In the summer of 2024 Mercury offboarded clients from several countries, Ukraine among them, effectively overnight. Many concluded at the time that the issue was citizenship, and plenty still believe it.
It was not the passport — and Mercury confirmed as much itself. Below we go through what actually happened, why the same person is rejected when signing up from scratch yet can open an account through an existing dashboard, which documents help keep an account alive, and what to do once a closure notice has already arrived.
01 — TimelineWhat happened in July 2024
In late July 2024 Mercury notified a portion of its clients that their accounts would be closed. Ukraine, Nigeria, Pakistan, Croatia and the Philippines were added to the list of countries the bank no longer supports where the founder resides there or the business is headquartered there. Closure was set for 13 August.
The backdrop was regulatory. Shortly beforehand, Mercury's partner bank Choice Financial Group had come under FDIC scrutiny over its practice of opening accounts for foreign companies. Mercury subsequently revised its client requirements and informed some customers that it could no longer serve them.
Mercury CEO Immad Akhund publicly explained that clients from these countries accounted for under 1% of deposits, while the load they placed on operations and compliance teams and on partner banks was disproportionate to that share.
He noted separately that Ukraine was the hardest case: the country is not under comprehensive sanctions, but parts of its territory are — and maintaining a regional verification model became too difficult.
02 — The key pointPassport or address
This is where the confusion started, and it still circulates in founder chats today.
A line did appear in Mercury's help center stating that the bank could not serve founders holding a Ukrainian passport. A company representative later called that line an error, and it was removed.
The bank's official explanation of how accounts were selected, given in a comment to TechCrunch, was different: accounts were identified by the business address and residential address supplied at onboarding and during routine KYC/KYB refreshes, and by where the account holder regularly logs in from, based on IP addresses. Mercury co-founder Jason Zhang separately told affected founders that the bank does not place Ukraine in the same category as Russia.
The difference between "by passport" and "by address" is both a matter of principle and a practical one. You cannot change your citizenship. Your actual place of residence, and the documents that evidence it, are something you can work with.
03 — PracticeOur experience: the documents we gathered
During that wave we managed to preserve and reinstate a number of client accounts. What we assembled and submitted to the bank was evidence of two things: that the company's owner genuinely lives in a whitelisted country, and that the company's operations are unconnected to the country triggering the closure.
On the individual
- Residence permit and a residential lease in the person's own name
- Utility bills
- Bank statements showing everyday spending in the country of residence
- Gym membership
- Confirmation that a child attends a local kindergarten
Some of this looks excessive — and in calmer circumstances it would be. But the task was to preserve an account in the middle of a hard offboarding wave, and in that situation the excess is justified: each document proves little on its own, while together they add up to a picture of someone who genuinely lives in that country rather than merely being registered there.
On the business
- Supplier contracts and invoices
- Evidence that the company's contractors and freelancers are not located in the country triggering the closure
Something else emerged along the way that explains a good many rejections. Opening an account for a new company owned by the same beneficial owner, through an existing Mercury dashboard, is possible. Yet the same person with the same passport, arriving at signup from scratch, would almost certainly be turned down.
04 — MechanicsWhy the same person gets different answers
This is not a loophole. It is the difference between two procedures inside the same bank.
Signing up from scratch
You go through automated identity verification with an external provider, and it accepts a passport — that is where the list of admissible documents ends. There is physically nowhere to show a residence permit, a local driver's licence or a lease: the interface has no such field. The system receives a single fact — country of citizenship from a restricted list — and the flag is raised before your case ever reaches the compliance team.
Opening an account through an existing dashboard
You are already a verified client with a transaction history, and the route is different: there is an option to contact support and submit documents on your actual place of residence individually — that is, to convey to the bank precisely the information the automated form cannot accept. The submission route, however, is only one variable. Two companies with a similar structure and a similar type of business, both submitted from scratch, may well get different answers. Beyond the founder's personal documents, how the company itself is presented matters.
- Submission route. Signing up from scratch through automated verification, or opening an account for a new company through an existing one.
- Industry and product categories. There are product categories and business types Mercury does not accept. No single published list exists — it accumulates from practice, and we maintain one for ourselves because we run into it regularly. It is worth checking your niche before applying rather than after a rejection.
- Properly prepared company documents. Formation documents, EIN, operating agreement, and documentation of the ownership structure. The last of these matters especially for companies in closed states, where the roster of owners is not visible in the public register and has to be evidenced by the company itself.
- Company address. Virtual addresses and PO boxes are not accepted as a company address.
- Beneficial owners. The roster of beneficial owners must match what the company documents say.
- Consistency across the whole picture. The website, the business description in the application, supplier contracts and the stated payment model all need to tell the same story.
There are more nuances than this, and no universal formula. But the general principle holds: what usually triggers a rejection is not one "bad" parameter but discrepancies between parameters.
05 — Limits of our experienceThe other countries on the list
Our confirmed experience covers Ukrainian citizens. We have not tested the other countries on Mercury's restricted list.
Everything described above works precisely because the person genuinely lives outside the restricted country and can evidence it with documents. Where the actual place of residence is inside it, submitting documents to the bank stating otherwise is no longer compliance work — it is providing false information to a financial institution, with everything that follows from that.
06 — ChecklistWhat applies in practice
- There is no warning ahead of an offboarding. Either a document request arrives, or a closure notice does. Those who did not clear the address check were cut off immediately and without correspondence. If a document request arrives, that is your opportunity to keep the account.
- Log in from a genuine IP in the country where your documents say you live. VPNs, proxies, VPS and other address substitutes count sharply against you. Anti-fraud systems at Mercury's scale detect them without difficulty — the hard part is not detection but convincing the compliance team afterwards that the substitution was not intended to hide something from the bank. Regular activity from elsewhere is a trigger in its own right, even when the address itself is in order.
- If you need a second account, open it for a new company from your existing dashboard, not from scratch.
- Keep the document pack assembled in advance: residence permit or another basis for staying, a lease in your own name, a recent utility bill, a tax number from your country of residence, a local bank statement. Having no local bank account after a year of living in a country is a question in itself for a reviewer.
- A second account at another bank is not paranoia but a practical necessity. When an account is closed, funds are usually released to an account belonging to the same company at another bank — better to be prepared in advance.
Three steps:
1. Work out exactly what has been requested — rather than sending whatever is at hand.
2. Assemble the most complete package of documents answering that request.
3. Attach honest explanations to what you send.
07 — Worst caseIf the account is already closed
In the closure notice the bank either requests the details of the company's account at another bank in order to transfer the balance, or states that the balance will be sent by check to the company address. The practical implication: a second bank account is better held in advance, and the company address needs to be a working one that actually receives mail.
You can request a re-review of the account — through support or directly in reply to the closure notice. This does not guarantee a reversal, but it is the moment at which it makes sense to submit the documents the bank was missing. Signing up for a new account after a closure, on the other hand, will not work: registering again does not resolve the issue that caused the closure.
The order of steps matters here: funds first, dispute second. A re-review can take weeks, while the deadline for withdrawing the balance is set by the bank.
- Move the funds to an account belonging to the same company at another bank.
- In parallel, request a re-review and submit the missing documents.
- Address the underlying cause rather than the symptom: if the offboarding happened on address grounds, a fresh application to another bank with the same address will produce the same outcome.
What needs to change is the substance — an evidenced place of residence, a tax number, a local account, a coherent website and business description — not the wording in the application.
It is also worth remembering that Mercury is not the only option for non-residents: after the 2024 wave, several competitors made targeted offers to founders the bank had stopped serving. Choosing a bank that fits your specific country of residence, business type and payment model is a separate task, and one solved before applying rather than after a rejection.
08 — FAQFrequently asked questions
This material is informational and does not constitute legal or tax advice. Bank policies and regulatory requirements change; the account of Mercury's decisions here is based on public statements made by the company and its representatives in 2024.
A company built to clear bank compliance
Formation, EIN, address and documents assembled so that no questions arise — neither when opening an account nor at a routine review. We have formed more than 800 companies and bank accounts for non-residents.
