5. Maintaining your account
Use the information on this page as a best practice guide to keep your organisation’s bank account up-to-date and running as smoothly as possible.
We recommend referring to this guide when:
- There are changes arising to your account
- There are changes to your organisation
- On a semi-regular basis (for example, each quarter), to ensure everything is up to date
Try to think of your voluntary organisation account as you would your personal account. If you move house or have a change to your personal circumstances your bank will need to know, and it is the same for any changes to your organisation, such as a change of address or change to a trustee.
Changes that conflict with the information your bank has already collected about you or your organisation may have an impact on your account or cause a delay to your service.
On this page
Tips & recommendations
Notify your bank and stay in touch
Your bank needs to be aware of any changes that could affect the way your account is run. Some changes take time for a bank to implement, so we strongly recommended that you notify your bank in advance of any changes to your personnel or account usage as soon as possible. This will ensure your account service continues to run smoothly.
We also recommend reviewing all correspondence from your bank, via email or post.
Use the information on this page to help you decide when you should contact your bank.
Banks have different ways of operating and will vary in their preference of how to get in touch. Your bank’s website will likely have this information on it. Most banks allow you to contact them by phone, in branch (sometimes via the local branch or business manager), or online – some banks offer a live chat service on their website.
Provide updates when submitting your annual return
For registered charities, when submitting your Charity Commission, OSCR, Charity Commission return, we recommend using the opportunity to update your bank of any changes that have arisen.
Know Your Customer (KYC)
Banks have a legal requirement to know who is associated with your account and what it is being used for. You will often hear this being referred to as “Know Your Customer” (KYC) regulation.
Depending on your organisation your bank may need to validate your account details yearly to ensure these are up to date, checked and confirmed.
Changes to your organisation personnel and contact details
You need to contact your bank proactively to notify them of any changes.
- When someone leaves your organisation, it is important to ensure that any access or authority is removed. Otherwise, they can still access the account or make payments. Updating your bank protects your organisation from fraud or unwanted activity.
- When you wish to add a signatory to your organisation’s account, it is crucial that your bank is informed as soon as possible so they can update your account mandate. Failure to add them in a timely manner will result in the new signatory being unable to make changes to your account, and could result in delays for payments or other matters.
- Your bank will send you a list of information they require to add new individuals to your account. Do ensure this is completed fully and within any applicable timelines so your bank can action your requests promptly.
This includes:
- Changes to any authorised individuals or signatories.
- You will need to update your bank mandate if these people move on from the organisation or are replaced. Some banks will require minutes of the meeting which reflect this change. Failure to do so could mean payments are put on hold, or your account is blocked, whilst this information is checked.
- Changes to your organisation’s officers such as the chair, finance person/treasurer, secretary, or trustees.
- You will need to update the bank if these people move on from the organisation or are replaced. Ongoing checks from the banks means they have a regulatory requirement to ensure these records are kept up to date.
- Changes of contact details or address for your organisation, authorised users, officers or signatories.
- When someone moves home or changes their contact details, you will need to keep your bank updated, so they can contact the correct person when needed (this includes address, email address, and phone number). There may be delays to your account service (for example, payments) if your bank cannot verify who you are or contact you.
- Your bank must be told when your organisation address changes, so they can ensure all important bank account information is sent to the correct address. Having the incorrect address listed on your account may result in you missing important account information or requests, which could result in your account being paused.
Changes to account usage
If your account activity changes suddenly, it may trigger “flags” on your bank’s internal systems. This will vary from bank to bank and differ depending on your account’s previous activity. Some examples of triggers are given below.
Triggers are most likely to occur if there is abnormal activity on the account, or when your activity does not match that which was set out when you opened your account (as well as inconsistencies regarding personnel and organisation information, as listed above).
When a trigger occurs, your account may be paused without explanation whilst the matter is investigated by your bank. It is therefore of huge importance to keep in regular contact with your bank about how your account is being used and who is associated with it. Your bank may not be allowed to explain what has caused the trigger for legal reasons. For more information please see The Financial Conduct Authority, The National Crime Agency and Anti Money Laundering requirements.
To ensure your account continues to run smoothly, it may be useful to contact your bank and notify them ahead of time if:
- A large sum of money is going to be withdrawn
- This will likely be necessary if it is substantially over and above how much you usually withdraw. Your bank may ask further questions on how it is being spent.
- A large sum of money is going to be deposited
- This will likely be necessary if it is substantially over and above how much you usually deposit, or if it is from an unknown person or entity. Your bank may ask further questions on where it has come from (sometimes called Source of Funds).
- If money is being sent or received from abroad
- This especially applies to countries, or organisations or persons in them, who are deemed high risk or may have been subject to financial sanctions. In some instances, it may just include countries your organisation has not previously operated in. (The links above are specifically for organisations operating in England and Wales however are also applicable to Northern Ireland and Scotland).
- Trustees of charities should be aware of their legal duties and responsibilities in the management and administration of their charity once it is set up.
Your obligations as a trustee
Trustees have a legal duty to:
- act in the charitable organisation’s best interests
- manage the resources responsibly
- act with reasonable care and skill.
Trustees of charities should be aware of their legal duties and responsibilities in the management and administration of their charity once it is set up. You can follow this link to the Charity Commission Compliance toolkit which sets out useful guidance on the due diligence required when running a charity. A lot of the checks you are required to do for any received donations will be mirrored to your chosen bank’s obligations. The Charity Commission for Northern Ireland also has Running Your Charity guidance. Provide updates when submitting your annual return.
Why do banks ask these questions?
Banks are required to assess and monitor the identity of individuals involved in a charity or voluntary group when an account is opened and throughout the life of the account. The questions enable banks to support charities, protect trustees and help them meet their legal duty. The questions may seem intrusive but are necessary. By law, banks must establish the legitimacy of a customer’s identity and identify any new or ongoing risk factors – this is called Know Your Customer (KYC).
KYC standards are designed to help prevent fraud, corruption, money laundering and terrorist financing. KYC involves actions to identify customers, understand the nature of customers’ activities and determine that the source of funds is legitimate. They also assess money laundering risks associated with the customer’s activities. As part of KYC, further due diligence reviews are likely to be conducted through the life of the account.
Banks will have varying approaches to communicating with customers when they have concerns and require information or evidence to confirm that account operation is legitimate.
Banks seek to have dialogue with customers when they have concerns and require information or evidence to confirm that account operation is legitimate. It is important to respond to all bank requests for information in a timely manner, to ensure the account continues to run smoothly.