AmericasUnited StatesLicensed-entity research

KeyBank National Association

KeyBank National Association (a US national bank; not replaced as the subject bank by its holding company KeyCorp or the KeyBank brand alone)

KeyBank National Association can be verified through the FDIC’s current institution API records as an active, FDIC-insured depository institution, with the OCC as its primary regulator. KeyBank’s publicly available personal checking account information requires applicants to choose an online or branch channel based on their place of residence and identity. Acceptance of foreign legal entities and the conditions for opening their accounts have not been publicly confirmed.

Regulator: Office of the Comptroller of the Currency (OCC; the FDIC is the deposit insurance agency)
Check date: 2026-10-26
Verify status: Some information is pending confirmation: KeyBank National Association’s legal entity, its currently active FDIC-insured depository institution record, OCC primary regulator, and public personal/business product conditions have been verified; the bank has not publicly confirmed full eligibility for overseas nonresidents, whether foreign legal entities and their owners are accepted, business checking-specific documents, foreign tax self-certification forms, or any remote witnessing arrangements.

Research scope and official resources

Topic number:americas-keybank-na

selection.json lists this among selected large U.S. banking groups using the Tier 1 capital measure in The Banker Top 1000 World Banks 2026, and notes that this record is a candidate mapping from a group to a banking entity. This selection context is not an individual ranking, real-time top 100 ranking, licensing conclusion, or evidence of acceptance of account applications.

Bank’s official website

Personal Eligibility and Documents

KeyBank’s personal checking FAQ states that online applicants must be at least 18 years old, be US citizens, reside in Alaska, Colorado, Connecticut, Idaho, Indiana, Maine, Massachusetts, Michigan, New York, Ohio, Oregon, Pennsylvania, Utah, Vermont or Washington, and apply for a personal account. The FAQ says that people who do not meet these online conditions may contact a local branch. KeyBank’s current Key Smart Checking page separately and expressly states that “non-residents” must open an account at a branch, but does not define whether this term refers specifically to non-US residents or non-US citizens, nor confirm whether applicants with foreign addresses can be approved. The US address and SSN/TIN wording on that page is part of that page’s promotional eligibility conditions and should not be expanded into a general policy for all deposit accounts. All applications remain subject to geographic restrictions and bank approval.

Personal information publicly disclosed or identified

KeyBank’s personal checking FAQ states that applicants must provide an SSN or Taxpayer Identification Number and one valid primary form of identification. The bank’s branch-account-opening page gives examples including a driver’s licence, valid passport or government-issued ID bearing a photograph and signature.
If the address on the identity document differs from the application address, KeyBank’s branch account-opening page requires separate proof of address, such as a utility bill. The page also says it will ask for a telephone number, date of birth and email address.
The initial deposit for account opening varies by account product. The Key Smart Checking product page states that the minimum initial deposit for this product is 10 dollars. This amount applies only to that product and should be checked against the latest disclosure at the time of opening.
The Key Smart Checking page states that non-residents must open an account at a KeyBank branch. The US address and valid SSN/TIN listed on that page are conditions for its promotional eligibility. Public materials do not confirm whether a foreign address can be used to open a standard account.

Company eligibility and documents

KeyBank publicly offers small business deposit products. Its Business Savings FAQ expressly requires applicants for a small business savings account to apply in person at a KeyBank branch. However, the public materials reviewed do not confirm whether foreign-incorporated companies, beneficial owners without a US residence or foreign companies can open accounts. Nor is there sufficient information to establish that the documents, channels and conditions are identical for business checking and business savings accounts. Do not infer that foreign companies are accepted; the bank must confirm in writing for the specific legal entity, business and account product.

Company information publicly disclosed or identified

The KeyBank Business Savings FAQ expressly lists the application documents for a small business savings account: the applicant’s SSN or the business’s EIN; business formation/organisation documents, such as a DBA, LLC formation certificate or certificate of incorporation; two valid forms of identification, either two primary IDs or one primary ID plus one secondary document (examples include a credit card, utility bill, lease or other non-government ID); and the minimum opening deposit required for this savings product. The page also states that applications must be made in person at a KeyBank branch.
The bank's explicit checklist above applies only to its small business savings account; it cannot be treated directly as the complete policy for a business checking account or an application by a foreign company. KeyBank's business checking product page lists small business checking products, but the official checking FAQ text accessible for this review did not provide a checklist sufficient to confirm documentation or eligibility for foreign legal entities.
General preparation suggestion (not a published KeyBank business checking policy): You may prepare company incorporation and existence documents, EIN (if obtained), an ownership structure chart, information on direct and ultimate beneficial owners and controlling persons, an account-opening authorization/board resolution, identification documents for signatories and relevant individuals, a U.S. business or contact address, and an explanation of the expected account purpose and source of funds. The bank may request additional documents; the specific forms, certification method, translation/notarization requirements, and whether foreign documents are accepted remain subject to written confirmation.

Address, tax, and remote / witnessed procedures

Address and tax

For personal applications, KeyBank’s public FAQ requires an SSN or TIN; its branch account-opening page requires proof of address when the address on the identification document does not match. The current Key Smart Checking page lists a US address and valid SSN/TIN as eligibility conditions for that promotion; this does not establish that all products generally accept or require a particular type of address. The IRS explains that SSNs are issued by the SSA, EINs identify businesses, and ITINs are for federal tax purposes for individuals who qualify and cannot obtain an SSN; obtaining an ITIN does not mean that bank account-opening requirements are met. For US tax-status documentation, the IRS explains that Form W-9 is used to request a TIN from US persons (including US tax residents). The public account-opening materials do not confirm which tax self-certification KeyBank requires from non-US tax residents, whether it requires Form W-8 or a foreign tax number. The business savings page accepts an SSN or EIN, but eligibility of foreign companies and their US tax-reporting obligations must be checked separately based on the facts.

Remote / witnessing

Personal online account opening is available only to applicants meeting the age, U.S. citizenship, state-of-residence, and personal-account requirements listed in the KeyBank FAQ. KeyBank’s current page requires non-residents to apply at a branch. Business small-business savings accounts must be opened in person at a KeyBank branch. No public commitment by the bank to global video account opening, opening accounts at overseas branches, or accepting third-party witnesses was found; do not interpret online product pages as offering a global remote account-opening service.

Public process reference

First determine whether the customer is an individual or a business and identify the specific account product. Confirm with KeyBank whether the applicant’s U.S. residency/tax status and state of residence or place of incorporation fall within the product’s acceptance criteria.
Individual checking applicants should use the FAQ to confirm whether they qualify to apply online; non-residents must apply at a branch according to the KeyBank page. Those who do not meet the online criteria may contact a local branch to confirm further; this does not imply approval.
For personal applications, prepare an SSN or TIN, valid primary identification, proof of address if required, and the product’s minimum initial deposit in accordance with the bank’s checklist. An account can be opened only after bank approval.
Applications for small-business savings accounts must be made in person at a KeyBank branch. Prepare an SSN or EIN, formation documents, two valid forms of identification and the applicable product’s minimum deposit, as specified in the product FAQ.
Specific steps for business checking accounts for foreign-registered companies, whether preliminary online screening is available, foreign document formats, accepted locations, account tax forms, and additional-document requirements have not been publicly confirmed. Verify these in writing with KeyBank; public information does not specify processing times for such applications.

Compliance topics, details, and sources

U.S. AML/BSA, Identity Verification, and Ongoing Customer Due Diligence

KeyBank’s personal account-opening information lists a tax number, primary identification and, where necessary, proof of address. The US FinCEN CDD rule applies to covered federally regulated banks and requires risk-based customer due diligence, understanding the nature and purpose of the relationship, ongoing monitoring and maintaining information on a risk basis. This describes the US regulatory baseline; it does not mean KeyBank has disclosed every internal screening measure or additional document required from each customer.

Source:KeyBank — Checking FAQs ；KeyBank — What to Bring to Open an Account in a Branch ；FinCEN — CDD Rule FAQs

Corporate Beneficial Owners, Controllers and Source of Funds

The FinCEN CDD Rule generally covers individuals who directly or indirectly hold 25% or more of the ownership interests in a legal entity customer, as well as one individual with significant managerial or control responsibility; identity verification follows a risk-based approach. An FAQ updated by FinCEN in 2026 explains that financial institutions may decide whether to use the account-opening relief, under which they identify and verify beneficial owners at the establishment of the relationship, when the reliability of information is questioned, or when required by ongoing risk-based due diligence; they may also continue collecting information at every account opening. The specific scope of source-of-funds or source-of-wealth documents is determined by the bank’s risk assessment; this information does not present general preparation advice as KeyBank’s published policy.

Source:FinCEN — CDD Rule FAQs

U.S. Tax Identification Number, Tax Status, FATCA, and CRS

The IRS distinguishes SSNs, EINs, and ITINs, and states that Form W-9 is used to request a TIN from U.S. persons. The U.S. FATCA law primarily requires foreign financial institutions to report their U.S. account holders to the IRS and also concerns foreign-account reporting by U.S. persons; this should not be generalized as meaning that KeyBank requires every non-U.S. account applicant to submit a particular FATCA form. The United States is not a participant in the OECD CRS automatic exchange of information. The United States is not listed in the OECD-published list of signatories to the CRS Multilateral Competent Authority Agreement (status as of 2025-03-13), so this file does not claim that the United States has joined CRS. KeyBank’s tax self-certification and foreign-TIN requirements for non-U.S. tax residents who are individuals or entities have not yet been publicly verified.

Source:IRS — Taxpayer Identification Numbers (TIN) ；IRS — Instructions for the Requester of Form W-9 ；IRS — Foreign Account Tax Compliance Act FATCA ；OECD — Signatories of the CRS Multilateral Competent Authority Agreement

U.S. OFAC Sanctions

The U.S. Treasury Department’s OFAC publishes a sanctions compliance framework for organizations subject to U.S. jurisdiction and foreign entities with U.S. business or personnel. Account holders, beneficial owners, sources of funds, and transactions may be affected by applicable sanctions and bank risk controls; KeyBank’s specific list screening methods, risk appetite, and refusal rules are not individually disclosed in the account-opening sources reviewed.

Source:U.S. Treasury OFAC — A Framework for OFAC Compliance Commitments

Compliance evidence

Account-opening compliance and supporting-document checklist

The bank’s stated requirements, local regulations, and preparation recommendations are presented separately. Acceptance in a specific case is subject to confirmation by the bank.

This guide concerns preparations for personal and non-personal deposit accounts with U.S. national bank KeyBank National Association. It does not mean KeyBank has confirmed that it accepts applications from foreign-incorporated companies, customers with foreign addresses, or applicants for any specific product. KeyBank’s current deposit agreement applies to personal and business accounts, but its coverage of business accounts does not establish that foreign businesses are eligible to open them. The channels and requirements for personal checking, business savings, and business checking must not be assumed to be interchangeable.

Date information checked:2026-10-26

Information evidence package

Business identity, authorization and basic account-opening information

Who it applies to: Companies, organizations and other non-individual applicants; the agreement terms below are expressly stated by the bank, while the form of offshore documents remains to be confirmed.
Documents to Prepare: The KeyBank agreement requires completion of applicable forms and provision of the documents, information or items it requires to establish and maintain an account, including acceptable identification, any applicable minimum deposit and a taxpayer identification number (TIN).
A non-individual account applicant must demonstrate that a resolution acceptable to the bank has been passed, authorising a designated representative to conduct business. You may prepare a board/member resolution, a list of authorised signatories, and their identity documents in advance so the bank can confirm the required format.
As a general preparation recommendation, have registration/organizational documents, proof of good standing or business operations, and company contact details ready. The agreement does not specify authentication, translation, or validity-period standards for foreign registration certificates, nor does it list a check-specific document checklist for businesses.
Description: The first two items are categories expressly stated in the agreement; this does not mean the agreement lists all documents actually required or that foreign identification documents are accepted. The third item is a preparation recommendation only. The agreement states that the bank may close the account if required information is not provided within a reasonable period.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)

Ownership chain, beneficial owners, and controllers

Who it applies to: Legal entity customers covered by the U.S. CDD Rule; this is not a global threshold applicable to all countries or all customer categories.
Documents to Prepare: Prepare a shareholding-chain diagram from the applicant entity to the ultimate natural persons, showing direct/indirect percentages, control relationships, and the place of registration of each intermediate entity. This is a recommendation to facilitate verification, not a form requirement published by KeyBank.
The US CDD baseline includes natural persons with direct or indirect ownership of at least 25% (if any) and a natural person with significant management/control responsibilities; prepare these individuals' names, dates of birth, street addresses, and SSNs or, for foreign persons, passport/similar government-issued document numbers.
You may prepare copies of unexpired government-issued photo ID and documents showing that the authorized representative may open an account on behalf of the company. FinCEN allows financial institutions to determine verification methods based on risk, and copies of beneficial owner documents may be handled as described in the rule; this does not establish that KeyBank accepts any particular foreign document.
Description: The FinCEN Rule applies to legal entity customers of covered financial institutions, with statutory exclusions and exemptions; banks may use stricter internal procedures.

Source:FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)；FinCEN — Exceptive Relief to Streamline Customer Due Diligence Requirements（2026-02-13）

Business purpose, expected fund activity, and explanation of source

Who it applies to: Prudent preparation advice for all business applicants; this is not a complete mandatory document checklist published by KeyBank.
Documents to Prepare: Prepare a one-page business description stating the products/services, locations of customers and suppliers, account purpose, main categories of payers and payees, and estimated transaction frequency and amounts.
Prepare evidence that can corroborate the source of funds, such as recent financial statements, key contracts/invoices, financing or shareholder capital contribution documents, and related bank statements. Select documents based on the client’s actual circumstances; do not state that any particular category is mandatory for the bank.
Explain whether anticipated wire transfers, cash transactions, or cross-border receipts and payments are consistent with the business, and prepare sample transactions and payment routes; FinCEN uses the nature and purpose of the relationship to profile customer risk and compare it with actual activity.
Description: The KeyBank agreement reserves the right to request additional information, but the bank has not published uniform documents, thresholds or risk appetite for source-of-funds/wealth evidence. Specific requirements should be confirmed with account-opening staff.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)；FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)

Due diligence and enhanced verification

Beneficial owner and controller verification

Basis for Verification: FinCEN’s CDD FAQ states that, generally, a covered institution identifies each natural person who owns at least 25% of a legal entity, if any, and one person with significant management or control responsibility, and verifies identity on a risk basis. The 2026-02-13 relief allows a financial institution to choose not to re-identify and verify the same customer each time a new account is opened. It must still do so at initial account opening, when there is reasonable cause to doubt the reliability of existing information, and when required by risk-based ongoing due diligence. Adoption is at the financial institution’s discretion.
Preparation recommendation: Provide an organizational chart explaining direct and indirect ownership, registration information for each tier, and the controller’s role. If ownership or control has changed recently, proactively prepare the dates of changes and supporting documents. Do not assume KeyBank has chosen to use an exception or will not collect information on each occasion.
Scope: U.S. regulatory baseline; scope is subject to the rules’ definition of a legal entity customer, exclusions, and exemptions; not a KeyBank case-specific checklist.

Source:FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)；FinCEN — Exceptive Relief to Streamline Customer Due Diligence Requirements（2026-02-13）

Business purpose, source of funds and transaction activity

Basis for Verification: FinCEN requires covered financial institutions to understand the nature and purpose of customer relationships and conduct ongoing monitoring, and to maintain and update customer information on a risk basis. The FAQ does not require all customers to submit one particular set of expected-transaction materials, nor does it specify uniform source-of-funds documents. The KeyBank agreement permits it to request other information needed to establish or maintain an account.
Preparation recommendation: Prepare a business description, contracts/invoices, explanation of the source of funds and a reasonable expected transaction profile that correspond to the account’s actual purpose. If the business model, transaction regions or fund volumes change significantly after account opening, retain the reasons for the change and supporting documents in case questions arise. This is a general preparation recommendation.
Scope: The bank agreement’s authorization and U.S. CDD regulatory obligations are described separately; KeyBank’s case-specific thresholds and enhanced due diligence triggers are not public.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)；FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)

Screening for sanctions, politically exposed persons and associated parties

Basis for Verification: The KeyBank agreement requires that accounts not be used in violation of applicable laws, expressly including OFAC sanctions regulations. The agreement does not publish specific screening lists, PEP definitions/handling standards or risk appetite. FinCEN’s FAQ also explains that the CDD rule itself does not require media searches or any particular type of screening for all customers.
Preparation recommendation: It is advisable to truthfully compile the legal names, aliases, nationalities/places of registration, and business locations of the entity, ultimate owners, controllers, authorized persons, and key counterparties. If a current/former public office or close-relative connection is involved, prepare an explanation of the position, term of office, and source of funds in case the bank asks. This recommendation does not mean that PEP status automatically results in refusal or that the bank will necessarily require a particular declaration.
Scope: The KeyBank agreement expressly requires compliance with applicable sanctions; specific screening and PEP-handling procedures are not public. Preparatory guidance does not mean that regulations require the same documents from every customer.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)；FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)

TIN and tax status

Basis for Verification: The KeyBank agreement requires customers to provide and certify their TIN, and states that its policy is not to accept accounts with an uncertified TIN or where no TIN has been applied for. The agreement also requires customers to notify the bank if their TIN is incorrect or they become subject to backup withholding. It does not specify self-certification forms for foreign entities/non-US tax residents, foreign tax numbers or W-8 documents.
Preparation recommendation: Prepare the entity's EIN/TIN and the corresponding legal name. If it has not yet been obtained, first confirm with the bank what evidence of an application in progress is acceptable and when the account can be opened. Ask the bank which U.S./foreign tax forms are required based on the entity's and individual's actual tax status; do not assume a form applies solely because of foreign status.
Scope: The KeyBank agreement expressly addresses TIN requirements; details of cross-border tax documentation are not public and must be verified based on the applicant entity, account type and tax circumstances.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)

Ongoing maintenance obligations

Address, email, and contact details

The KeyBank agreement requires prompt written notice of a change to a mailing address or email address. Notice may first be sent by email, but written confirmation must be mailed within five days. Customers should maintain a contact address where statements and notices can be received; this clause should not be interpreted as the bank requiring proof of address at a uniform recurring interval.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)

Account statements and unusual transactions

The agreement requires customers to review statements promptly after receiving or being able to view them; if a statement does not arrive by its usual date, customers should contact the bank immediately, and they should promptly report unauthorized, forged or erroneous transactions. FinCEN requires banks to conduct ongoing risk-based monitoring and maintain/update information based on risk; customers should retain transaction contracts, invoices and payment explanations to respond to reasonable inquiries.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)；FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)

Changes to TIN, authorization, and beneficial owners

The bank must be notified if a TIN is incorrect or backup withholding status changes; update signatories/authorization resolutions promptly to avoid the bank acting on outdated authorization in its records. FinCEN does not require beneficial ownership information to be automatically recollected at every periodic review when no risk trigger exists; if bank monitoring identifies a change that may affect its risk assessment, updates may be required under risk-based procedures. The agreement and regulatory rules do not disclose a fixed review frequency for KeyBank.

Source:KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)；FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)；FinCEN — Exceptive Relief to Streamline Customer Due Diligence Requirements（2026-02-13）

Please confirm with the bank before booking

Will KeyBank National Association accept an application from a foreign company based on its place of incorporation, business type and owners’ places of residence? Which specific business account products are available?
Which state/branch must the applicant visit? Must the representative, controller, or beneficial owner attend in person? Is there a pre-screening or remote verification channel?
What forms of originals/certified copies, translation, or certification are accepted for foreign registration certificates, articles of association, ownership charts, director/member resolutions, and signatory identification?
What identity details and supporting documents does KeyBank use for beneficial owners, controlling persons, and authorized representatives? Are they collected again each time a new account is opened?
What EIN/TIN, tax-status declarations or US/foreign tax forms are required for the entity and individuals? Can an account be opened while a TIN application is pending, and what evidence would be required?
What are this product’s minimum deposit, fees, supplementary-document procedures, and approval timeline? Are there additional requirements for document reviews or notification of material business changes after account opening?

Not confirmed by public information

The public agreements do not confirm that KeyBank accepts foreign-registered companies, foreign addresses, or non-U.S. beneficial owners; no public commitment was found that could be relied on to guarantee remote/video account opening.
A complete document checklist for opening an account for a foreign company, certification/translation requirements for overseas documents, documents specific to a business checking account, and acceptable forms of proof of ownership have not been published.
The bank must confirm on a case-by-case basis the tax forms, cross-border tax self-certification, foreign tax numbers, and applicability to each account type for foreign tax residents.
KeyBank’s internal risk appetite, thresholds for source-of-funds evidence, PEP/sanctions screening methods, approval timeframes, fees for opening accounts from abroad and fixed review frequency are not public; no assumptions are made about them.

Sources & Scope of Verification

KeyBank National Association — Deposit Account Agreement and Funds Availability Policy (effective date: 2026-09-18)
KeyBank’s current official agreement applies to personal and business accounts and expressly addresses categories of information required to open/maintain an account, TIN and certification, authorising resolutions for non-individual accounts, consequences of failing to provide additional documents, OFAC compliance, notice of changes to address/email, statement review and error reporting. It does not provide a complete policy on the eligibility of foreign companies or forms of foreign identification.
FinCEN — Customer Due Diligence Rule FAQs (updated 2026-05-06)
Original U.S. regulatory FAQ on CDD for covered financial institutions: scope of the legal-entity customer definition; identification of owners with 25% ownership and control persons; identity information and risk-based verification; relationship purpose and ongoing monitoring; and maintenance of information following risk triggers. It also explains that a uniform expected-activity profile, media search, or fixed-interval beneficial-owner updates are not necessarily required.
FinCEN — Exceptive Relief to Streamline Customer Due Diligence Requirements（2026-02-13）
The official FinCEN announcement explains that financial institutions may choose to identify and verify beneficial owners at initial account opening, when there is reasonable doubt about the reliability of existing beneficial ownership information, and when required by risk-based ongoing due diligence, rather than necessarily repeating the process for every new account; other obligations, including ongoing monitoring and risk-based maintenance and updating of information, remain in effect.

Fees and timelines

As of 2026-10-26, the Key Smart Checking page published a minimum initial deposit of 10 US dollars. The KeyBank Basic Business Checking product page published a minimum opening deposit of 25 US dollars and a monthly maintenance fee of 5 US dollars, with waiver conditions listed on the page. These amounts apply only to the specific products and do not establish eligibility for foreign customers or fees for all accounts. The official website has not published approval times or guaranteed processing periods for opening accounts for individuals/companies overseas; the full charges for each product are subject to the agreement and disclosures applicable at the time of opening.

Limitations and practical considerations

Personal online applications are limited to U.S. citizens listed in the KeyBank FAQ who are at least 18 years old, reside in specified states, and are applying for a personal account; other applicants should confirm with a local branch. Non-residents must apply at a KeyBank branch. Remote account opening from abroad has not been verified.
The current product promotion specifies a U.S. address and valid SSN/TIN requirements, is subject to geographic restrictions, and requires bank approval. Eligibility for the promotion must not be taken as a commitment that ordinary accounts are available to non-residents.
KeyBank’s published small business savings account process requires an in-person application. Acceptance of foreign-incorporated companies, businesses without a US address, foreign shareholders or controllers, and the application documents for business checking accounts all require written confirmation from the bank.
The bank’s published product, directory or regulatory information does not establish an agency relationship, guarantee account approval, or confirm that Rengangyongsheng (Hong Kong) Limited currently offers an appointment channel or can act on the applicant’s behalf. Do not promise acceptance to clients before this is confirmed.

Licensing evidence and regulatory verification

The entity and current regulatory records have been cross-checked: the current FDIC BankFind official institution API record lists KeyBank National Association, ACTIVE=1, FDIC certificate number 17534, OCC as the primary regulator, and OCC Charter number 14761. The data index time is 2026-10-23, and the institution record was updated on 2026-09-28. The OCC official active national banks list also gives the legal name, OCC Charter number 14761, Cleveland address, and FDIC certificate number 17534. These numbers are regulatory identifiers; no separate licence number is fabricated. This verification concerns the U.S. national bank entity and does not constitute a licence check for every state branch, affiliate, or product.

Office of the Comptroller of the Currency (OCC; the FDIC is the deposit insurance agency) Official registration or record

Information sources

KeyBank — Checking Accounts
KeyBank’s personal checking product page expressly states that non-residents must open an account at a branch. The current promotional eligibility wording requires a valid SSN/TIN and a US address, and notes geographic restrictions and that account opening is subject to approval. This describes promotional conditions and does not extend them to a general address policy for all deposit accounts.
KeyBank — Checking FAQs
SSN/TIN, primary identity documents, and product minimum deposit required for an individual checking application; the online application conditions of age 18, U.S. citizenship, residence in specified states, and individual-account status; applicants who do not meet the online criteria may ask a local branch.
KeyBank — What to Bring to Open an Account in a Branch
Individuals opening an account at a branch, including joint accounts, need a primary identity document. If the address on the document differs, provide proof of address, such as a utility bill. The bank will also request contact information such as a phone number, date of birth, and email address.
KeyBank — Business Savings Account FAQs
Applications for KeyBank small business savings accounts must be made in person at a KeyBank branch. The stated requirements are an SSN or EIN, business formation documents, two valid forms of identification and the minimum opening deposit applicable to the product. This applies only to that savings product and does not extend to business checking or policies for foreign companies.
KeyBank — Small Business Checking Accounts
KeyBank offers small business checking products. The page lists a minimum opening deposit of 25 US dollars and a monthly maintenance fee of 5 US dollars for KeyBank Basic Business Checking, together with the related balance-waiver conditions.
FDIC BankFind API — Institution record for certificate 17534
The FDIC official current institution API directly returns KeyBank National Association, ACTIVE=1, FDIC certificate 17534, OCC as chartering agency, OCC Charter 14761, and a Cleveland address. Institution record updated 2026-09-28; data index 2026-10-23.
OCC — National Banks Active by State
The original OCC official active national bank list entry names KeyBank National Association, OCC Charter number 14761, 127 Public Square, Cleveland, Ohio, and FDIC certificate 17534; this is used to cross-check the current legal bank name and national bank regulatory status.
FinCEN — CDD Rule FAQs
The FinCEN FAQ explains ongoing CDD obligations for covered U.S. financial institutions, identification requirements for legal entity customers’ 25% beneficial owners and one control person, use of a passport or other government-issued identification for foreign individuals, and the 2026 account-opening relief, which financial institutions may choose whether to use.
IRS — Taxpayer Identification Numbers (TIN)
The IRS states that SSNs are issued by the SSA, EINs identify businesses, and ITINs are used for federal tax treatment for eligible individuals who cannot obtain an SSN; it also lists the basic ITIN application requirements.
IRS — Instructions for the Requester of Form W-9
The IRS states that Form W-9 is used to request a TIN and related certifications from U.S. persons (including U.S. tax residents), defining U.S. persons for federal tax purposes, and explains that foreign persons should use applicable W-8 forms; this does not establish what forms KeyBank specifically requires.
IRS — Foreign Account Tax Compliance Act FATCA
The IRS states that FATCA generally requires foreign financial institutions and certain foreign entities to report information on their U.S. account holders/U.S. owners, and provides official information links for financial institutions and individuals.
OECD — Signatories of the CRS Multilateral Competent Authority Agreement
The official OECD signatory list is marked as current as of 2025-03-13; the United States is not listed as a signatory to this CRS multilateral competent authority agreement. This evidence is used to explain why the United States should not be said to have joined this CRS arrangement, and does not replace separate verification of later updates.
U.S. Treasury OFAC — A Framework for OFAC Compliance Commitments
OFAC explains that its sanctions compliance framework is intended for organizations subject to U.S. jurisdiction and foreign entities with U.S. business, U.S. persons, or U.S.-origin services, and outlines the circumstances in which sanctions compliance programs apply.

Verification

Research verification

Most recently verified: 2026-10-26
Status: Some information is pending confirmation: KeyBank National Association’s legal entity, its currently active FDIC-insured depository institution record, OCC primary regulator, and public personal/business product conditions have been verified; the bank has not publicly confirmed full eligibility for overseas nonresidents, whether foreign legal entities and their owners are accepted, business checking-specific documents, foreign tax self-certification forms, or any remote witnessing arrangements.
Author: Drew

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