The rule, plainly
Two countries are excluded, and they are two heavyweights: the United States and the United Kingdom. If you reside in either, you will not be able to open an account, and there is no point routing around it with a document from somewhere else: compliance will catch up with you.
This is not a warning sign about the institution's soundness. Quite the opposite. It is the price of a clear positioning, which we unpack next.
Why: Gibraltar, and nothing beyond it
Xapo Bank Limited is licensed in Gibraltar and regulated by the Gibraltar Financial Services Commission. By accepting neither US nor UK residents, it stays strictly inside the perimeter of that licence and spares itself the supervision of two of the world's most demanding regulators.
Serving US residents, for instance, would drag the bank into a thicket of tax and reporting rules specific to the United States. Staying out of those two markets is a deliberate trade-off, consistent with the rest of the product: a niche bank, built for people who are not resident in those zones.
Residence, not nationality: the distinction that decides it
This is the most common mistake. What settles your eligibility is not your passport, it is the country where you live.
A French citizen settled in Panama, Paraguay or Dubai is eligible. A French citizen living in New York or London is not. Symmetrically, a US national who has genuinely moved his residence outside the United States will still meet Xapo's sensitivity on anything American: a US passport remains a subject institutions handle carefully. In practice, reason first in terms of tax residence.
If you are eligible, fine. But keep two things in mind: you will not be able to recommend the account to contacts based in the United States or the United Kingdom, and if you plan to move there yourself, opening now does not shield you from a future change of residence. Plan according to your trajectory.
What you will be asked at sign-up
Like any regulated bank, Xapo runs a compliance process. In practice you will be asked to share your geolocation and to answer questions about the source of your funds, particularly on the crypto side.
Nothing unusual for a licensed institution, but if sharing your location bothers you on principle, better to know before you start. It is also the mechanism that verifies, indirectly, that you do not reside in an excluded country.
For an expat outside the US and UK: no obstacle
For the audience this account genuinely targets, someone who has left home and lives outside the two excluded countries, the US and UK restriction is a non-question. You are exactly the target: receive euros, hold interest-bearing dollars, keep bitcoin in full reserve, all from a bank outside the eurozone.
That is our own case, and it is why the account has served us for three years. If your hesitation is about the product rather than eligibility, our full review after three years goes through the upsides and the limits in detail.
In short
- Excluded: residents of the United States and the United Kingdom.
- Criterion: residence, not nationality.
- Reason: staying within the Gibraltar licence, outside the US and UK regulators.
- At sign-up: geolocation and source of funds, standard compliance for a licensed bank.
- No obstacle for an expat settled outside those two countries.