Fund managers, family offices and corporate service providers managing fund structures, private wealth structures, or corporate holding structures have been facing bank account closures by their banks globally, with often limited notice time given to find an alternative. Possible reasons for banks stopping servicing these clients include:
- Changes in the strategic direction of a bank towards having only full-service clients (for example, banks requiring lending or depository services to be consumed by clients)
- Changes in bank risk appetite (for example, no longer accepting clients with more than 3 layered entities, no appetite for certain fund jurisdictions); or
- Banks matching the size of the client portfolio to their fixed Anti Money Laundering (AML) and Know Your Customer (KYC) client re-assessment resources
Finding an alternative provider for bank accounts can be challenging due to long onboarding times with traditional banks (3-6 months is not uncommon), combined with the limited appetite for banks to service clients that only require transaction banking services.
An extended period of uncertainty about whether and when alternative bank accounts can be opened can materially impact the daily operations of these entities. For group structures with a large number of entities, the large administrative burden of migrating to a new transactional account provider can add an additional layer of complexity.
Ebury's blueprint for efficient group structure onboarding
When migrating group structures across from banks, Ebury follows a client migration blueprint that fulfils three key objectives.
Provide clarity fast
Reduce the time a client remains uncertain whether the group entities fall within the risk appetite and, therefore, are likely to be onboarded as a client.
Limit the administrative burden
Use communal elements within the group structure where possible in performing the AML/KYC assessment and reduce time around signing T&Cs at scale.
Transparent communication
Schedule regular team calls between the client & Ebury team to limit back and forth and provide clarity on the migration progress.
Ebury’s 5-step blueprint migration process
Ebury follows a 5-step blueprint migration process to ensure the process is done efficiently.
Step 1 | Initial request for information
An initial request for information is completed by the client, covering the group structure chart, an overview of the group ownership, and of the business activities. Ebury’s AML/KYC team then performs an initial assessment based on the information provided to inform the most effective way to set up the migration.
Step 2 | Setup Ebury KYC/AML onboarding team
Assign a Ebury KYC/AML onboarding team to cover the migration from start to end. The resourcing of the team is dependent on the number of entities in the group and the estimated complexity of the onboarding.
Step 3 | Migration kickoff call
Kickoff call with Ebury relationship manager, Ebury KYC/AML onboarding team, and the client representatives in order to discuss:
- further request for information and documentation
- potential areas for further deep-dive identified based on the initial request for information
- most logical grouping and phasing of onboarding the several substructures
- approach to reduce administrative burden (for example, methods to sign a large amount of agreement at once)
Step 4 | Project calls and phased onboarding per substructure
Substructures defined in Step 3 (logical sub-groupings of total group structure) are migrated per substructure, often starting with the top holding. During the migration, regular team calls with the client are set up in order to limit the email back and forth and to provide transparency on the progress of the migration.
Step 5 | Post Migration
Post-migration, Ebury provides ongoing support to clients in operating the payment platform, payment execution, FX operations, and cash management.
Bottom line
Effectively migrating group structures across from banks requires a combination of project planning, clear communication, a client-centric approach, and a dedicated project team. Ebury has the right experience and tools to enable migrations at scale.
Let’s start a conversation
Get in touch with our experts to discuss the needs of your fund and how Ebury can help. You can also visit our Institutions page to learn more about our solutions.
Disclaimer
Risk warning & legal notice: For informational purposes only; not financial, legal, or tax advice. Certain products, including derivative products, involve risk and may result in losses. Products and services described may not be available in all jurisdictions or from all Ebury entities; availability depends on the entity’s regulatory permissions and applicable local laws. Learn more about Ebury’s legal entities.
