose of the bank account relation,
  • expected annual account turnover,
  • expected highest incoming transfer,
  • expected highest outgoing transfer,
  • countries from which transfers are expected,
  • countries to which transfers are expected
  • nature of incoming transfers,
  • nature of outgoing transfers,
  • tax identification number of the beneficial owner(s) in his or her country of residence.

If the shareholder of a Cyprus company is a company, banks may also ask for recent annual financial statements of that company.

Additional information, for licenced business

If the Cyprus company (or applicant company in another country) conducts or plans to conduct regulated business activities, certified copies of the respective licences or permissions need to be submitted.

Additional information, in case of politically exposed persons

If the ultimate beneficial owner of a Cyprus company (or applicant company in another country) is a "politically exposed person" ("PEP"), "enhanced compliance rules" apply automatically and appropriate additional information and evidence may be requested.

Additional information, in case of high-risk customers in general

If the ultimate beneficial owner(s) of a prospective customer is to be classified as high-risk customer, "enhanced compliance rules" apply automatically and appropriate additional information and evidence may be requested. Regarding the classification of high-risk customers, please see the EU's guidelines in the Annexes to the 4th Anti Money Laundering Directive at the end of this article.

Cyprus still remains as a place of business with a relatively low tax burden, compared with other EU countries. Cyprus tax rules provide for a total taxation of business profits with 12,5 % corporate tax, payable on taxable profit classes. As Cyprus provides the lowest overall tax burden for both businesses and individuals in the EU, Cyprus Company Formations are increasing. The Cyprus Registrar of Companies reported almost 1.900 Cyprus Company Registrations during the first two months of 2017.

Please do not hesitate to contact us for more information and perhaps for our services  regarding Cyprus bank account opening or Cyprus company formation: .

Banks' customer acceptance policies and account opening procedures

Banks' customer acceptance policies and account opening procedures in the EU member states are mainly ruled and shaped by the national implementation laws of EU directives and OECD/G20 rules. If there is no national implementation law in place or if a national implementation law is not covering all provisions and aspects of respective EU directives, said provisions of such EU directives become national law automatically and are thus legally binding.

Furthermore; Central Banks or National Banks formulate directives and circulars, based on respective EU directives and national implementation laws. Those directives and circulars are binding for the banks in the country.

The 4th EU Anti Money Laundry Directive

The current 4th EU Anti Money Laundering Directive (the 4th AML Directive) is the main legislation affecting banks' customer acceptance policies and account opening procedures. However, said directive is not the only legal instrument to be taken into account.

At the time when this article was published (09 March 2017), there were yet no national implementation laws for the 4th AML Directive in place, not even in one single EU member state. Thus, the 4th AML Directive itself became national law in all EU member states, as per 01 January 2017.

There are some very important differences between the 3rd and the 4th AML Directive, which seriously increase the burden and the risk of entities concerned. Entities concerned are not only banks, but many other "obliged entities" such as financial institutions, financial consultants, funds and fund management companies, payment providers, administrative service providers, law offices or accountants and auditors.

While the 3rd EU AML Directive provided for a rule-based approach of due diligence and compliance methods, the 4th AML Directive provides for an enhanced risk-based approach. The rule-based approach was providing more or less clear rules, which needed to be complied with.

However, the enhanced risk-based approach provides for the definition of due diligence and compliance rules, measures and tools to be defined by the obliged entities (banks etc., please see explanation in previous paragraph), based on the entities' risk classification of the customer or client.

The 4th AML Directive does not provide clear rules for the risk classification of customers or clients. In its appendixes, it provides some guidelines, though. But: some of those guidelines contradict current rules, directives and laws. The 4th AML Directive suggests that Private Banks are to be considered as high-risk customers. However, being regulated entities themselves, under the strict control of the national regulators of the financial markets, all entities regulated by capital market regulators were deemed to be low-risk customers automatically, until the 4th AML Directive came up.

Now, obliged entities have to judge and determine the level of risk that a client creates themselves, and they must be able to prove the rationale for this decision.

The guidelines for risk classification as per the appendixes of the 4th AML Directive are really very interesting, and raise some question marks at the same time. The guidelines can be found at the end of this article.

Another important change in the 4th AML Directive is the scope crimes covered. While the 3rd AML Directive was referring to money laundering, terrorist financing and organized crime, tax evasion is no added.

An example for changes regarding practical procedures: while the customer or client had previously to be identified based on sufficient documents, the customer or client's documented identity now needs to be verified through third party sources! This needs to be seen in praxis, because even many EU countries do not have such sources in place, or they are not accessible for the obliged entities.

We would like to stress that all the above information is not limited to legislation and procedures in Cyprus and to Cyprus bank accounts, but they are legally binding in all EU member states. Although we know that some countries, including Germany, are quite relaxed with the implementation of the new rules during bank account opening procedures.

The original whole text of the 4th AML Directive can be found here, in all languages of the EU.

After all the above, would you still believe that any law office, consultancy firm, corporate service provider or accountant could "guarantee" the opening of a bank account?


on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC.


The following is a non-exhaustive list of risk variables that obliged entities shall consider when determining to what extent to apply customer due diligence measures in accordance with Article 13(3):

  1. the purpose of an account or relationship;
  2. the level of assets to be deposited by a customer or the size of transactions undertaken;
  3. the regularity or duration of the business relationship.


The following is a non-exhaustive list of factors and types of evidence of potentially lower risk referred to in Article 16:

  1. Customer risk factors:
  1. public companies listed on a stock exchange and subject to disclosure requirements (either by stock exchange rules or through law or enforceable means), which impose requirements to ensure adequate transparency of beneficial ownership;
  2. public administrations or enterprises;
  3. customers that are resident in geographical areas of lower risk as set out in point (3).
  1. Product, service, transaction or delivery channel risk factors:
  1. life insurance policies for which the premium is low;
  2. insurance policies for pension schemes if there is no early surrender option and the policy cannot be used as collateral;
  3. a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by way of deduction from wages, and the scheme rules do not permit the assignment of a member's interest under the scheme;
  4. financial products or services that provide appropriately defined and limited services to certain types of customers, so as to increase access for financial inclusion purposes;
  5. products where the risks of money laundering and terrorist financing are managed by other factors such as purse limits or transparency of ownership (e.g. certain types of electronic money).
  1. Geographical risk factors:
  1. Member States;
  2. third countries having effective AML/CFT systems;
  3. third countries identified by credible sources as having a low level of corruption or other criminal activity;
  4. third countries which, on the basis of credible sources such as mutual evaluations, detailed assessment reports or published follow-up reports, have requirements to combat money laundering and terrorist financing consistent with the revised FATF Recommendations and effectively implement those requirements.


The following is a non-exhaustive list of factors and types of evidence of potentially higher risk referred to in Article 18(3):

  1. Customer risk factors:
  1. the business relationship is conducted in unusual circumstances;
  2. customers that are resident in geographical areas of higher risk as set out in point (3);
  3. legal persons or arrangements that are personal asset-holding vehicles;
  4. companies that have nominee shareholders or shares in bearer form;
  5. businesses that are cash-intensive;
  6. the ownership structure of the company appears unusual or excessively complex given the nature of the company's business.
  1. Product, service, transaction or delivery channel risk factors:
  1. private banking;
  2. products or transactions that might favour anonymity;
  3. non-face-to-face business relationships or transactions, without certain safeguards, such as electronic signatures;
  4. payment received from unknown or un-associated third parties;
  5. new products and new business practices, including new delivery mechanism, and the use of new or developing technologies for both new and pre-existing products:
  1. Geographical risk factors:
  1. without prejudice to Article 9, countries identified by credible sources, such as mutual evaluations, detailed assessment reports or published follow-up reports, as not having effective AML/CFT systems;
  2. countries identified by credible sources as having significant levels of corruption or other criminal activity;
  3. countries subject to sanctions, embargos or similar measures issued by, for example, the Union or the United Nations;
  4. countries providing funding or support for terrorist activities, or that have designated terrorist organisations operating within their country.

Please do not hesitate to contact us for more information and perhaps for our services regarding Cyprus bank account opening or Cyprus company formation.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.


Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.


Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.


A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.


If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.


This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at and we will use commercially reasonable efforts to determine and correct the problem promptly.