KYC and source of funds: preparing a banking file that gets through, for a creator and for an OFM agency.

"They are asking me for the source of funds, what do I say?" The question reaches us at two moments: when an account is being opened, when the institution asks for documents before approving it, and six months later, when an OnlyFans transfer or a payment from an agency triggers a request for explanation. This guide explains what KYC and KYB cover, what the law actually requires of the bank, the documents it is entitled to expect from a creator and from an OFM agency, and the inconsistencies that get a file refused.

KYC, KYB: what these acronyms mean

KYC stands for Know Your Customer: the checks a financial institution carries out on an individual — who they are, what they do, where their money comes from, what the account will be used for. KYB, Know Your Business, is the same exercise applied to a company: who runs it, who ultimately owns it, what its real activity is, how its funds move.

The acronyms are industry shorthand; the statutes speak of "customer identification", "customer due diligence" and "ongoing monitoring". But they describe something concrete: a compliance department, analysts, monitoring software, and a risk grid in which adult content income is classified as "high". Platforms do their own KYC at sign-up; the bank's is more demanding, because it is the bank that carries the risk if the money it moves comes from an offence.

What the law requires of the bank, and why it asks you these questions

The obligations sit in the anti-money-laundering rules that bind every regulated institution; knowing them makes it clear that an analyst asking questions is not being overzealous.

Before opening the account, the institution must identify its customer and, for a company, its beneficial owners, and verify those identities against a reliable document (article L. 561-5). It must also gather information on the purpose and nature of the business relationship, that is your activity, the intended use of the account and the expected flows (article L. 561-5-1). That information must be updated throughout the relationship.

During the relationship, it exercises ongoing due diligence and examines transactions to check they remain consistent with what it knows about you (article L. 561-6). Any particularly complex transaction, of an unusually high amount or with no apparent economic justification, is subject to an enhanced examination: where do the funds come from, what are they for, who benefits (article L. 561-10-2).

If it cannot reach a conclusion, article L. 561-8 is unambiguous: an institution unable to identify its customer or understand the relationship carries out no transaction and neither establishes nor continues the business relationship. A refusal after a request for documents went unanswered is therefore not arbitrary; it is the law being applied.

If it suspects, it reports. Article L. 561-15 requires institutions to report to the financial intelligence unit sums or transactions they know, suspect or have good reason to suspect come from an offence punishable by more than one year's imprisonment, or from tax fraud meeting certain criteria. That report is confidential: the bank is forbidden from telling you it exists (article L. 561-18). The volume gives a sense of scale: in 2024, the unit received 211,165 suspicious activity reports, 57.2% of them from banks.

For an OFM business, the word that matters is consistency. The bank does not judge the morality of the content; it checks that what you told it, what you gave it and what arrives in the account all tell the same story.

The documents asked of a creator

For an OnlyFans, MYM or Fansly creator opening an account dedicated to her business, the documents the law allows the institution to require are few:

• a valid identity document, and proof of address;
• proof that the activity is registered: sole trader registration, articles of organisation or a certificate of incorporation, with a consistent stated purpose;
• a description of the activity and an estimate of the expected monthly flows, in amount and frequency;
• earnings statements exported from the platform, showing who sends the transfers and how regular they are;
• where there is an agency: the management contract and the commission invoices;
• for an initial contribution or a large transfer: the document showing where the sum came from.

The point creators neglect is the third. An honest estimate of the amounts is not a commitment; it is the benchmark the analyst will use to judge whether the flows are consistent. Announcing €2,000 a month and receiving €15,000 triggers an enhanced examination; announcing €15,000 with statements to prove it triggers nothing.

The documents asked of an OFM agency

For an agency, KYB takes the documents of any company and adds what describes the real activity.

• The registration extract, the articles and the directors' identities.
• The beneficial owners: any individual who holds, directly or indirectly, 25% or more of the equity or voting rights, or who otherwise exercises control. That threshold is the same under the FinCEN Customer Due Diligence rule in the United States and the people-with-significant-control regime in the United Kingdom. Interposing a foreign holding company does not exempt anyone: the bank traces back to the individual, and refuses if it cannot.
• The management contracts signed with the creators, which prove the commission has a cause.
• The invoices issued to the creators, consistent with the contracts.
• A one-page diagram of the flows: the platform pays the creator, the creator pays the commission to the agency, the agency pays its chatters and contractors.
• A revenue and cash flow forecast consistent with the number of creators managed.
• How the chatters are paid: services contracts, countries, currency, and where relevant the use of stablecoins (see our guide on paying in USDT and USDC).

The diagram of flows is the document that decides. An agency whose creators are paid directly by the platform and which invoices its commission presents a simple flow. An agency that collects the creators' payouts and then pays them on presents a flow the analyst has to reconstruct, which inflates its turnover and feeds the argument of economic control developed in our guides on whether agencies are legal in the United States and the United Kingdom. The structure of the flows is decided before opening the account.

"Source of funds": what evidencing actually means

When the bank asks for the source of funds, it is not asking for an explanation; it is asking for a chain of evidence, with no missing link, between the source of the income and the account. For OnlyFans income the chain is short: the platform's earnings statement, the matching transfer, and the declared activity under which that income is taxed. For an agency commission: contract, invoice, transfer from the creator. For a capital contribution: a statement from the originating account, and the document explaining how the sum got there (declared income, sale of an asset, a gift).

Two rules. The chain must be dated and readable: an export from the platform with amounts, dates and currency beats a screenshot. And it must be ready before the question: the response time a bank allows is measured in days, and an incomplete answer counts as no answer.

Presenting the activity without lying or euphemising

The temptation is to dodge the word: writing "digital marketing", "image consultancy" or "content creation" without saying what content. That is the strategy that fails most reliably, because the bank always ends up seeing the transfer references. The day "Fenix International" or a well-known platform appears on the statement of a client who declared consultancy, the analyst does not see an adult content business; they see a client who lied at account opening, and a suspicious activity report is not far away.

The right presentation is factual: "creating and distributing digital subscription content on online platforms, including OnlyFans and MYM", with the statements to match. For an agency: "account management, marketing and subscriber relationship services for content creators on subscription platforms, paid by commission". That is accurate, complete and verifiable. The institution remains free to refuse the sector; it will not be able to accuse you of a false declaration, and the file will still be presentable elsewhere, to the family of institution described in our guide on banks that accept OnlyFans.

The inconsistencies that get a file refused

They recur from one file to the next.

1. The corporate purpose does not match the flows: a "consultancy" company receiving payments from content platforms.
2. The amounts announced do not match the amounts received, in either direction.
3. A third party collects: the manager receives the creator's payouts, or the agency receives those of ten creators into its account.
4. The beneficial owner cannot be found: a foreign holding company, a nominee, a shareholder who appears nowhere.
5. The contracts are missing: a commission taken with no management contract is a flow with no cause.
6. The documents contradict each other: a contract at 30% commission and invoices at 50%, a forecast for five creators and transfers from twenty.
7. A late or partial answer to a request for information, which counts as a refusal to cooperate.

None of these inconsistencies has anything to do with the sector. All of them can be corrected before the file is submitted, and none can be salvaged after a refusal without changing what caused it.

Timeframes, periodic reviews and the life of the account

There is no statutory deadline for opening an account. The time depends entirely on how complete the file is: complete, it is processed in a few days; incomplete, it sits waiting at every chase. Business-focused online banks are usually the fastest, and the ones most willing to tell you their sector policy up front.

Opening is not the end of KYC. The law requires the institution to keep its knowledge of the customer up to date throughout the relationship, and its internal classification sets how often reviews occur, more frequently for a customer classified as high risk. Expect a request for documents at every notable change: a lasting rise in amounts, a new platform, a new country of residence, a new shareholder, a first flow in foreign currency or crypto-assets. A file kept up to date, with statements exported every month and current contracts, turns those reviews into a formality. That preparation and presentation work is what we do with agencies and creators, including with institutions abroad where the structure justifies it.

Your contactOlivier MaciejewskiFounder of OFM Legal · Former international business lawyer (HEC Paris, Arendt, Clifford Chance) · Official MYM partnerHis background Updated July 15, 2026

This article is general information and does not replace advice tailored to your situation. OFM Legal is not a law firm: court proceedings are handled by our partner lawyers.

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