Most traditional banks now decline or heavily restrict clients they once onboarded directly—such as foreign companies with foreign directors, overseas companies, money services businesses, and similar profiles. This is why specialized program managers have become the common route. These firms have already completed the lengthy compliance process with multiple MSB-friendly banks. In practice, you complete the program manager’s due diligence and sign an agreement with them; they then present you to one of their partner banks. The account is still opened at the regulated bank (typically under an FBO structure), and many of these arrangements can provide a named account in your company’s name. The program manager remains the ongoing intermediary that maintains the banking relationship and compliance bridge.
Being comfortable with this model matters because the program manager is the entity the bank trusts and works with day-to-day. If that intermediary relationship is not acceptable as your main banking solution, true direct options still exist with a smaller number of institutions, but they are fewer, the process is longer, and approval is less predictable than it used to be.