Mercury vs Relay vs Wise for a Non-Resident US LLC (2026)
TL;DR
None of Mercury, Relay or Wise is a bank — each is a fintech holding funds at partner banks. For a non-resident owner all three accept a passport instead of an SSN or ITIN, and the binding constraints are your country of residence and your address type, not your tax ID. Verified August 2026.
Do you need an ITIN to open a US business bank account?
No — and the ITIN is not what the bank is looking for.
The bank’s customer is the LLC, not you. Under the Customer Identification Program rule, 31 CFR 1020.220(a)(2)(i)(A), the identification number for “a person other than an individual” is a taxpayer identification number — which for the LLC is its EIN.
You are identified separately, as a beneficial owner. For a non-US person, the same rule expressly permits “a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document.”
A passport is legally sufficient. Bluevine states it plainly in its own product copy: “No U.S. SSN required.”
Where an SSN is demanded — Novo, Found, Mercury Personal, Bank of America — that is provider policy, and an ITIN generally will not cure it. Mercury Personal is explicit: “we don’t accept ITINs.”
The myth persists because at traditional retail banks an ITIN genuinely can substitute for an SSN on a personal account. Chase’s non-resident guidance lists “Social Security number or Individual Taxpayer Identification Number (ITIN)” — but that is personal-account guidance about the human, not about your LLC. See EIN vs ITIN — which you actually need.
Side-by-side: what actually differs
| Mercury | Relay | Wise Business | Payoneer | |
|---|---|---|---|---|
| Legal status | Fintech; partner banks Choice Financial Group, Column N.A. | Fintech; partner bank Thread Bank | Not a bank; funds at commercial banks incl. JPMorgan Chase | Not a bank account, per its own terms |
| FDIC | Pass-through via partner banks and sweep, stated up to $5M | Sweep up to $3M, $250k per program bank | Pass-through to $250k only if you opt in to APY | ”FDIC or other government-sponsored insurance does not apply” |
| SSN required? | No for business accounts (passport accepted) | No — “passport only for non-U.S. citizens” | No for non-US beneficial owners | No |
| Restricted countries | ~47 incl. Nigeria, Pakistan, Bangladesh, Indonesia, Philippines, Vietnam, Croatia, Latvia | 31 incl. Nigeria, Pakistan, Russia, Ukraine, Lebanon, Venezuela | USD details unavailable in 30+ countries | OFAC-sanctioned countries |
| Inbound payments | Open ACH and wire | Open ACH and wire | ACH, domestic wire, SWIFT USD | Only payers Payoneer approves |
| Cash / cheques | No | No | ”We can’t accept cash or cheque payments" | "does not support cash deposits or checks” |
| Operating agreement | Not requested | Only if multi-member | Not requested | — |
The single most important row is the last-but-one. Payoneer’s terms state that “only payers approved by Payoneer in Payoneer’s sole discretion may make payments to your Payoneer Balance.” A real business account accepts any inbound ACH or wire. That difference is why Payoneer works as a marketplace collection rail and fails as your only account.
What “not a bank” actually means for you
All three consumer-facing platforms disclose it themselves. Mercury: “Mercury is a fintech company, not an FDIC-insured bank.” Relay: “Relay is a financial technology company and is not an FDIC-insured bank.” Wise: “We are not a bank, which means we do not lend out our customers’ money.”
Three practical consequences:
- Your deposit insurance is conditional. Mercury’s own disclosure notes that “certain conditions must be satisfied for pass-through insurance to apply.” Wise’s FDIC coverage applies only to customers who opt in to earn APY — it is not automatic.
- Your account depends on a partner bank you did not choose. Mercury moved off Evolve Bank & Trust through March 2025. Thread Bank, Relay’s sole partner, received an FDIC consent order in June 2024 aimed at its banking-as-a-service business.
- Approval is not permanent. In July 2024 Mercury closed accounts for customers in Ukraine, Nigeria and Croatia with 30 days’ notice, identifying them from “business and residential addresses given during onboarding and regular KYC/KYB refreshes, as well as frequent location of account activity (via IP addresses).” That last clause is the durable lesson.
One change worth watching: on 27 April 2026 the OCC granted Mercury conditional approval to establish Mercury Bank, N.A. Final OCC authorization plus FDIC and Federal Reserve approvals remain pending. If it completes, the fintech analysis above changes — and eligibility policy may change with it.
Why non-resident applications actually get rejected
Ranked by how often they are the real cause. Note that Mercury explicitly declines to tell you: “While we cannot disclose specifics as to why a particular application was approved or rejected…” — so this is assembled from published eligibility rules, not a rejection table.
- Your country of residence or citizenship is on the provider’s list. The largest single cause. Providers check citizenship, residence and login IP. Nigeria, Pakistan, Vietnam, Indonesia, Philippines, Bangladesh, Ukraine, Belarus, Russia, Lebanon and Venezuela appear on Mercury’s or Relay’s lists — countries with large populations of legitimate sellers.
- The address is a registered agent, virtual mailbox, or mail-forwarding service. Mercury rejects “a P.O. box, virtual address, commercial mail receiving agency, mail center, or registered agent address” for the physical address. Relay bars non-US residents from using a registered agent address. Wise excludes virtual offices and business-registration-agency addresses as the trading address. This is the most common fixable failure — and formation agents cause it by default.
- Name mismatch across three documents. The entity name on the Articles of Organization, on the IRS EIN letter, and on the application must match exactly.
- Wrong EIN document. Mercury wants the IRS-returned SS-4, CP 575, or 147C — not the blank SS-4 you filed.
- No verifiable business. Mercury: “A website isn’t required, but it greatly helps our onboarding team evaluate your application.” Mercury and Brex both require existing or planned US operations.
- Entity formed outside the US. Mercury: “we cannot accept companies that are formed outside of the US.” A UK Ltd or Hong Kong company is a hard no regardless of everything else.
- Incomplete beneficial-ownership disclosure. Everyone at 25% or more, plus a control person. Undisclosed co-owners surface during verification.
- Prohibited business type — MSBs, adult content, cannabis, gambling, crypto, tobacco, depending on provider.
The others, in one line each
- Brex — accepts non-residents and is the only provider here that explicitly accepts “virtual offices or registered agent offices,” but gates access commercially: equity investment or over $500,000 annual revenue, or a $50,000 minimum balance. Effectively closed to bootstrapped sellers.
- Bluevine — launched digital onboarding for international owners on 6 July 2026, no US SSN required, no US personal address needed — but only 25 accepted countries, with China, Turkey, Latin America, Africa and the Gulf absent.
- Novo — requires US residence and an SSN. Closed.
- Found — requires an SSN. Closed.
- Bank of America — explicit: “Must be U.S. based. Foreign business customers are unable to apply at this time.”
- Chase / Wells Fargo — publish no non-resident business path. In practice both are branch-shaped, with original-document ID and owner presence expected.
What is legally required vs what is provider policy
Separating these tells you what is negotiable.
Required by federal rule:
- An identification number for the LLC — the EIN (31 CFR 1020.220(a)(2)(i)(A))
- A physical location for the entity: “a principal place of business, local office, or other physical location.” The regulation does not say it must be in the United States.
- Identification of beneficial owners at 25% or more plus a control person (31 CFR 1010.230) — satisfiable for a non-US person with a passport
Provider policy, not law:
- An operating agreement (Relay only if multi-member; Mercury does not ask; the big banks often do)
- A US address of any kind
- Refusal of registered agent and virtual addresses — Brex accepts them
- Prohibited-country lists beyond OFAC sanctions
- Revenue or funding minimums
- Any SSN requirement
Application checklist
- Check your country against the provider’s current list first. Relay’s was updated 11 August 2026; Mercury’s carries no date. Re-check immediately before applying, not from any article including this one.
- Get the IRS-returned EIN document — CP 575 or a 147C letter.
- Confirm the entity name matches exactly on the Articles of Organization, the EIN letter, and what you type into the application.
- Sort out the address before you apply. If your only US address is a registered agent, expect rejection everywhere except Brex. Your own overseas residential address, evidenced by a utility bill or lease, is usually the workable answer for the personal-address field.
- Have a website that names the applying entity.
- List every 25%+ owner and the control person.
- Do not apply repeatedly after a rejection. Mercury permits reapplication only with new information.
Frequently Asked Questions
Q: Which one should a non-resident Amazon seller pick? A: It depends on your country of residence more than on features. Check your country against Mercury’s and Relay’s restricted lists first — if you are excluded from both, Wise or Bluevine are the realistic remaining options.
Q: Can I open an account without visiting the US? A: With Mercury, Relay, Wise, Bluevine and Brex, yes — all are remote. Bank of America, Chase and Wells Fargo have no published remote path for a non-resident-owned entity.
Q: Does Wise give real US account details? A: Yes. Wise issues a unique USD routing number, account number and account type “Checking,” and receives ACH and domestic wire from the US plus SWIFT USD from abroad. It cannot accept cash or cheques and does not lend.
Q: My account was approved and later closed. Why? A: Periodic KYC/KYB refresh or location review. Mercury’s July 2024 closures used onboarding addresses and account-activity IP addresses, with 30 days’ notice. Approval reflects policy at the time of application, not permanently.
Next Steps
Banking eligibility for a non-resident-owned LLC changes faster than most published guidance — provider country lists move without notice, and the constraint that blocks you is rarely the one you expected. Before applying, it is worth confirming that your EIN documentation, entity name and address configuration will survive verification, since a rejection at one provider is often repeated at the next for the same underlying reason.
Verified August 2026 from provider primary sources. Provider policies and country lists change frequently — confirm current terms with the provider before applying. This article is general information, not tax, legal or financial advice.
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