Japan Corporate Bank Accounts for Foreign Owners: Checks and Documents

A corporate bank account for a company run by a foreign owner is opened only after the bank has completed the checks required by the Act on Prevention of Transfer of Criminal Proceeds and its own internal review. The review looks at whether the company exists, what it does and why it needs the account, who its beneficial owners are, and the identity of its representative. What matters most is whether you can demonstrate the reality of the business in concrete terms, with documents.

Why banks review corporate accounts so carefully

Under the Act on Prevention of Transfer of Criminal Proceeds (犯罪収益移転防止法, “APTCP”), banks are required to carry out verification at the time of transaction (取引時確認) when an account is opened. They also apply risk-based checks in line with the Financial Services Agency’s guidelines on anti-money laundering and countering the financing of terrorism.

Corporate accounts can be misused for fraud or illicit transfers. As a result, newly incorporated companies and companies with frequent cross-border remittances tend to face more checks. Screening criteria and required documents differ from bank to bank.

What banks verify (verification at the time of transaction)

Under the APTCP, the following items are verified when a bank deals with a corporation.

How beneficial ownership is determined

For a kabushiki kaisha (株式会社, KK), the beneficial owner (実質的支配者) is, in principle, any individual who directly or indirectly holds more than 25% of the voting rights. If there is no such individual, the individual who represents the company and executes its business is treated as the beneficial owner.

Where shares are held through a foreign parent company, you must trace ownership up to the individual who ultimately controls the company and declare that person. A false declaration may be subject to penalties.

When stricter checks apply

Transactions with people who hold important public positions in a foreign government or similar body, with their family members, or with corporations whose beneficial owner is such a person, are subject to stricter verification. You may be asked for additional documents or for information on assets and income.

What the review focuses on for foreign-run companies

Can you show that the business is real?

Banks place weight on whether the business can be explained in concrete terms. Prepare your website, company profile and business plan, as well as any contracts, quotations and purchase orders with business partners. For businesses that require a licence or permit, you may also be asked for a copy of it.

Does the office actually exist?

The bank checks whether business is actually conducted at the registered head office address. Prepare the office lease agreement. Where the type of office makes it hard to confirm actual operations, the review may be more cautious.

Where representatives and officers live, and their status of residence

Since 16 March 2015, a KK can be registered even if all of its representative directors live outside Japan. However, specialists point out that account opening is often more difficult in such cases. If a representative or officer lives in Japan, the bank will check their status of residence (在留資格) and period of stay on their residence card (在留カード).

Amount of capital and source of funds

Be ready to explain the amount of capital and where the funds came from. Records of remittances from overseas and the history of the investor’s bank balance help. The source of funds is also a key point in the Business Manager visa (経営・管理ビザ) review. For details, see the revised approval criteria for the Business Manager visa.

Planned cross-border remittances

If you plan to send or receive funds with an overseas parent company or business partners, set out the countries involved, approximate amounts and frequency. The bank looks at whether the purpose and scale of the transactions are consistent with the business.

Resident classification shortly after arrival

Under the Foreign Exchange and Foreign Trade Act (外為法, FEFTA), foreign nationals are, in principle, treated as non-residents until six months have passed since their entry into Japan (there are exceptions). This classification can affect matters such as opening a personal account for the representative.

In February 2023 the Financial Services Agency asked financial institutions to allow foreign entrepreneurs using programmes such as the Foreign Entrepreneur Promotion Programme (外国人起業活動促進事業) to open resident accounts, or equivalent accounts, on the basis of confirmation documents, even within six months of entry.

The account-opening process and documents to prepare

1. Complete the company’s incorporation registration
2. Choose a financial institution and confirm its required documents and procedures
3. Submit the application form and documents
4. An interview or an office check may be carried out
5. The account is opened after the review

Financial institutions include city banks, regional banks, shinkin banks (credit associations) and online-only banks. Required documents and the application method (in branch or online) vary by institution and by application route. Approaching an institution near your head office, or one used by your business partners or tax accountant, is one option.

Some institutions indicate that it can take around two weeks from application to opening. Because the timing depends on the institution and the review, plan backwards from the date you need to start trading.

Key documents

• Certificate of registered matters and the company’s seal certificate (issued within a set period; the period varies by institution)
• Articles of incorporation
• Identity documents for the representative and the person visiting the bank (residence card, passport, etc.)
• Beneficial owner declaration and shareholder register
• Materials describing the business (website, company profile, business plan, contracts, etc.)
• Office lease agreement
• For businesses that require a licence or permit, the relevant certificate

Using the beneficial owner list system

Since 31 January 2022, the Legal Affairs Bureaus (法務局) have operated a beneficial owner list system (実質的支配者リスト制度). A KK (including a special limited liability company, 特例有限会社) can submit a list setting out its beneficial owner information to the registry office with jurisdiction over its head office and receive a copy bearing a certification statement. There is no fee, and requests can also be made by post.

The list records the beneficial owners as determined by voting rights (an individual holding more than 50% of the voting rights or, if there is no such individual, individuals holding more than 25%, and so on). Even if you submit the copy, some financial institutions may also ask for a declaration form, the shareholder register or other documents.

It has also been reported that in October 2026 the Cabinet approved a new bill that would require corporations other than listed companies to file beneficial owner information. As the timing of enactment and entry into force has not been decided, check the Ministry of Justice’s guidance for the latest position.

What to prepare before incorporation

• Account for paying in capital: before incorporation, use a promoter’s personal account. Accounts at overseas branches of Japanese banks or at Japanese branches of foreign banks can also be used, but accounts at overseas branches of foreign banks cannot.
• Head office address: secure an office where you can actually conduct business.
• Business purposes: make sure the purposes in the articles of incorporation match the business you will actually carry on.
• Board composition: consider whether to appoint an officer who lives in Japan.
• Materials explaining the business: get your website and company profile ready early.

The incorporation steps are explained in how foreign nationals and foreign companies set up a company in Japan. If a foreign parent company is investing, also check prior notification and post-investment reports under FEFTA.

Checks continue after the account is opened

Even after the account is opened, banks periodically review customer information according to risk. You may be asked to submit documents or answer questions about your registered details, business, beneficial owners and the purpose of transactions.

If you move your head office, change officers or shareholders, or change your business, notify the bank. If you leave requests unanswered or changes unreported, transactions may be restricted. Add the bank notification to your checklist whenever you file a registration change.

If your application is declined

The review may conclude that an account cannot be opened. If that happens, check whether anything was missing from your explanation of the business or your supporting materials. Reapplying once you have a trading record and signed contracts is also an option. Because each institution reviews applications from a different angle, approaching another institution is another route.

Summary

For a corporate account for a foreign-run company, banks check not only the APTCP items verified at the time of transaction but also the reality of the business, the existence of the office, the source of funds and where the representative lives. Nothing can guarantee that an account will be opened, but the basic step is to be ready to explain your business concretely, with documents.

Working with partner judicial scriveners (司法書士) and certified tax accountants (税理士), TIMOA helps you design your incorporation with account opening in mind, prepare materials describing the business and the beneficial owner list, and get ready to apply to financial institutions. See also our Japan Entry & Company Setup services.