Bank Account

Rule Watch: Dated Log of US Banking, Payment and Filing Rule Changes for Non-US Founders

October 16, 2026 · By the Bizstartz Team

Maintained by Rahul Shrestha, Co-Founder, Bizstartz. First published 16 October 2026.

Disclosure: Bizstartz earns referral or partner fees from providers named in this log. Those fees play no part in the data: every entry comes only from each provider’s own published rules, linked here so anyone can check it.

Banks, payment platforms and regulators change the rules for non-US founders quietly, on help pages most people never re-read. Rule Watch is our dated log of those changes, each linked to the page it came from, so you can see what changed, when, and who it affects.

How this log works

  • Our monitor re-reads the Mercury, Relay, Stripe, FinCEN, IRS and Delaware pages below twice a day and flags any change for a person to check.
  • Wise blocks automated reads, so we check Wise by hand at least every quarter.
  • “Date” is when the change took effect or the provider updated its page. Every entry was recorded or re-confirmed on the date shown in the changelog at the bottom.
  • We only log what a provider or regulator publishes. We never log rumours or single customer stories.

Change log

Date Rule What changed Source
15 Oct 2026 Mercury Mercury updated its prohibited countries page. As read on 16 October 2026 it lists 48 prohibited countries plus 4 sanctioned countries and regions, based on where the founder lives. The list includes Nepal, Nigeria, Pakistan, the Philippines, Bangladesh, Indonesia, Vietnam, Croatia, Latvia and Ukraine. India, the UAE, Sri Lanka, Malaysia, Brazil and Mexico are not on it. We did not hold the previous version, so this is our baseline. Mercury
14 Aug 2026 FinCEN (BOI) FinCEN’s final rule took effect: all entities created in the United States, and their beneficial owners, are exempt from beneficial ownership (BOI) reporting. This covers US LLCs owned by non-US residents. FinCEN
11 Aug 2026 Relay Relay updated its prohibited countries page: 31 countries, applied to any owner with citizenship or residency there, including beneficial owners. Nigeria, Pakistan, Ethiopia, Cambodia and Ukraine are on it. Relay
19 Jun 2026 FATF grey list Bosnia and Herzegovina and Iraq were added to the FATF list of jurisdictions under increased monitoring. Algeria and Namibia were removed. Banks often apply extra checks to people linked to listed countries. FATF
13 Feb 2026 FATF grey list Kuwait and Papua New Guinea were added to the list of jurisdictions under increased monitoring. No country was removed. FATF
24 Oct 2025 FATF grey list Nigeria, South Africa, Mozambique and Burkina Faso were removed from the list of jurisdictions under increased monitoring. FATF lists
21 Feb 2025 FATF grey list The Philippines was removed from the list of jurisdictions under increased monitoring. Laos and Nepal were added. FATF lists

Current rules we monitor

Confirmed against each source on 16 October 2026.

Rule What it says today Source
Mercury Founders who live in 48 prohibited countries, plus sanctioned countries and regions, cannot open an account. Based on residence, not citizenship. Mercury
Relay 31 prohibited countries by citizenship or residency of any owner. The opening guide also lists a Social Security Number for each beneficial owner. Relay list, Relay guide
Stripe Eligibility follows the country where the business is registered. India and Indonesia are in preview. Côte d’Ivoire, Ghana, Kenya, Nigeria and South Africa are on the extended network. Pakistan, the Philippines, Vietnam, Türkiye and Bangladesh are not listed. Stripe
Stripe India Stripe is available in India by invite only. It is not banned. Stripe docs
Wise A Wise Business account cannot get USD account details if the business has an address in Bangladesh, Cameroon, China, Nigeria or Pakistan, or if the owner’s personal profile has an address in those countries or Ukraine. The trading address must be a real physical place; registered agent, virtual office and mail forwarding addresses are not accepted. Holding money: India only when travelling overseas; Malaysia personal accounts only; Mexico, Nepal, Nigeria, Pakistan and the UAE not listed. USD details, address, holding money
FinCEN BOI US created entities and their beneficial owners are exempt from BOI reporting. FinCEN
Delaware LLCs pay a $400 yearly tax on or before June 1 and do not file an annual franchise tax report. Delaware
IRS EIN An applicant with no legal residence, principal place of business or principal office in the US cannot use the online EIN application. By fax the EIN generally arrives within 4 business days, by mail in about 4 weeks. International applicants can apply by phone on 267-941-1099. IRS SS-4 instructions
IRS Form 5472 A foreign-owned single-member LLC files a pro forma Form 1120 with Form 5472. Contributions to and distributions from the LLC are reportable. The penalty for not filing is $25,000. IRS 5472 instructions

Coming up

  • FATF plenary, 26 to 30 October 2026: the next update to the grey and black lists. We will log the outcome here.
  • Quarterly re-check of the US Fintech Lockout Index: January 2027.

Use this data

For a country-by-country view, see the US Fintech Lockout Index, which scores 197 countries on Mercury, Relay, Wise and Stripe rules, and our banking and payments guide by country. Journalists and researchers may cite Rule Watch with a link to this page. To report a change we missed: rahul@bizstartz.com.

If a rule change affects your company, book a free consultation and we will tell you what it means for you.

Changelog

16 October 2026: first edition. All entries above recorded on this date.


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