Bank accounts and the work around them

Open a bank account in Cyprus, through a lawyer For individuals, families and companies, at home and from abroad

I open accounts for clients and I keep them open. Not by knowing someone at a branch, but by preparing the file the bank will actually read, presenting it, and answering what comes back. Where an account has already been refused, frozen or closed, I take that on as well.

You can instruct me for the account alone, or give me a power of attorney and let me deal with the whole of it while you are somewhere else.

Cyprus advocate Individuals, families and companies Non-resident and cross-border files Refused, frozen and closed accounts

The honest starting point

A bank never meets you. It reads a file about you and decides on that. Most refusals are a failure of the file, not of the client.

No lawyer can make a bank say yes. A good deal can be done to make saying no harder.

The decision is taken by someone you will never speak to, from documents you did not choose the order of. That person is asking three questions and only three: who is really behind this money, where did it come from, and what will move through the account once it opens.

Answer those three so that each answer can be checked against paper, and the file goes through. Answer them from memory, in a hurried phone call, in the wrong order, and it joins the pile nobody is in a hurry to clear.

Which is why the work is legal rather than administrative. Documents have to be collected from three countries and reconciled against each other. Dates that do not line up have to be explained before anyone thinks to ask. A history has to be written down once, carefully, so that it survives a second reading by someone looking for the gap.

It is the discipline of preparing a case, with a compliance officer instead of a judge, and no hearing at which to explain yourself afterwards.

So I promise no outcomes. I promise that the file arrives complete, consistent and capable of being defended, and that I am still on it when the questions come back.

This is not a rare problem

Four figures, each with its source, because the numbers that circulate on this subject are routinely quoted to the wrong one.

453.230

accounts closed in the United Kingdom in a single year, against 45.091 in 2016/17

Figures obtained from regulatory returns under freedom of information and reported in the press. The regulator has not published them in this aggregated form.

third

most significant issue reported to the European Banking Authority, as more consumers struggle to open and keep accounts

EBA Consumer Trends Report 2024/25. Payment fraud ranked first, household debt second.

under 2%

the refusal rate Cyprus reports on payment accounts with basic features

European Commission reporting under the Payment Accounts Directive. That product is the only one carrying a legal right, and the only one counted.

154

reports of every kind to the conduct section of the Central Bank of Cyprus across the whole of 2024, thirteen of them about opening or closing a basic account

Central Bank of Cyprus Annual Report 2024.

Two things follow. A refusal today is far more likely to be a decision about a category, a nationality, a sector, a structure, than a judgement about you. And the official Cyprus figures describe a very small corner of the problem: ordinary personal accounts, and every corporate account, are not counted at all.

Who I work with

The documents differ. The questions behind them do not.

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Individuals and non-residents

A salary, a pension, a sale or an inheritance in another country, and a bank that wants the whole history before it opens anything. Often clients who have already been refused somewhere and want to understand why before applying again, which is the cheaper order to do it in.

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Families

Accounts held jointly, held for children, or held alongside a trust or a will. Where money is going to cross a generation or a border, the account and the structure behind it are better designed together than one after the other.

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Companies and their owners

Cyprus and foreign companies, holding structures, special purpose vehicles, funds and family offices. Several currencies, counterparties in several countries, and an ownership chart that has to be legible to a reviewer who will never meet you.

If you are not in Cyprus

Most of this work is done for people who are somewhere else. A power of attorney is how the file keeps moving without you getting on a plane, and the mechanics are worth understanding before you sign one.

A special power, not a general one

An instrument that lists the acts you want covered, opening, operating, instructing transfers, closing, is accepted far more readily than a broad general power. For a Cyprus company a general power is actively unhelpful: the tax residency questionnaire asks whether one has been issued, and a wide power can be read against management and control sitting here.

Signed abroad, made usable here

A power executed outside Cyprus is signed before a local notary and apostilled under the Hague Convention of 1961. From a state outside the Convention it goes through consular legalisation instead, or you sign at a Cyprus consulate. A certified translation is usually needed, and the original travels: copies and scans are not accepted.

No stamp duty since January 2026

Stamp duty on powers of attorney was abolished with effect from 1 January 2026. If someone is still quoting you the old figures, they are working from a note that has not been updated, which tells you something about the rest of the advice.

Where it goes wrong

Banks frequently decline a client’s own instrument and insist on their own mandate forms. Some still want the beneficial owner present, or on video, in spite of a valid power. And the person acting under it is separately subject to identification. A power of attorney does not displace the bank’s own obligations, and planning around that is half the work.

Five distinctions that decide these files

Most of the difficulty in this area comes from terms that sound interchangeable and are not. Each of these has cost somebody an account.

Not every account with an IBAN is a bank account

A deposit with a bank in the European Union is covered by the deposit-guarantee scheme, up to €100.000 per depositor per bank. Other regulated providers can issue you an account with an IBAN and move your money without taking deposits at all, and your balance with them is protected by a different mechanism, in which client money is held apart from the provider’s own. Both arrangements can be entirely sound. They are not the same thing, and you are entitled to know which one you are being offered before you move anything into it.

Source of funds is not source of wealth

Source of funds is where this particular money came from: the sale, the salary, the loan. Source of wealth is how you came to hold assets at all, across a working life. Both are asked, and the second is where files come apart, because it gets answered from memory when it has to be answered from documents.

Beneficial owner is not shareholder

The register records who holds the shares. The question being asked is who ultimately benefits, through however many companies, nominees and trusts stand in between. A chart that answers only the first question reads, to a reviewer, as an attempt to avoid the second.

Frozen is not closed

A freeze leaves the account in existence while you cannot use it, usually while something is being checked or while an order runs. A closure ends the relationship and returns the balance. The first can be argued with. The second is rarely reversed, and the real question becomes where the banking goes next.

De-risking is not a judgement about you

When a provider withdraws from an entire category of client, sector or country, nobody has examined your case and found it wanting. Worth knowing, because the instinct to defend yourself personally is exactly what produces the ill-advised letter.

What a refusal has to tell you

For a payment account with basic features, how a bank communicates a refusal is not left to its discretion. Cypriot law, transposing the European directive, prescribes the timing and the content.

The institution must open the account, or refuse it, without undue delay and no later than ten working days from a complete application. A refusal must be:

  1. given immediately, in writing, and free of charge
  2. specific as to the reasons, unless disclosing them would cut across anti-money-laundering law, national security or public order
  3. accompanied by the procedure for complaining about the refusal
  4. accompanied by notice of your right to take the matter to an alternative dispute resolution body

Who this covers. A consumer lawfully resident in the European Union, whatever the place of residence. The right extends expressly to people with no permanent address, to asylum seekers, and to people without a residence permit whose removal is not in fact possible. It does not depend on income, employment, credit history or bankruptcy. It applies to natural persons acting outside a trade or profession, so companies fall outside it, and a bank may refuse where you already hold such an account elsewhere in Cyprus.

Court of Justice, June 2026

Appearing on a third-country sanctions list, a United States listing for example, is not on its own enough to refuse a payment account with basic features. The bank must carry out an individual assessment of money-laundering risk. An automatic screening hit is not a reason. It is a prompt to look. Case C-81/24 Jenec, judgment of 11 June 2026.

If your account is frozen or closed

Three quite different things go by the same word, and a closure is a fourth thing again. The difference decides everything about what to do next, which is why the first hour of the work goes on establishing which one you are in. It is an hour that saves months.

01

A block by the bank itself

Internal risk scoring, due diligence that could not be completed, or a term of the contract. Nobody has been to court and no authority has ordered anything, which is the good news here and the reason the answer is written rather than judicial.

What I do Written representations to the compliance officer, in the form the institution needs in order to close its own file, with the remediation pack behind them: ownership chart, documented source of wealth, a description of the business that reads consistently with the transactions already on the reviewer’s screen.

02

An administrative postponement

The financial intelligence unit can order a transaction to be held without going to court, a power that Cyprus’s own materials describe as reaching beyond the European and international minimum. You will not usually be told that this is what has happened.

What I do Work out that this is where you are, from the shape of the correspondence rather than from any admission, and then deal with it through the proper channel and on its timetable. Pressing the branch harder achieves nothing here except a note on the file recording that you pressed.

03

An order of the court

Either a civil freezing injunction, granted where there is a good arguable case and a real risk that assets will be moved, or a restraint order in a criminal money-laundering context. Both are normally obtained without you present.

What I do Apply to set aside or vary, to the court that granted it and on its own timetable, not through the branch. Since the civil procedure rules were replaced in 2023, a person whose account is caught by an order made against somebody else can challenge it without first being joined to the main case, which used to be a serious obstacle for account holders who were never the target of anything.

04

A closure, which is none of the three

Outside the basic-account regime, a banking relationship can generally be brought to an end on reasonable notice: long enough for you to make other arrangements. Reasonable notice has never been a right to keep the account, and no court has turned it into one.

What I do Take the complaint up the ladder below where it is worth taking, and in parallel arrange working banking elsewhere, because suppliers and salaries do not wait for a resolution. On a closure the second half of that sentence usually matters more than the first.

The most expensive mistake, in all four, is the telephone call or the quick email that tries to explain the money on the spot. A half-documented explanation given under pressure becomes the version the institution treats as your account of events, and everything filed afterwards is read against it.

The ladder, if the answer is no

There is a sequence, and every rung of it has a deadline attached. Most people never get past the first, usually because nobody told them the rest existed.

01

The institution itself

first, in writing

A written complaint to the bank comes first: the Financial Ombudsman will not take up a matter that has not been put to the institution itself. Make it in writing and keep proof of the date, because the deadlines on the next rung are counted from it.

02

The Financial Ombudsman

within 12 or 18 months

Escalation to the Office of the Financial Commissioner within the statutory windows: twelve months from the complaint to the institution, or eighteen months from when you knew, or ought reasonably to have known, of the act complained of. The threshold runs to €250.000 and the fee is €20. The decision binds only if both sides accept it within two months, which is worth knowing before you rely on it.

03

The Central Bank

supervision, not a remedy

An alleged infringement report to the conduct section of the Central Bank of Cyprus, which is the competent authority. Worth understanding before you file: the Central Bank does not mediate between you and the institution, and it does not tell you what came of your report.

04

The court

the last rung

Proceedings: to challenge a refusal, to discharge or vary a freezing order, or to sue. Slow, expensive, and occasionally the only thing that moves anything at all. This is the part of the work I was trained for.

Almost nobody climbs it. Not because the problem is small, but because the sequence is not obvious from the outside and the deadlines run whether or not you know they are running.

Or start with a conversation

Tell me the short version

Who needs the account, in which country, and whether anything has already been refused, frozen or closed. That is usually enough for me to say what the realistic route is and what it will take. If the real question turns out to be who should own the money rather than where it sits, say so and we start there instead.