Reports are starting to emerge of US banks closing the domestic accounts of US persons living in the European Union. US and Canadian citizens living in Europe need to keep a close eye on the situation.
One IL reader in the EU, who wishes to remain anonymous, said:
I got a letter from JP Morgan Chase, and it basically said, because of this new ruling, we're closing your accounts. You have until December 1st to close them yourself, or we will close them for you. So I immediately called them, because I have both checking and credit cards, and I said, I look up the law, there's a grandfather clause in there. My accounts are 5 to 10 years old. Why aren't you honouring the grandfather clause? And they said, “we're doing more research on it.”
The issue is the European Union’s Sixth Capital Requirements Directive (CRD VI), particularly Article 21c. Its restrictions on non-EU banks providing banking services to EU customers take effect on 11 January 2027. The new rules say that banks that don’t have branches in the EU may not provide banking services to EU residents, even if they are citizens of a non-EU country.
The problem is “grandfathering”— whether non-EU banks can continue to offer account services to people who were clients before they became EU resident.
The EU’s official position is that they can. But US banks—always skittish about serving non-resident clients, even if they are US citizens—are starting to close older accounts anyway. The clearest example is JPMorgan Chase, which has begun notifying American expatriates in Europe.
In September, The Local reported that numerous American residents of Spain and Italy had received letters from US banks warning about potential account closures. On 15 October, an American living in Germany reported on Reddit about receiving an email from Chase stating that the bank would close his account from January 2027. The customer had maintained US accounts while living in Germany and used them to pay American credit cards and student loans.
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On 21 October, The Connexion, an English-language newspaper serving foreign residents in France, reported that Chase customers had begun receiving account closure notices on 1 October. American Citizens Abroad, an expatriate advocacy organisation, reported hearing from approximately 80 Americans in France about the issue. Chase was the only bank identified in those reports.
These reports are significant because Chase previously allowed customers to maintain US accounts with European residential addresses. The new closures therefore affect established banking relationships, not just people attempting to open accounts after relocating abroad.
To be clear, the EU legislation doesn’t require foreign banks to close all accounts belonging to EU residents. Under Article 21c, foreign banks need a European presence to provide core banking services, including deposit-taking, lending and financial guarantees. But there are two exceptions:
Grandfathering: Accounts opened before 11 July 2026 are exempt.
Reverse solicitation: EU residents who approach a foreign bank on their own initiative may still receive covered services without the bank maintaining an EU branch.
The problem is that US banks will make these decisions based on their assessment of commercial and regulatory risk, not on whether EU law allows them to keep offering account services. Grandfathering provisions don’t compel a bank to maintain an account.
If you are living in EU—or planning to relocate there soon—the immediate priority is to establish whether your bank will continue servicing your accounts using your European residential address. If you have a valid residential address already, such as a relative or friend, you should be OK. But if you don’t have one, you need to act now.
A word of warning: be cautious of virtual mail drop companies. Many people swear by them. But the US Postal Service maintains a database of these companies, which they share with banks. If your bank finds out your so-called residential address is a mail drop, they’ll close your account without warning.
What if worse comes to worse, and your US bank says ciao, auf wedersehen, adeus? Here are some solutions:
Open an account at the State Department Federal Credit Union (SDFCU). Members of American Citizens Abroad, the Association of Americans Resident Overseas, and dozens of other voluntary associations qualify for an SDFCU account, which is designed explicitly for expats. FDFCU has explicitly said that it will continue offering account services after January.
Apply for an account a bank with an EU presence, like Citibank or HSBC. But such banks tend to require relatively high account balances for Americans living outside the country.
Open account at Wise.com, Revolut, or another money transfer platform. Although these aren’t banks per se, they provide accounts in multiple currencies that can be used to pay bills, including in the US. They also provide a debit card which you can use anywhere in the world. The downside is that they don’t pay interest.
The solution you ultimately adopt will depend on a number of factors. One to keep in mind is that services like Zelle, Venmo, PayPal and other e-finance platforms don’t work with all banks. If you depend on these services, make sure you ask up front whether they offer them.
What about my correspondent in the EU? How has she solved the problem?
Initially I asked Chase to let me know by email when they had finished considering the question of grandfathered accounts. They said they would, but never did. So I called customer service. They said ‘I've checked your accounts, you're going to be fine, your accounts won't be closed.’ I said, okay, what's changed? And she said, as long as you have had at least one transaction in each account over the last two months and you're continuing doing business with us, we won't close your accounts. I asked them to put that in writing for me. He refused, saying ‘you can take my word for it.’ And right now, I am taking their word for it, because what's the other option, right?
I’ll be keeping a close eye on this situation for you, so stay tuned.
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