closing foreign bank accounts

CLOSING FOREIGN BANK ACCOUNTS

Background
• Over the last decade, banks have been put under pressure to combat money laundering
– both on national and European level, stringent laws have been put in to place.
Compliance requirements become a heavy burden on banks and they are the ones that
will be fined for not following strict procedures.
• An important moment was the implementation of FATCA (2014 in Belgium) for clients with
ties to the United States. Banks had to change procedures to comply with the IRS and
have noted the heavy burden and costs associated with it.
• The European legislation came into effect a few years later, but has similar implications
and banks had already made a cost-benefit analysis of these “international” clients,
which showed that in most cases, the risk, cost and work was not worth keeping these
clients.
• This has resulted in banks minimizing exposure and risk. In practice, this means opening
bank accounts with an “international element” becomes very difficult and existing clients
are being “fired”, with their accounts being closed if they no longer have strong ties to
Belgium; either being a resident (private citizens) or having a physical presence in the
country (companies).
• Banks are private institutions and it is to a large extent up to their own discretion who they
want to take on or keep as a client, both private and business clients.

Situation
• We’ve received input from Belgians worldwide that they get account closure notices.
• It happens for clients of all big banks in Belgium (we don’t have a specific bank to
recommend that does not do it).
• While it mostly impacts those living outside of the EU, there are some cases impacting
those living within the EU too.

Steps being taken
• UFBE and VIW are advocating with local authorities to come up with a practical and viable
solution.
• The new federal government includes an action point in their coalition agreement, to
prevent restrictions on access to bank accounts.
• Please note they mostly focus on diplomats, embassies and companies, rather than
individual expats.
• In March of 2024, a law proposal was submitted to provide a “basic banking service” for
Belgian nationals (private citizens) living outside of the EU, that guarantees access to their
pre-existing Belgian bank account for up to 10 years after leaving the EU. Banks still have
to comply with KYC requirements (Know Your Customer); if a customer cannot fulfill these
requirements, the bank has no obligation to keep the account open.

Our advice
• Prepare: open bank accounts in country of residence and spread assets. Notice of closing
a bank account usually only gives the end user 30 days to move assets so have an
alternative in place before it happens.
• Digital banks like Revolut, N26 have multiple currency accounts and are available in most
countries. They also offer business accounts.
• Transferring money: Wise (formerly TransferWise) remains best solution for transfers up
to € 10.000 with lowest exchange rates and transfer fees.
• Look up rules around large money transfers; there may be paperwork involved to “import”
money. You always have the right to move your own money, but often you need to register
it somewhere and explain the source of the funds.
• Make sure you can comply with KYC requirements; have an up-to-date Belgian eID and a
card reader or ItsMe application (this often cannot be downloaded from a non-EU app
store and should be pre-installed) in case you need to connect this with your banking
platform.

DISCLAIMER: Information and advice is provided by Vlamingen in de Wereld to the best of
our knowledge and no legal rights can be derived from it.