bank wants to know if we are going to transfer money abroad, how should I fill that in
Expected transaction flow is a customer due diligence question, not a forecast
The bank does not want an exact prediction here, but a profile: does your business structurally receive or send money abroad, and if so, to which countries or regions, in what order of magnitude and with which counterparties. This falls under the customer due diligence that banks must conduct pursuant to the Anti-Money Laundering and Counter-Terrorist Financing Act. The bank must be able to assess the risk of the relationship, and foreign money flows — especially to countries outside the EU — weigh more heavily in this assessment than domestic ones.
Enter what is factual: which countries appear in your purchasing or sales, and whether that is structural or incidental. If you do not have a concrete figure, a range based on the figures from previous years is often sufficient; the question is rarely intended as an exact forecast. Align this with at which banks the business maintains accounts, because a bank that already knows your account structure often poses the transaction question more specifically and expects an answer that matches accordingly. If the transaction arises from a chain with intermediaries or own foreign establishments, this also affects the question of who are the ultimate beneficial owners of the company, because the bank compares both answers side by side.
Where this comes from: the customer due diligence in the Anti-Money Laundering and Counter-Terrorist Financing Act
The obligation for this type of question does not follow from a format created by the bank itself, but from the Anti-Money Laundering and Counter-Terrorist Financing Act, which requires banks to investigate and monitor the nature and purpose of the business relationship — including the expected transaction flow, especially for cross-border payment transfers. The basic information about your business that the bank already has, such as place of establishment and directors, comes from the Business Register pursuant to the Business Register Act 2007; the transaction question supplements that picture with information that is not in any register and which is therefore obtained directly from you.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- Act on the prevention of money laundering and the financing of terrorism — client due diligence
- Directive (EU) 2022/2464 (CSRD)
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.