Banks by Jurisdiction: Private Banking and Accounts

Concept

A bank is not a brand. It is a bundle of three independent variables, and this domain exists to keep them apart. The first is the licence held by one specific legal entity: deposit protection, the right to lend out deposits and access to clearing all attach to a licence rather than to a group logo, and large UK groups are required outright to ring-fence retail banking into a separate entity with its own board and its own authorisation. The second is the booking centre — the jurisdiction and entity through which the account is actually opened. The booking centre fixes governing law and competent court, regulator, guarantee scheme, the ranking of the client's claim in insolvency, transaction taxes and the address from which automatic exchange reporting departs. The third is the client's own sanctions and compliance profile: passport, residence, beneficial owners and origin of capital.

Hence the rule of the domain: a bank is chosen by booking centre, licence and client profile, not by brand. One logo in Zurich, Singapore and Dubai means three contracts, three regulators and three different answers to "will they take me". After 2022 Swiss booking centres capped deposits of Russian persons at CHF 100,000, with an exception for holders of Swiss or EU residence permits; the same bank booking in Singapore knows no such cap. That is a constraint of the platform, not of the brand.

Boundaries. Inside the domain sit deposit-taking institutions and everything that makes them deposit-taking: the licence, deposit guarantee, access to clearing, the compliance cycle and the mechanics of exit. Outside sit brokerage and investment platforms, insurance wrappers, managers without a balance sheet of their own, and the family office as a governance form — it coordinates capital rather than holding it on its own licence.

Section map: the questions readers bring most often and the cluster pages that answer them.

The remaining country shelves and the head-to-head platform comparisons are collected in the map of jurisdictions and under canonical owners below.

The Repeating Model: Licence → Booking → Protection → Compliance → Exit

A personal account, a company's settlement perimeter, a trust or fund account, a private mandate — every object in this domain runs through the same five steps. Analysing any particular bank or jurisdiction reduces to how it performs at each one.

Licence. A bank takes deposits onto its own balance sheet, lends out of those funds and holds a direct correspondent account at the central bank. A neobank operating under an e-money or payment institution licence has none of the three rights: it holds client money segregated at a partner bank and reaches clearing through a correspondent — that layer is set out in correspondent banking and safeguarding, and its infrastructure supply side in the Clear Junction profile. A digital format does not rule out a full licence: the eight virtual banks of Hong Kong operate under HKMA licences with ordinary deposit protection, in the United States non-financial groups enter the deposit perimeter through the industrial loan company charter, and in Georgia Hashbank operates under an NBG digital licence with the same 50,000 GEL deposit insurance as TBC and Bank of Georgia.

Booking centre. Choosing the platform is the second decision after choosing the institution, and in consequence often the heavier of the two. It sets the law of the contract, the regulator, the insolvency regime and the product shelf; moving a booking is a separate event with a tax price and a list of instruments that physically will not travel.

Protection of funds. The central fork of the domain is deposit insurance versus custody segregation — two different mechanisms, not two versions of one. Cash on account is an unsecured claim on the bank, covered by a guarantee scheme only up to a limit: FSCS at £120,000 since 1 December 2025, esisuisse at CHF 100,000, national EU schemes at €100,000, SDIC at S$100,000, Hong Kong's DPS at HK$800,000, FDIC at US$250,000. Securities work the other way round: they sit outside the bank's balance sheet and return to the owner past the insolvency estate — the cost of the question lies in the length of the custody chain and in whether securities lending and rehypothecation have been signed. The mechanics are set out in securities custody, and the European settlement nodes that chain runs through in Euroclear and Clearstream. The practical conclusion for large capital: keep the cash buffer minimal and hold the rest in securities.

Compliance cycle. Onboarding is built around two separate questions — where the wealth came from and where these particular funds came from. Both are closed with documents rather than declarations, and both are set out in source of funds evidence and in AML/KYC for the private client. Discipline here has tightened in measurable ways: in July 2025 MAS imposed composition penalties totalling S$27.45m on nine institutions precisely for failures to corroborate source of wealth. A corporate pack needs an apostille obtained in advance; without one, European and Asian banks will not accept the documents at all. The account carries no confidentiality towards tax authorities: CRS transmits data to the country of residence automatically, FATCA runs in parallel for US indicia, and Russian currency residents separately notify the tax authority of a foreign account. Sanctions screening runs against UN, OFAC, EU and UK lists, the bank's own internal restrictions and national registers such as the list of jurisdictions designated unfriendly by Russia; a separate layer of control covers over-the-counter crypto settlement. An account for a structure is opened not by the beneficiary but by a trustee or administrator, and the chain is unwound to the ultimate owner regardless.

Exit. Relationships end more often than they are planned to, and the exit framework has densified over the past two years: in the United Kingdom the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 require, from 28 April 2026, ninety days' notice and detailed reasons on new accounts, while the Court of Justice of the EU in Case C-81/24 of 11 June 2026 barred refusal of a basic account for the sole reason that the client appears on a third country's restrictive-measures list, absent an individual risk assessment. Notice periods, appeal routes and the economics of transferring a portfolio are covered in bank account closure.

The Decisions That Matter

Operating account or capital account

The first fork removes half the options. An operating perimeter — payments, multi-currency receipts, acquiring, trade finance — is measured by speed, conversion cost and the reliability of the correspondent chain; deposit protection barely applies, because the balance is transitory by design. A capital account is measured by the opposite: insolvency regime, quality of custody, access to lending against the portfolio and the horizon of the relationship. Combining the two in one institution turns out expensive, and the working construction is a settlement bank on one side, a deposit and investment perimeter on the other. The personal side of this fork is set out in personal accounts abroad, the China trade side in payments and trade with China and in CNY settlement.

Client residence or booking jurisdiction

The second fork is confused more often than any other. Residence determines where reporting goes and where tax arises; the booking jurisdiction determines the law of the contract and the protection regime. They need not coincide, and usually do not. Changing residence changes the first and does not solve the second: Spain's Beckham regime, digital nomad visas and Malta's Global Residence Programme deliver a status and a tax frame, but no account opens automatically on the strength of them — the bank still looks at source of capital and at the economic logic of the client's link to the jurisdiction. The mirror-image mistake also costs money: the EU right to a basic account under Directive 2014/92/EU belongs to consumers legally resident in the Union and does not reach a non-resident without a permit.

Bank or EMI

The third fork is about what backs the money, and on three parameters the two institutions part ways.

An electronic money institution wins on speed, multi-currency accounts and cheap conversion, but applies segregation instead of deposit insurance: on its insolvency the client relies on safeguarding having been arranged correctly, not on a guarantee scheme. Neither is better — they cover different steps of the model, and the standard error is holding reserves where no insurance exists.

Classic private banking or an external asset manager

The fourth fork concerns who manages and who holds. A private bank combines both roles: custody, execution and mandate inside one group. The external asset manager model separates them — the bank stays custodian and executing broker while an independent manager runs the portfolio under a limited power of attorney; since 2023 Swiss EAMs operate only under a FINMA licence by virtue of FinIA. Separation gives one control point across several custodian banks and portability when a platform changes, at the cost of a third contract and a second fee stack. How segregation is arranged at the partnership houses is covered in the Geneva private banks.

Types of Institution and What Each One Can Do

Very different constructions live under the single word "bank", and the word on the door says almost nothing about the institution's rights. The useful axis is not size but the scope of the licence.

Protection attaches to whoever holds the asset on its own licence, not to whoever manages it; the table carries caveats. In a universal group the product shelf lives in separate licensed subsidiaries, not "in the group". A UCITS or AIFMD depositary, beyond safekeeping, also oversees the fund manager. An offshore bank is expressly barred by its regulator from retail business where it is established; at a digital bank, large private mandates and complex cross-border servicing usually sit outside the perimeter. An external asset manager or multi-family office holds no assets, so protection follows the custodian bank, not the manager.

Map of Jurisdictions

A jurisdiction decides not prestige but four things at once: regulator and law of contract, protection regime, the currency and correspondent perimeter, and what compliance is realistic for a given profile. Below are the perimeters of the domain and the country shelves where the practice of opening an account is set out.

The Offshore Perimeter: One Caveat

An offshore bank operates on a restricted licence and serves non-residents rather than the local market, and what decides the outcome there is not the size of the compensation limit but who the scheme recognises as a depositor at all: a structure — a company, a discretionary trust, a private trust company — usually has no cover at any limit, and segregation of client money at a fiduciary is no substitute for deposit protection. The statute-by-statute analysis, the class of eligible holders and the differences between the five centres belong to offshore banking jurisdictions; reproducing the figures here serves no purpose, since they move with each reform of the schemes.

Canonical Owners

The hub routes; the subtopics are analysed on their own pages. The service class itself belongs to private banking: thresholds, mandates, retrocessions, deposit protection by booking centre. The personal side belongs to personal accounts abroad: the price of a non-resident account, payout periods across seven guarantee schemes, remote onboarding and the EU basic account right. The jurisdiction of the account inside a group belongs to booking centres. Leaving a relationship belongs to bank account closure. The non-bank perimeter belongs to neobanks and to correspondent banking and safeguarding.

The practice of opening lives on the country shelves: Hong Kong and its virtual banks, the United Kingdom for non-residents, the UAE, China, Spain, Portugal, Türkiye, Serbia, Latin America and the offshore perimeter. The two head-to-head comparisons of booking centres sit separately: Hong Kong against Singapore and Switzerland against Singapore. The crypto-fiat perimeter under a banking licence is held by the Sygnum and AMINA Bank profiles.