Banking prep for global HNW

Banks serving wealthy cross-border clients are asking for more proof before they open accounts or move money, especially when crypto exposure or offshore structures are involved. (law.cornell.edu) In the United States, private banking accounts for non-U.S. persons must be covered by due diligence programs that identify nominal and beneficial owners, check whether any owner is a senior foreign political figure, document the source of funds, and review activity against the account’s stated purpose. (law.cornell.edu) Federal bank exam guidance says private banking relationships often include trusts, offshore entities, funds transfers, lending, and asset management, with a relationship manager acting as the central point of contact. That mix of services raises money-laundering risk case by case rather than by client label alone. (bsaaml.ffiec.gov) For wealthy clients, that means onboarding now often turns on paperwork that shows who ultimately owns a company or trust and where the money came from, not just a passport and proof of address. The Financial Action Task Force updated its guidance on legal arrangements on March 11, 2024, after revising Recommendation 25 in February 2023. (fatf-gafi.org) Crypto adds another layer. The Financial Action Task Force says virtual asset service providers should apply the same preventive measures as banks, including customer due diligence, record-keeping, suspicious transaction reporting, and transmission of originator and beneficiary information on transfers. (fatf-gafi.org) That helps explain why some banks treat crypto-linked wealth as an onboarding problem before it becomes a payments problem. The Financial Action Task Force says many virtual asset service providers are still seen as “risky business” and are denied access to ordinary bank accounts in some markets. (fatf-gafi.org) At the same time, big financial institutions are testing faster ways to settle legitimate transfers once clients clear compliance. On September 29, 2025, Swift said it would build a blockchain-based shared ledger with more than 30 financial institutions, starting with real-time cross-border payments using regulated tokenized value. (businesswire.com) J.P. Morgan is making a similar pitch through Kinexys, which it describes as bank-led blockchain infrastructure for repo settlement, multicurrency payments, fund flows, and on-chain transfers for institutional clients. The point is to compress steps that now sit on separate ledgers, messaging systems, and reconciliation queues. (jpmorgan.com) The Bank for International Settlements put the same idea in plainer institutional terms in its June 24, 2025 annual report: tokenization can combine messaging, reconciliation, and asset transfer on one programmable platform. The bank also said stablecoins fall short of the standards it sees as necessary for the core monetary system. (bis.org) So the near-term play for advisers is less about a sudden new product than about client readiness. The clients who can document ownership, explain source of wealth, and separate regulated settlement tools from speculative crypto activity are the ones banks can onboard fastest. (bsaaml.ffiec.gov)