A GMC company needs a bank account to pay staff, hold capital and, for financial services applicants, to satisfy a precondition of the GFSO In-Principle Approval. The bank that opens it is a Licensed Firm with statutory due diligence duties, so the quality of the file you hand over decides how quickly the account is opened. Basnet Law Pte. Ltd. is the first law firm incorporated in GMC. We advise on the legal and beneficial-ownership information a bank will ask for, in step with incorporation and licensing. This page explains what the bank is required to check and how we advise on the file.
Our legal advisory
- Advise on the corporate file a bank expects: certificate of incorporation, constitution, registers of directors and members, and the resolutions authorising the account and signatories.
- Advise on the beneficial ownership chart and supporting evidence, using the "registrable controller" concepts in the LLP Act 2026 as the reference model.
- Draft source-of-funds and source-of-wealth narratives for founders, with documentary support.
- For GFSO applicants, advise on sequencing the account within the IPA conditions so the capital injection, office and personnel milestones line up.
- Advise on USD as the currency of account, since tax computations under the Income Tax Act 2025 must be denominated in US dollars unless a different functional currency applies.
- Advise on payroll banking so salary can be paid into an account with a bank licensed in GMC, as the Employment Act 2025 requires.
How GMC bank account opening works, in plain terms
GFSO's published licensing pathway makes the account a gating item. After the In-Principle Approval (IPA), the applicant must satisfy preconditions that include "incorporating a company in GMC via the Gelephu Corporate Registration Office (GCRO)", "opening a bank account in GMC", "injecting the required regulatory capital", obtaining office space and hiring key personnel. Only then does the Financial Services Licence issue, and "the IPA does not permit you to conduct your business in GMC yet".
Banks in GMC are themselves Licensed Firms. Accepting Deposits is a regulated activity, and every Relevant Person must "conduct customer due diligence as specified in the Rules" and keep records of it. The Regulator is the designated Supervisory Authority for money laundering in GMC, and "money laundering" includes terrorist financing, financing of unlawful organisations and sanctions non-compliance. The due diligence a bank runs on your company is therefore a statutory obligation, and the file should be built to meet it.
Two further points assist with planning. Under the Companies Act 2025 a foreign company is not regarded as carrying on business in GMC merely because it "maintains any bank account" here, so a parent can hold a GMC account without registering as a foreign company. And the bank will check the GCRO registers, so director and secretary appointments should be complete before the application is lodged.
We do not name banks or state their individual requirements. Each bank sets its own onboarding standards within the AML and Sanctions Rulebook, and we confirm current requirements at engagement.
Who this is for
- Newly incorporated GMC subsidiaries of international groups that need an operating account before hiring.
- GFSO applicants at the IPA stage, including virtual asset firms, who must show an account in GMC before the licence issues.
- Founders relocating under a work pass who need a compliant payroll account.
- Fund and holding structures that need USD accounts aligned with the Income Tax Act's currency rules.
How a legal advisory engagement runs
- Readiness review: we review the corporate documents for consistency and advise on any gaps before the bank sees them.
- File build: we advise on the ownership chart, source-of-funds narrative, business description and draft the signatory resolutions.
- Bank queries: we advise on the legal issues raised in the bank's queries.
- GFSO alignment: for licence applicants, we advise on the account status GFSO expects as an IPA condition.
- Operation: we advise on mandates, signatory changes and record-keeping once the account is live.
Frequently asked questions
Do I need a GMC bank account before I get a GFSO licence?
Yes. GFSO lists opening a bank account in GMC among the IPA preconditions that must be met before the Financial Services Licence is issued. We schedule the account so it is not the item holding up the licence.
Why does the bank ask for so much on beneficial ownership?
Because the bank is a Licensed Firm bound by the Financial Services Act 2025 to carry out customer due diligence under the AML Rules. A complete ownership chart shortens the process, and we advise on the standard the Rules require.
Must the account be in US dollars?
Not necessarily, but tax computations are denominated in US dollars under the Income Tax Act 2025, with a functional-currency exception. All "$" references in GMC statutes mean US dollars. We advise on the currency before the account is set up.
Can my overseas parent open a GMC account without registering here?
Maintaining a bank account alone does not amount to carrying on business in GMC under the Companies Act 2025. Other activities may still require registration as a foreign company, and we check the parent's activities against that line.
How long does account opening take?
The statutes and GFSO's published material do not fix a timeframe. It depends on the bank's due diligence and the completeness of the file, which is why we advise on the file before it goes to the bank.
Contact
Basnet Law Pte. Ltd. is the first law firm incorporated in the Gelephu Mindfulness City.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
