Banking and the Patriot Act
There is NO provision in the Patriot Act, not any US law or regulation, which prohibits banks from accepting clients who do not live in the US. However, US banks are looking at the increased diligence provisions in the Patriot Act and using this guidance to remove clients who are too difficult to assess. Lack of a US residential address along with lack of US utility bills to support proof of residency is one of the common requirements that many US banks are requesting in order to open or maintain US based accounts. It is a private bank decision as to what documentation they will accept in order to open or maintain a US based account.
The US Treasury Department has offered to help citizens who have problems with account closures at US banks. If you are notified of account closure of an existing account by a US national bank (i.e. not a “local” bank), you can file a complaint with the Customer Assistance Group of the Treasury Dept. www.occ.treas.gov/customer.htm . You should also consider filing a complaint with the Consumer Finance Protection Bureau www.consumerfinance.gov/complaint and the Federal Reserve https://www.federalreserveconsumerhelp.gov/complaint/formcomplaint.cfm
ACA, Inc. as well as the Congressional Americans Abroad Caucus are very interested in getting feedback from people who use these resources. And also, ACA, Inc. recommends that you write your own representative in Congress about your banking problems.
As a service to members, ACA is now offering access to the State Department Federal Credit Union which accepts overseas Americans as customers.