

January 11, 2027.
This date could become important for banks in Switzerland, the United Kingdom, the USA, or Singapore if they actively offer certain services to customers in the European Union.
The reason is the new European Capital Requirements Directive, CRD VI.
A much more dramatic message is now circulating on social media:
In the future, EU citizens could practically no longer open accounts outside the EU.
Is that true?
No – at least not in such general terms.
The actual regulation is nonetheless interesting.
With Art. 21c CRD VI, the EU is harmonizing market access for certain third-country undertakings.
If a covered undertaking from a third country wishes to offer certain classic banking services in an EU member state, it must, in principle, establish a branch authorized there.
At its core, it specifically concerns:
Deposits and other repayable funds,
Lending,
Guarantees and commitments.
This will, for example, make it more difficult for a bank from Singapore or Switzerland to offer certain classic banking services directly and actively in Germany without having the necessary structure and authorization here.
That is not what the directive says.
On the contrary.
CRD VI contains an important exception.
If a customer approaches a third-country undertaking on their own initiative, the so-called reverse solicitation exception may apply.
Furthermore, the directive's recitals explicitly clarify that the use of banking services outside the Union shall remain unaffected.
This is a significant difference.
The EU is therefore not generally prohibiting its citizens from using banking services outside the EU.
Rather, it regulates the conditions under which third-country undertakings may offer certain banking services in the EU market.
This cannot be inferred from the directive either.
Art. 21c para. 5 explicitly protects existing contracts concluded before July 11, 2026.
The regulation is intended to preserve the acquired rights of customers from these contracts.
How individual banks will handle their European customers is a different matter.
Regulatory burden can lead a provider to decide, for economic reasons, that they no longer wish to serve certain customer groups.
However, that would be a business consequence of the regulation – and not a legal ban on foreign accounts.
Therefore, CRD VI should neither be sensationalized nor downplayed.
The EU is indeed changing the conditions for cross-border financial services.
The goal is a harmonized regulatory framework and stronger supervision of third-country banks operating in the European market.
The EBA only published its final guidelines for the authorization of third-country branches on July 7, 2026.
For providers, this means more regulatory requirements.
For customers, it may mean that certain foreign banks reconsider their offering for EU customers.
This is a real change.
But it is something different from capital controls.
This is where it gets interesting for investors.
Because a bank account and physical gold are two completely different things, both legally and economically.
A bank balance is a claim against a bank.
The account holder does not own the specific banknotes they deposited.
They possess a claim against the credit institution.
Physical gold, on the other hand, can be the direct property of the customer.
The specific legal structure is decisive here.
In the case of fully allocated physical gold, it is not about a deposit, but fundamentally about ownership of an asset.
It is precisely this distinction that is being lost in the current discussion.
CRD VI regulates banking services.
It does not automatically follow that an EU citizen would be prohibited from purchasing and storing physical gold in Switzerland or Singapore in the future.
Art. 21c also does not contain a general obligation to hold assets within the European Union.
This is a crucial difference for the discussion on international asset diversification.
Conversely, it would be irresponsible to conclude that physical gold outside the EU is fundamentally immune to European regulation.
The decisive factors are always the specific contractual arrangement, the provider, payment channels, anti-money laundering regulations, tax obligations, and the question of which services are actually provided.
International diversification, therefore, does not mean an absence of regulation.
It initially only means:
Not all assets are located within the same legal, monetary, and financial system.
The interesting story is therefore not:
“The EU is banning foreign accounts.”
That would be an overstatement.
The actual development is more interesting.
Europe is drawing a clearer regulatory line for certain financial services from third countries.
Third-country banks must decide whether and how they want to operate in the European market in the future.
For investors, this creates an important distinction:
Where are my assets located?
What do I legally own?
And against whom do I merely have a claim?
A euro in a bank account is a claim against a bank.
A government bond is a claim against a state.
Fully allocated physical gold, on the other hand, can be direct property.
That doesn't automatically make one better than the other.
But it makes them fundamentally different.
The crucial question is therefore not only where assets are located – but in what legal form they are held.
Stay farsighted
Yours, Helge Peter Ippensen