Extraterritorial USA sanctions: How to tell how exposed my EU bank is?

Question

The USA have threatened extraterritorial financial sanctions for EU entities which do business with Iran (see the link for how it works and further resources, including relevant USA laws). The EU's proposed countermeasures will be announced tomorrow.

Suppose I'm an EU person or entity, I don't have any business in USA and I only or mostly conduct transactions in Euro.

To minimise the risk of disruption, I'd like to gradually move my and my customers' transactions, assets, credit lines etc. to whichever of my banks is least exposed to sanctions. What factors should I check?

I've thought of checking whether my bank has:

• any USA subsidiary or participation;
• accounts in USD;
• security accounts which trade in USA exchanges;
• specific services for USD/EUR conversion or other currency services which might go through private entities in USA.

I've checked the BIS (Bank of International Settlements) and I found some information on the mechanisms and amounts at play, but no bank-specific information: Non-US banks' claims on the Federal Reserve; Distinguishing global dollar reserves from official holdings in the United States.

Answer 1

Stick to local credit unions and small banks. Large Banks generally have global presence in some form and shape.

Even if worst things happen, the Banks in Europe will loose Banking license in US, meaning they will have quite a bit of assets frozen or may take a while to get back ... this can cause financial hardship to the EU Banks, however if there is a collapse of EU Banks in such situation; the EU Central Bank will step in and provide some relief.

In short; this shouldn't affect individuals or small business much.