LETTER from The Treasury regarding UK Bank Accounts for expatriates
Non-residents (`ex-pats`)
UK nationals who are resident abroad and who do not have an address in the UK sometimes experience difficulties in gaining access to domestic banking services. There are no legal or regulatory barriers to banks providing services to non-residents, but many banks and building societies have decided not to do so, on commercial not regulatory grounds. I understand that they are driven chiefly by concerns about fraud prevention and additional administrative requirements in dealing with people living abroad. The number of banks and building societies prepared to offer services is small.
Consumers may find it helpful to know that while the Government cannot offer a referral service to help non-residents, the British Bankers Association has begun to offer an account finder service through its website at It is intended to help those who have difficulty in finding a suitable onshore account.
Money-laundering (identification) checks
It is reported that some customers continue to experience difficulties meeting identification requirements. It is important that banks should identify their customers for their own commercial purposes as part of the fight against financial crime. We also recognise that the measures taken need to be proportionate to the risks posed and avoid unnecessary intrusion, as well as being effective.
The requirements on firms to identify customers were originally introduced by the Money Laundering Regulations 1993. Those requirements were updated by the money laundering Regulations 2003, and were further updated in 2007.
However, the Regulations are not prescriptive, instead setting high-level objectives for businesses to meet. It is for them to decide how to interpret the Regulations. Each will have their own policies on identification, and on the circumstances in which other checks should be undertaken. Government does not prescribe those detailed policies. To help banks and other financial firms make such policies they are assisted by the availability of guidance. For the financial institutions, this is the Joint Money Laundering Steering Group (JMLSG) guidance notes. The Chancellor approved a revised set of these notes at the end of 2007.
The Government encourages financial institutions to adopt a risk-based approach to customer checks and to follow the JMLSG Guidance Notes, or, where appropriate, other guidance. The JMLSG Guidance Notes encourage firms to act reasonably where, for example, customers do not have passports or driving licenses, or where customers experience difficulties in managing their own affairs. Driving licenses and passports are useful, and banks and other institutions may ask for them as they are the most commonly encountered documents, but our Regulations do not require banks to demand sight of them, and the guidance encourages them to consider a wide range of other evidence.
Under the signature of
Sarah McCarthy-Fry, MP Exchequer Secretary to the Treasury
11th August 2009.