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A friend showed me a letter from The Co-operative Bank, a UK bank with which they have an account. This letter requests their US Social Security Number (SSN):

We've written to you requesting [this] to be returned to the Bank, as our records show that you're either one of the following:

  • A United States of America (U.S.) citizen
  • A U.S. national
  • Have either a living or correspondence address within the U.S.
  • Informed us that you're tax resident in the US

Due to this we are required to hold your US Social Security Number (SSN). (...) This information is required to comply with the tax regulations, under which we are required to prvide any foreign tax residency details, including your SSN, together with information about your account(s) in our annual return to HM Revenue and Customs (HMRC).

My friend does not remember telling this bank they are a US citizen. They are also wary about disclosing their SSN to someone who doesn't require it. The bank is threatening to freeze, then close the account if they don't get the required information.

The paperwork looks legitimate, as do the means of conveying the information to the bank. The other bank or banks they have accounts with in the UK have not asked for this information.

Do UK banks need to collect SSNs from US citizens? (and the other people listed in the quoted excerpt) And if they do, why?

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    Whether your friend told them they are a US citizen is less relevant than if your friend is a US citizen. It sounds like the bank is required to report certain activity to the IRS (by treaty?), which would likely require the SSN. (Whether that is true or not will likely answer the question of the bank needing the SSN.) – chepner Jul 6 at 14:38
  • UK banks have stringent "know your customer" requirements and collect UK National Insurance numbers from customers; US SSN is the equivalent. If the bank is threatening to freeze the account without the information they really mean it - this step is not taken lightly. – Owain Jul 6 at 17:33
  • The reason is FATCA, as explained on this near-dupe money.stackexchange.com/questions/29692/… – dave_thompson_085 Jul 7 at 3:17
  • @dave_thompson_085 Thank you for pointing out that question; they're both different sides of the same coin! The other question doesn't mention SSNs, and the letter my friend got didn't mention FACTA, so hopefully this QA fills a gap for other folks who have received letters and are wondering about it. Perhaps it would be worth writing a short answer pointing this out? :) – bertieb Jul 8 at 7:08
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International banks are required to inform the IRS about your accounts, including total assets and interest gained. This is difficult without being able to identify you through an SSN, so they typically insist on having it.
You will probably not find any bank in the world that offers you an account without having your SSN (unless you keep the information that you are a US person from them).

Note also that you are required to annually file an FBAR to the IRS about your foreign accounts, failure to do so (even unwillfully = negligent) will result in a fee of the higher of 100 000$ or 50% of your accounts (Yes, that means you might only have 1 000 in the account but will be fined 100 000, and "I didn't know" won't help you). See for example https://www.forbes.com/sites/robertwood/2015/12/04/when-foreign-banks-ask-for-u-s-taxpayer-id-how-should-you-respond/#549a5e37791d

  • FBAR only applies if "the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported." irs.gov/businesses/small-businesses-self-employed/… – PersonX Jul 6 at 15:27
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    Correct; however, if paychecks move through the account, it is quite easy to be over $10k at one single day, unless you live paycheck-to-paycheck. Note that the limit is for the accumulated total of all your foreign accounts, including investment accounts, savings accounts, and accounts at any other banks outside the US. – Aganju Jul 6 at 18:51
  • FBAR (under BSA) goes to FInCEN, not IRS. There is also form 8938 (under FATCA) which does go to iRS, at a higher and varying threshold and only if you are required to file income tax (which US citizens are even when living abroad; you may avoid actual tax due to FEIE, but you still must file); see irs.gov/businesses/… – dave_thompson_085 Jul 7 at 3:05
  • Thank you for taking the time to answer. It seems that from the first part of your answer that my friend should not worry- a UK bank has a legitimate cause to ask for an SSN, is that fair to say? – bertieb Jul 8 at 7:05
  • I mentioned the part about FBAR to my friend and their response was <confused noises>; I may ask a separate question on that as it seems a tangential-but-important issue! – bertieb Jul 8 at 7:06

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