Explain what the holding company actually holds
A holding company should identify each present or intended asset: subsidiaries, shares, real estate, intellectual property, bonds or other investments. State whether the entity is a passive owner, an active group headquarters, a financing vehicle or an investment manager. These roles have different risks and documentation.
A newly incorporated vehicle with no assets can still present an acquisition plan, but the target, funding and timeline should be credible. Vague statements about “future investments” without capital or identifiable opportunities provide little commercial context.
If the company will invest third-party money or provide regulated financial services, ordinary holding-company banking may not be appropriate. Licensing and bank appetite must be reviewed before onboarding.
Make the ownership and control chain transparent
Provide a diagram from the applicant through every shareholder to each natural-person UBO, including percentages, voting rights and jurisdictions. Add registry and constitutional documents for every corporate layer and explain any trust, nominee, foundation or partnership.
Identify directors, investment decision-makers, account signatories and persons with veto or control rights. A complex structure is not automatically prohibited, but every layer should have a lawful and commercial reason.
Changes planned after opening—new investors, transfers, options or reorganisations—should be disclosed when known. The bank may require renewed KYC before ownership changes are implemented.
Evidence subsidiaries and investment assets
For subsidiary holdings, provide registry extracts, financial statements, business descriptions and valuations or acquisition documents. For real estate, add title records, purchase agreements, valuation and rental information. For securities, provide broker or custodian statements and investment agreements.
The account purpose should follow the assets. A holding entity may receive dividends, sale proceeds or shareholder funding and pay acquisition costs, professional fees, taxes and group financing. It should not receive unrelated operating revenue without explanation.
If assets are not yet acquired, distinguish committed transactions from general targets. Draft purchase agreements, term sheets and professional reports are more useful than promotional projections.
Trace investment capital and UBO source of wealth
Holding structures often involve substantial capital, so banks may examine the beneficial owners’ wealth in depth. Explain whether funds arise from salary, business profits, dividends, a company sale, property, inheritance or investments and provide a chronological evidence trail.
The immediate source account should belong to the true contributor or a documented group company. Moving money through several accounts does not improve evidence and may create questions. Shareholder loans and capital contributions should match corporate approvals and agreements.
Crypto-derived wealth, cash accumulation and assets from high-risk jurisdictions require early disclosure. Evidence standards and bank appetite vary, and no general acceptance promise is possible.
Dividends, loans and intercompany payments
Forecast expected dividends by subsidiary, acquisition payments, shareholder contributions, loans, professional fees and distributions. Identify countries, currencies, approximate amounts and frequency. Large but infrequent transactions should be explained even when annual transaction count is low.
Intercompany loans require agreements, interest terms, repayment schedule and a clear commercial purpose. Dividends should be supported by financial statements and resolutions. Management fees or royalties require real services or rights, not labels added only to justify transfers.
The bank may request documents before each material payment. Prepare asset and corporate records in advance and retain evidence showing how the transaction affects the group.
Management, tax residence and economic substance
State where board decisions are made, where directors live and how investment decisions are documented. A Georgian registered address alone does not establish management or tax residence. Obtain appropriate tax advice for the company and its owners.
Board minutes, investment policies, service providers, office arrangements and accounting records can demonstrate governance. If directors act for several entities, explain how conflicts and authority are managed.
Opening a bank account does not determine treaty eligibility, tax residence or beneficial ownership for tax purposes. CRS and FATCA self-certification must be accurate and updated when circumstances change.
Holding-company KYC documents
The file normally includes applicant registry and charter documents, full ownership chart, directors and signatories, UBO personal KYC, source-of-wealth evidence, group chart, asset records, financial statements and transaction projections.
Add acquisition contracts, shareholder agreements, loan agreements, dividend resolutions, broker statements, property documents or IP records according to the asset class. Foreign documents may need certification and Georgian translation.
Banks can request information about underlying subsidiaries and counterparties even when they are not direct account holders. Prepare a complete group picture rather than limiting disclosure to the top entity.
Local and remote opening for holding structures
A representative can attend in Tbilisi after a detailed pre-assessment. Simple structures may fall within our standard corporate scope, while layered ownership, trusts, regulated assets or high-value funding usually require a separate quotation and longer preparation.
Remote opening may be considered but is more document-intensive. A bank-specific PoA, certified company records, originals, video KYC and personal evidence from UBOs can be required. Confirm the route before notarising documents.
The bank’s approval of the account does not guarantee acceptance of every future acquisition, dividend, loan or investment payment. Ongoing transparency remains essential.