The Former Official's Pre-Banking Checklist Before Opening an Account Abroad

Applications from former officials succeed or stall on the quality of the file. This is what to have ready before the first meeting.

Opening an account abroad as a former public official takes longer than it does for other customers, because enhanced due diligence is mandatory for foreign politically exposed persons under the FATF standard. No preparation guarantees acceptance. Preparation does determine whether the bank is assessing a complete file or waiting on you.

Identity and name variants

Passport, national identity document and any second nationality document.
A written list of every spelling and transliteration of your name that appears in official records, press coverage or company filings, including French and English variants.
Date and place of birth exactly as they appear on your primary identity document. These are the identifiers that separate you from a same-name match on a sanctions list.

Role history

Each public position held, with start and end dates.
A public source for each: an official gazette, a ministry or parliamentary website, an appointment notice.
A source confirming the end of the appointment. Departure is documented far less often than appointment, and its absence is a recurring cause of stale database records.
Any current position that could itself be treated as a prominent public function, including roles at state-owned enterprises or international organisations.

Source of wealth and source of funds

These are two different questions and banks ask both. Source of wealth is how the overall estate was built. Source of funds is where the specific money entering the account comes from.

Employment and remuneration records for public and private roles.
Company shareholdings, with registry evidence and, where they exist, accounts.
Property records, sale agreements and completion statements.
Inheritance documentation.
Where relevant, a declaration of assets filed with a national authority, if your jurisdiction required one.

Sanctions searches, dated

Run the official searches yourself before the meeting, and record the date:

Search each name variant separately, and search any company you own or direct. Method notes are in how to check if you are on a sanctions list.

Entities connected to you

Companies, foundations and trusts in which you hold an interest or a directorship will be examined alongside you. Have registry extracts, current officer lists and ownership structure ready, including for dormant entities you may have stopped thinking about.

What to expect from the process

Senior management approval, questions that feel intrusive, requests for the same document a second time, and a timeline measured in weeks rather than days are all normal features of enhanced due diligence rather than signs of a problem. Being classified as a PEP is a risk category, not an allegation, as set out in our guide to PEP status.

No document, including a Scrutinex report, can promise that an account will be opened. A report is not an official clearance certificate, and it is not a consumer report under the US Fair Credit Reporting Act.

Next step

Order a PEP and sanctions self-check report if you would rather walk into the meeting with the search already documented.