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2026
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Disclaimer
This article is for informational purposes only and does not constitute investment, tax, or financial advice. Brokerage policies change frequently and individual circumstances vary. Verify current policies directly with your brokerage before making decisions. Consult a qualified financial advisor with expat expertise before acting on the information below.
If you are an American living abroad and received a letter from your brokerage saying your account is being closed, you are not alone. Since late 2024, a wave of US financial institutions have been terminating or severely restricting accounts held by American expats. Expat financial planners have dubbed it the “Great Expat Closure” — and it is the single biggest financial disruption facing the estimated nine million Americans living overseas.
This guide covers which brokerages are closing accounts and why, which firms still serve expats, exactly what to do if your account is being shut down, the PFIC trap that prevents you from simply opening a local brokerage abroad, and long-term solutions to protect your investments across borders.
What Is Happening: The Great Expat Closure
Starting in late 2024 and accelerating through 2025, a broad sweep of US financial institutions began sending letters to American clients living outside the United States, notifying them that their brokerage accounts would be closed or severely restricted. This was not one firm making a policy change — it was an industry-wide shift driven by converging regulatory pressures.
The scale is significant. Morgan Stanley, Fidelity, Merrill Lynch, Ameriprise, TIAA, Edward Jones, USAA, UBS, and many smaller broker-dealers have all taken action. Some firms closed all brokerage accounts for non-US residents outright. Others restricted trading to liquidation-only (you can sell but not buy). Others required very high minimum account values — $1 million or more — for non-resident clients to remain. The common thread: if you have a foreign address on file, your brokerage likely considers you a compliance liability.
The timing was not coincidental. Several regulatory threads converged simultaneously:
FinCEN’s Investment Adviser AML Rule
In late 2024, the US Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized rules placing investment advisers under the same stringent Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) requirements that previously applied only to banks. While FinCEN later postponed the effective date to January 2028, the announcement itself triggered immediate compliance reviews across the industry. Firms began scrubbing their client lists for accounts that would be difficult or expensive to monitor under the new rules — and foreign-address clients topped the list.
Vanguard’s Platform Migration Trigger
Vanguard announced it would shut down its legacy mutual fund platform by end of 2025, forcing all clients to migrate to its newer brokerage platform. The migration triggered mandatory Know Your Client (KYC) reviews. Expats who had quietly maintained accounts with a US address for years were suddenly flagged when the new platform’s compliance systems detected foreign IP addresses, foreign phone numbers, or address mismatches. Accounts that could not provide a legitimate US residential address were frozen and forced to liquidate or transfer out.
FATCA Compliance Costs
The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, has been steadily raising compliance costs for financial institutions dealing with clients abroad. The reporting requirements under FATCA — combined with the patchwork of securities regulations across 200+ countries — make non-resident accounts disproportionately expensive to maintain. For many firms, the compliance cost of keeping a $200,000 expat account exceeds the fee income it generates. The business math finally tipped against expats.
Enhanced Compliance Technology
Newer trading platforms include “smarter” compliance logic that automatically flags foreign IP addresses, VPN usage, and foreign phone numbers. Expats who previously flew under the radar — perhaps using a family member’s US address — found themselves caught in automated sweeps. Many received account restriction notices with little warning and tight deadlines.
Which Brokerages Are Closing Expat Accounts
The following table summarizes the current status of major US brokerages for American expats. Policies change frequently — always verify directly with your provider before making decisions.
| Metric | Brokerage | Status |
|---|---|---|
| Vanguard | Closing accounts for non-residents. Platform migration triggers KYC review; foreign address = forced liquidation. | Closed to expats |
| Fidelity | Blocks new mutual fund purchases for non-residents. Existing ETF holdings may remain but no new purchases in many countries. | Severely restricted |
| Morgan Stanley | Sending closure letters to US citizens with foreign addresses. Most non-resident accounts being terminated. | Closing accounts |
| Merrill Lynch | Sending closure letters to non-resident clients. Full account termination in most cases. | Closing accounts |
| Edward Jones | Does not serve clients with foreign addresses. Existing accounts being closed upon address update. | Closed to expats |
| Ameriprise | Restricting or closing non-resident accounts. Some high-value clients retained with additional compliance. | Mostly closed |
| TIAA | Restricting brokerage services for non-residents. Retirement accounts may be retained with limitations. | Restricted |
| USAA | Reduced services for members abroad. Some brokerage functions restricted based on country of residence. | Restricted |
| UBS | High minimum requirements for non-US residents ($1M+). Smaller accounts being closed. | High minimums only |
| Schwab International | Actively serves US expats. $0 minimum (waived 2025). 100+ countries. Zero-commission US stocks/ETFs. | Open — expat-friendly |
| Interactive Brokers | Full access in 200+ countries. Multi-currency. Low-cost. The most accessible platform for expats globally. | Open — expat-friendly |
The picture is stark: out of the major US brokerages, only Schwab International and Interactive Brokers (IBKR) reliably serve American expats. Everyone else is either closing accounts, restricting services, or requiring minimum balances that exclude most investors.
Which Brokerages Still Serve American Expats
Two brokerages stand out as viable long-term options for US citizens living abroad. Here is a detailed comparison:
Interactive Brokers (IBKR)
Interactive Brokers is the gold standard for expat investing. It serves clients in over 200 countries and territories, offers multi-currency accounts, access to 150+ global exchanges, and some of the lowest trading costs in the industry. Key advantages for expats:
- Global coverage: Available in 200+ countries. If you relocate, your account moves with you seamlessly.
- Multi-currency: Hold and convert between 20+ currencies at interbank rates. No forced USD conversion.
- Low costs: $0 commission on US stocks (IBKR Lite) or tiered pricing starting at $0.0035/share (IBKR Pro).
- No minimum deposit: $0 to open (IBKR Lite). IBKR Pro has no minimum either but previously required $10,000.
- Account portability: Unless you move to a sanctioned country, your account continues uninterrupted.
- Tax document support: Provides 1099s for US tax filing and can report to multiple jurisdictions.
The main downside: Interactive Brokers’ platform has a steep learning curve compared to consumer brokerages like Fidelity or Vanguard. The Trader Workstation interface is designed for active traders, not passive index investors. Their mobile app and web portal have improved significantly, but it still requires more setup than a simple three-fund portfolio at Vanguard.
Charles Schwab International
Schwab International serves US expats and non-US residents in 100+ countries. Following the TD Ameritrade merger, Schwab consolidated its international services under a dedicated division. Key advantages:
- $0 minimum: The previous $25,000 minimum was waived in 2025. You can now open with any amount.
- Zero-commission trading: $0 on US-listed stocks and ETFs. No foreign settlement fees on US securities.
- US-based customer service: Phone support with dedicated international team. Better service experience than IBKR for most retail investors.
- Familiar interface: Standard Schwab platform, easy transition if you are coming from another US brokerage.
- Checking account: Schwab International includes a checking account with unlimited ATM fee rebates worldwide — a huge perk for expats who need local currency access.
The downside: Schwab International is not available in all countries. Certain countries are restricted due to US sanctions or local regulations. Notably, residents of some EU/EEA countries may face restrictions on purchasing certain US-domiciled ETFs due to the EU’s PRIIPs regulation (which requires Key Information Documents that US funds do not provide). If you want to trade on non-US exchanges, Schwab charges $50 per trade — making it unsuitable for international diversification through foreign-listed securities.
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Compare tax rates in your destination countryWhat to Do If Your Account Is Being Closed
If you have received a closure notice — or suspect one is coming — act quickly and methodically. Here is the step-by-step process:
Step 1: Read the Notice Carefully
Determine the exact timeline. Most brokerages give 30–90 days to transfer or liquidate. Note whether the notice says “account closure” (full termination) or “service restriction” (reduced functionality). Some firms restrict trading to liquidation-only while keeping the account open for transfers.
Step 2: Open a New Account at IBKR or Schwab International
Do this immediately — before you do anything else. Account opening can take 1–3 weeks depending on the platform and your country of residence. You will need:
- Valid passport or government ID
- Proof of current foreign address (utility bill, bank statement, or lease)
- US Social Security Number or Individual Taxpayer Identification Number
- W-8BEN or W-9 form (the brokerage will guide you through this)
Step 3: Initiate an ACATS Transfer (Do Not Liquidate)
This is critical: transfer your positions in-kind via ACATS (Automated Customer Account Transfer Service). Do not sell everything and move cash. Liquidating triggers capital gains taxes on every appreciated position. An in-kind transfer moves your shares directly from one brokerage to another with no tax event.
Initiate the transfer from the receivingbrokerage (IBKR or Schwab). They will pull the assets from your old account. The process typically takes 5–10 business days. Some things to watch for:
- Mutual funds may not transfer. Most mutual fund shares cannot be held at a different brokerage. Convert mutual funds to their equivalent ETFs before initiating the transfer (e.g., VTSAX → VTI, VTIAX → VXUS). This conversion is a taxable event at Vanguard, but most fund-to-ETF conversions at Vanguard are done as a tax-free exchange. Check with your provider.
- Fractional shares will be liquidated. ACATS only transfers whole shares. Any fractional shares will be sold and the cash transferred.
- Cost basis transfer. Confirm that cost basis information transfers correctly. Request a cost basis statement from your old brokerage before the transfer completes as a backup.
Step 4: Verify Retirement Accounts Separately
IRAs (Traditional, Roth, SEP) require a separate trustee-to-trustee transfer, not a standard ACATS. Both IBKR and Schwab accept IRA transfers. If your current provider is closing your IRA, you generally have 60 days to complete a rollover before it becomes a taxable distribution. Do not miss this deadline — an unintended distribution from a Traditional IRA triggers income tax plus a 10% early withdrawal penalty if you are under 59½.
Step 5: Update Beneficiaries and Linked Accounts
After the transfer, update beneficiary designations on your new account, set up any automatic investment plans, and link your bank accounts for future deposits. Also update your records with any financial advisor, tax preparer, or estate attorney.
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Read our full guide to expat investment accountsThe PFIC Trap: Why You Cannot Just Open a Local Brokerage
When faced with a US brokerage closure, the natural instinct is to open an account at a local brokerage in your country of residence. For a British citizen in the UK, this makes perfect sense. For an American citizen in the UK, it is a tax catastrophe — because of PFIC rules.
What Is a PFIC?
A Passive Foreign Investment Company (PFIC) is any non-US pooled investment vehicle. This includes every mutual fund, ETF, index fund, and investment trust that is domiciled outside the United States. A Vanguard fund registered in Ireland? PFIC. An HSBC mutual fund offered in Hong Kong? PFIC. A Nutmeg portfolio in the UK? Every underlying fund is a PFIC. The definition is broad and catches virtually every investment product available at a non-US brokerage.
Why PFIC Taxation Is Punitive
The IRS designed PFIC rules to discourage Americans from investing in foreign funds (which the IRS cannot easily audit). The “excess distribution” regime works like this:
- When you sell PFIC shares or receive certain distributions, the gain is allocated across all years you held the investment.
- Each year’s allocated portion is taxed at the highest marginal rate for that year (currently 37% federal).
- An interest charge is added for the “deferral benefit” of not having paid tax in prior years.
- You must file Form 8621 for every PFIC holding, every year. Penalty for not filing: $10,000 per fund per year.
The combined effect: effective tax rates of 50% or more on investment gains in foreign funds, compared to 15–20% on the same gains in US-domiciled funds. A $100,000 gain that would cost you $15,000–$20,000 in a US fund could cost $50,000+ in a foreign fund. This is not a theoretical risk — it is the mathematical reality of PFIC taxation.
The QEF Election Workaround (Usually Impractical)
A Qualified Electing Fund (QEF) election can avoid the punitive excess distribution rules, but it requires the foreign fund to provide you with an annual PFIC statement containing specific information the IRS requires. Most foreign fund managers have no idea what this is, do not provide it, and will not create it for one American client. The QEF election is theoretically available but practically impossible for retail investors.
The bottom line: as a US citizen abroad, you must invest through a US brokerage in US-domiciled funds. There is no practical workaround. This is why the brokerage closure wave is so damaging — it removes access to the only investment channel that does not trigger punitive taxation.
Calculate your FIRE number abroad
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Calculate your FIRE number abroadCountry-Specific Considerations
Your country of residence affects which brokerage you can use and what restrictions you face. Here are the key considerations for popular expat destinations:
United Kingdom
UK-resident US citizens face a specific challenge: the EU/UK PRIIPs regulation requires that investment products sold to retail investors include a Key Information Document (KID). US-domiciled ETFs do not produce KIDs, so UK platforms cannot sell them to you. However, Schwab International and IBKR can — because they operate as US brokerages, not UK platforms. This is a critical distinction: use a US brokerage, not a UK one, even for US-listed ETFs.
The UK’s ISA (Individual Savings Account) provides tax-free growth in the UK but is not recognized by the IRS. Any gains in an ISA are fully taxable on your US return. The reporting burden (FBAR, FATCA Form 8938) often exceeds any UK tax benefit. Stick to US-domiciled funds through IBKR or Schwab.
European Union
The PRIIPs/KID issue applies across the EU. Retail investors resident in EU countries generally cannot purchase US-domiciled ETFs through European brokerages. This makes IBKR and Schwab International essential — they are the legal pathway for US citizens in the EU to buy US funds.
Some EU countries (France, Germany, Netherlands) have tax-advantaged accounts (PEA, Riester, etc.) that are not recognized by the IRS. Using these accounts as a US citizen creates reporting complexity with no US tax benefit. Country-specific tax treaties may affect how investment income is treated — consult a cross-border tax advisor.
Singapore
Singapore does not tax capital gains and has no dividend withholding tax for residents. This makes it one of the most tax-efficient locations for US citizen investors — on the local side. You still owe US taxes on worldwide income, but the Foreign Tax Credit calculation is more favorable in Singapore since there is less local tax to offset. Both IBKR and Schwab International serve Singapore residents. Local brokerages like DBS Vickers and POEMS are available but would expose you to PFIC rules on any non-US funds purchased through them.
Hong Kong
Hong Kong also has no capital gains tax. IBKR has a strong presence in Hong Kong and provides full access to US markets. Schwab International also serves Hong Kong residents. The main risk is geopolitical — some US expats in Hong Kong are concerned about potential future restrictions given evolving US-China relations. From a pure brokerage-access standpoint, Hong Kong remains one of the easier places to maintain US investments.
Middle East (UAE, Bahrain, Qatar)
Zero-income-tax countries in the Gulf are popular with American expats partly for investment reasons. With no local tax on investment gains, and FEIE/FTC reducing your US tax liability on earned income, the net tax burden on investments can be lower than living in the US. Both IBKR and Schwab serve most Gulf countries. Avoid insurance-wrapped investment products aggressively marketed in the region — they are almost always PFICs with high fees. See our investment accounts guide for details on the insurance wrapper trap.
Latin America (Mexico, Costa Rica, Colombia)
Both IBKR and Schwab International serve most Latin American countries. Local tax treatment of foreign investments varies widely — Mexico taxes worldwide income for residents, Costa Rica is territorial (foreign-source investment income is not taxed locally), and Colombia taxes worldwide income with a credit mechanism. Your choice of country significantly affects your total tax burden on investments. Use our tax comparison tool to model the differences.
Southeast Asia (Thailand, Vietnam, Indonesia)
IBKR serves most Southeast Asian countries. Schwab International coverage varies — check their restricted countries list for your specific location. Thailand recently began enforcing worldwide income taxation for residents (previously only remitted income was taxed), which changes the calculus for US expats there. Vietnam and Indonesia have more complex regulatory environments but IBKR access remains reliable from both.
What About Using a US Address?
Many expats have historically used a family member’s US address on their brokerage accounts to avoid detection. This worked for years but is increasingly risky:
- Compliance systems have improved. Brokerages now cross-reference IP addresses, phone numbers, and login patterns. Logging in consistently from a foreign IP while listing a US address raises red flags.
- VPNs are detectable. Many brokerages can identify VPN traffic and may flag or restrict accounts that appear to be masking their true location.
- It may constitute fraud. Providing a false residential address to a financial institution could be considered fraud under federal law. The risk is low for any single individual, but it is a real legal exposure.
- Tax implications. Some states tax investment income of “residents.” If you claim to reside in a US state on your brokerage forms, that state may come after you for state income tax on your investment gains.
The safer approach: use a brokerage that explicitly serves expats (IBKR or Schwab International) and provide your actual foreign address. It is better to have a compliant account at a firm that wants your business than to hide at a firm that would close your account if they knew where you actually lived.
Long-Term Solutions and Best Practices
Build Your Investment Infrastructure Before You Move
If you are planning a move abroad, set up your investment accounts before you leave. Open accounts at both IBKR and Schwab International while you still have a US address — having two brokerages provides redundancy if one changes its policies. Convert any mutual fund holdings to equivalent ETFs (VTSAX → VTI, VTIAX → VXUS, VBTLX → BND). Update your address to your foreign location after you have verified that both accounts function correctly from abroad.
Keep Your Portfolio Simple
A three-fund portfolio (US total market, international, bonds) held at one or two US brokerages is ideal for most expats. Every additional account, fund, or jurisdiction adds tax complexity and reporting requirements. Your CPA bill increases with every financial institution that sends you a different form. Simplicity saves money on both the fee side and the compliance side.
Maintain a US Bank Account
Even if your brokerage account survives, you need a US bank account to fund it. Most US banks also restrict non-resident accounts, but Schwab (linked to their brokerage) and some credit unions are more accommodating. Having a US bank account also helps with receiving US Social Security payments, tax refunds, and other domestic financial transactions. See our complete expat banking guide for details.
File Your Taxes Correctly
Proper tax filing protects your accounts. Brokerages are increasingly sharing data with the IRS through FATCA and information exchange agreements. An account that is properly reported on your FBAR, FATCA (Form 8938), and tax return is an account that is less likely to trigger compliance concerns. Use an expat-specialized CPA or tax service — general US tax preparers often lack the expertise for international reporting.
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FEIE vs Foreign Tax Credit: which saves you more?Consider the Bigger Financial Picture
The brokerage closure wave is a reminder that your country of residence affects every aspect of your financial life — not just daily expenses. When evaluating where to live abroad, consider investment access, banking infrastructure, tax treaties with the US, and regulatory stability alongside the usual factors like cost of living, safety, and quality of life. A country that is cheap to live in but creates a financial infrastructure nightmare may not be the bargain it appears.
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Compare countries across every dimensionTimeline: What Happens Next
The regulatory environment is still evolving. Key dates and trends to watch:
- January 2028: FinCEN’s Investment Adviser AML Rule is now scheduled to take effect (delayed from January 2026). When it does, investment advisers will face the same AML/KYC requirements as banks, potentially triggering another wave of non-resident account reviews.
- Ongoing: FATCA intergovernmental agreements (IGAs) continue to expand, increasing cross-border information sharing between tax authorities. More brokerages may tighten non-resident policies as compliance costs rise.
- Potential legislation: Bills to reform FATCA or simplify expat taxation have been introduced in Congress repeatedly but have not passed. The Residence-Based Taxation proposal would exempt foreign-resident Americans from US tax on foreign-source income — which would eliminate many of the compliance concerns driving brokerage closures. Do not hold your breath, but it remains the long-term policy solution.
Related Financial Guides for Expats
- Investment Accounts for US Expats: Fidelity, Schwab & IBKR Restrictions — complete guide to expat investment accounts and strategies
- FEIE vs. Foreign Tax Credit — which tax strategy saves you more money abroad
- Tax Optimization Strategies for Expats — structure investments for minimum tax
- Complete Guide to Expat Banking — managing money across borders
- FIRE Abroad: Retire Early in a Low-Cost Country — geo-arbitrage strategies and country rankings
Frequently Asked Questions
Can I keep my US brokerage account if I move abroad?▾
It depends on the brokerage. Most major US brokerages (Vanguard, Fidelity, Morgan Stanley, Merrill Lynch) are closing or severely restricting accounts for non-residents. Interactive Brokers and Charles Schwab International are the two reliable options that explicitly serve US expats. Open an account with one of them before or immediately after your move.
What should I do if my brokerage is closing my account?▾
Act immediately: open an account at Interactive Brokers or Schwab International, then initiate an ACATS in-kind transfer to move your positions without selling. Do not liquidate into cash — selling triggers capital gains taxes. Convert any mutual funds to equivalent ETFs first, as mutual fund shares may not transfer between brokerages.
Can I just open a local brokerage in my country of residence?▾
As a US citizen, this is almost always a bad idea. Any non-US fund you purchase through a local brokerage is classified as a PFIC (Passive Foreign Investment Company) and subject to punitive US taxation — effective rates of 50% or more on gains. You must invest through a US brokerage in US-domiciled funds to avoid PFIC rules.
Is it safe to use a family member's US address on my brokerage account?▾
This strategy is increasingly risky. Brokerages now cross-reference IP addresses, phone numbers, and login patterns. Using a false address could constitute fraud under federal law and may create state tax liabilities. The safer approach is using a brokerage that explicitly serves expats (IBKR or Schwab International) with your actual foreign address.
What is the difference between Interactive Brokers and Schwab International?▾
IBKR covers 200+ countries with multi-currency accounts and access to 150+ exchanges — best for expats who may move between countries. Schwab International covers 100+ countries with zero-commission US trading and a linked checking account with global ATM rebates — better customer service and simpler interface. Both have $0 minimums. Many expats maintain accounts at both for redundancy.
Will the brokerage closures eventually stop?▾
Unlikely in the near term. The regulatory trends driving closures (FinCEN AML rules, FATCA compliance costs, enhanced KYC technology) are intensifying. Legislative reform like Residence-Based Taxation could reverse the trend but has not passed Congress. Plan for a world where IBKR and Schwab International are your only reliable options.
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