Banks by Jurisdiction: Private Banking and Accounts

Concept

A bank and a payment service solve different tasks. A payment service moves everyday transfers; a bank stores money, lends, insures it within a national scheme and folds it into the long-term structure of a family or company: reserves, collateralised lending, inheritance, wealth management.

A bank is a licensed deposit-taking institution regulated by a central bank or an equivalent prudential regulator, with the right to accept deposits from an unlimited number of persons, issue loans, conduct settlements in its own name and hold a direct correspondent account at the central bank. A mobile app, a card and transfers are now offered by every payment institution; what distinguishes a bank from any other financial service is three structural rights and three structural obligations enshrined in the banking legislation of each country.

Client money at a bank is recorded on the bank's balance sheet as a liability to the depositor. Against this liability the bank holds reserves, issues loans out of accepted deposits under the fractional-reserve model and complies with capital standards. So a bank raises both the question "will they open the account" and the more important one: will its balance sheet, capital and supervision withstand the risk the client brings.

The second difference is deposit protection. It is tied to licensed-bank status and usually applies per depositor per bank or banking licence. It does not extend to payment institutions, investment funds, crypto platforms or corporate wallets, where client money may be held through a separate safeguarding arrangement or at a partner bank.

The third difference is a direct correspondent account at the central bank. A payment institution, an investment fund, a custodian settle through a partner bank. That bank holds their liabilities to clients and can, if necessary, end the relationship on commercial or regulatory grounds. A bank has no such intermediary. Its account at the Federal Reserve System of the United States, the European Central Bank, the Bank of England, the Monetary Authority of Singapore, the Hong Kong Monetary Authority is a direct node in the national payment system. This gives the bank two things unavailable to a payment institution: access to lender-of-last-resort liquidity and independence from the stability of relationships with third parties.

Entry Thresholds: Premium and Private Banking

Banks segment clients by qualifying AUM — the deposits and investments booked through the bank. Below are the published thresholds of the main banks by booking jurisdiction; data as of July 2026.

Singapore and UK banks publish their thresholds on official pages; Swiss and Liechtenstein private banks do not disclose minimums — entry is agreed individually. Tier-by-tier breakdowns are on the linked bank pages.

Deposit Insurance Limits by Jurisdiction

Deposit insurance limits are established by national legislation and reviewed periodically. Current values as of 4 July 2026:

Bank Failures of 2023

In three months of 2023 a 167-year-old globally systemically important bank went under and several large US banks collapsed — Credit Suisse, Silicon Valley Bank, Signature, Silvergate and First Republic.

Credit Suisse. One of the world's thirty globally systemically important banks ceased to exist in a matter of days. After years of scandals (Archegos, Greensill) and deposit outflows — around CHF 111 billion in Q4 2022 alone — confidence ran out; on 15 March 2023 the largest shareholder publicly refused to add capital and the share price collapsed. On 19 March the Swiss authorities, under emergency law and without a shareholder vote, arranged the bank's takeover by UBS for CHF 3 billion in stock — a fraction of the prior market value. The SNB and the government backstopped liquidity with more than CHF 200 billion, plus a separate CHF 9 billion loss guarantee to UBS. But the key lesson lies in the fate of the subordinated debt: FINMA wrote down about CHF 16 billion (roughly US$17 billion) of AT1 (CoCo) bonds to zero, while shareholders still received something for their stock. This inverted the usual order: under Basel III logic, equity absorbs losses first and AT1 holders rank above shareholders. Here the order was reversed — bondholders wiped out entirely, shareholders paid. Investors filed hundreds of suits; on 1 October 2025 the Swiss Federal Administrative Court ruled the write-down unlawful, but the ruling is under appeal and, as of mid-2026, is not final. The takeaway for a depositor is twofold: even a 167-year-old systemic bank can disappear over a weekend, and the label "safer than equity" is worth exactly what the individual instrument's prospectus says.

Silicon Valley Bank. A conventional bank killed not by fraud but by interest-rate risk. SVB put a flood of cheap-money deposits into long-dated Treasuries, of which about US$91 billion sat in a held-to-maturity portfolio not marked to market. When the Fed raised rates, the market value of those securities fell, and the bank had removed its hedges. The deposit base was uniquely fragile: startups and funds, with roughly 94% of the money above the FDIC insurance limit. On 8 March the bank booked a US$1.8 billion loss and announced a capital raise — and venture investors told their portfolio companies, in group chats, to pull their cash. On 9 March clients requested around US$42 billion of withdrawals in a single day, over a million dollars per second; for comparison, Washington Mutual in 2008 lost US$16.7 billion over ten days. On 10 March the bank was closed and the FDIC took over. To stop the panic spreading, the authorities invoked the "systemic risk exception" and made all depositors whole, including the uninsured — but that was a policy decision, not a right, and it cannot be relied on to repeat. The business was later bought by First Citizens.

Signature and Silvergate. The same March showed the risk of sector concentration. Crypto-focused Silvergate announced a voluntary wind-down with full repayment of deposits on 8 March; Signature Bank, where the crypto sector accounted for some 20–30% of deposits, was closed on 12 March under the same systemic-risk exception. A homogeneous deposit base leaves all at once — whether it is labelled "startups" or "crypto."

First Republic. On 1 May 2023 the FDIC took over a bank that served wealthy clients with jumbo mortgages and held a high share of uninsured deposits, and on the same day sold it to JPMorgan Chase. By assets (around US$229 billion) it was the largest US bank failure since Washington Mutual in 2008. Here the uninsured were saved not by a special order but by an acquirer.

Bank Reliability: G-SIBs, Ratings, Metrics

Reliability rests on three groups of factors that do not reduce to the insurance limit.

Globally systemically important banks (G-SIBs). The Financial Stability Board (FSB) publishes an annual list of globally systemically important banks — 29 as of end-2025. They are sorted into "buckets" (1–5) by systemic importance: the higher the bucket, the larger the surcharge to Common Equity Tier 1 capital (CET1). The top, fifth bucket is always empty; the fourth (2.5% surcharge) holds JPMorgan Chase alone; the third holds Citigroup, HSBC and — having moved up in the 2025 list — Bank of America and ICBC; Deutsche Bank, by contrast, dropped from the second bucket to the first. G-SIB status matters to a depositor not in itself but for what it brings: a higher capital buffer, a TLAC requirement (a stack of capital and bail-in bonds that absorbs losses without taxpayer money), and a resolution plan for a failure. Such a bank is designed so that in trouble the losses are taken by shareholders and TLAC-debt holders while the depositor stands ahead of them in the queue. That is not a state guarantee, but a thicker cushion and a clear resolution path.

Credit ratings. Moody's, S&P and Fitch assess a bank's probability of default on their own scales (broadly from Aaa/AAA downward), reflecting both the bank's standalone strength and the likelihood of external support. For a depositor this is a rough but useful marker: investment grade versus speculative, the direction of review (outlook), and the gap between the group's rating and a specific subsidiary's. It is worth remembering that a rating is an opinion on creditworthiness, not a guarantee: Credit Suisse remained investment grade almost to the very end.

Capital, liquidity and balance-sheet structure. Behind the rating sit concrete metrics: capital adequacy (CET1 ratio), liquidity coverage (LCR), the share of uninsured deposits, sector concentration, and portfolio structure — how much sits in long-dated held-to-maturity paper, as it did at SVB.

Types of Banks: A Multi-Level Taxonomy

Completely different businesses live under one banking licence, and the word "bank" on the sign says almost nothing about what an institution does or whom it serves. The classification runs along four independent axes: by function (what the bank does), by ownership and legal structure (who owns it and who answers for its obligations), by delivery model (how access is arranged), and by specialisation. One bank almost always falls on several axes at once: N26 is a neobank by model, universal by function and licensed by status; Pictet is a private bank by function and a partnership by structure.

By function: what the bank does

A central bank is the issuer of the national currency and the lender of last resort; it does not serve private clients but keeps the accounts of all other banks and sits at the base of the whole structure (the Fed, the ECB, the SNB, the HKMA). Everything else is a commercial institution, and it helps to place them on a spectrum from the mass client to the narrow one.

A retail bank takes deposits and lends to individuals and small business through a branch network or an app, earning on scale and payment fees (Lloyds, Crédit Agricole, DBS's retail arm). A commercial bank is, historically, the one that puts depositors' money to work; it takes deposits broadly and lends, serving everyone rather than only the large (JPMorgan Chase, Santander, ICBC). A corporate and wholesale bank works only with large companies and institutions — loans, cash management, syndication; it takes no retail deposits, keeps no branch network and funds itself wholesale (HSBC Global Banking, BNP Paribas CIB, Standard Chartered). The difference between commercial and corporate is not the size of the fee but the client base and the source of funding.

An investment bank is the intermediary between an issuer and the capital market: underwriting equity and bond issues, M&A advisory, trading in securities; as a rule it takes no deposits and lives on fees and trading (Goldman Sachs, Morgan Stanley, Jefferies). A merchant bank invests its own capital in private companies and holds the stake for years — closer to private equity than to brokerage (Rothschild & Co, Lazard; historically Baring Brothers). An investment bank takes a fee on the public market; a merchant bank risks its own money in private deals.

A private bank serves wealthy clients on its own balance sheet and licence: deposits, lending against a portfolio (Lombard), brokerage, trust and estate solutions (UBS, J.P. Morgan Private Bank, Julius Baer, Pictet). A wealth manager only advises and plans, usually without a banking licence and without a balance sheet of its own — client assets sit in custody with third parties, and the manager's income is a fee, not a spread (St. James's Place, independent RIA platforms). A family office sells no products of its own and coordinates capital without a product conflict of interest — see the separate breakdown of family office. The key distinction is whether the institution has its own balance sheet and how independent its advice is. Details — private banking.

Holding and recording assets is a separate function. A custodian holds securities, handles settlement and corporate actions, but does not invest (BNY, State Street, Northern Trust). A fund depositary in UCITS and AIFMD structures is a layer above custody: by law it must be a credit institution and does not merely hold assets but oversees the fund's manager and is answerable for their restitution. A custodian holds; a depositary holds and controls.

Infrastructure roles serve not the end client but another bank or fund. A transaction (treasury) bank sells companies the settlement infrastructure: payments, liquidity, pooling, FX (Citi Treasury and Trade Solutions, Deutsche Bank Corporate Bank, J.P. Morgan Payments). A trade-finance bank secures deliveries — letters of credit, guarantees, factoring — where the collateral is the goods, not the borrower's balance sheet (Standard Chartered, HSBC, Commerzbank). A correspondent (clearing) bank keeps the accounts of other banks (nostro / vostro) and gives them entry to clearing systems. A prime broker serves hedge funds: margin financing, securities lending, centralised clearing (Goldman Sachs, Morgan Stanley, J.P. Morgan). Why correspondent links matter so much is covered below, in the section on settlement infrastructure.

By ownership and legal structure: who answers for the obligations

A universal bank brings all of the above under one group, but the "one bank for everything" feeling is deceptive: legally, each product lives in a separate licensed subsidiary. In the UK this is written into law — since 2019, banks with deposits above £25 billion must ring-fence: separate retail into a legal entity with its own board and PRA licence (HSBC UK Bank plc versus HSBC Bank plc, Barclays Bank UK plc versus Barclays Bank plc). So deposit protection and risk are counted per specific licence, not per brand.

Ownership shapes the risk profile more than size does. A cooperative bank belongs to its member-depositors rather than shareholders and feels no shareholder-value pressure (Crédit Agricole, Rabobank, Raiffeisen). Savings banks — the German Sparkassen (public-law institutions of municipalities) and Landesbanken, the Swiss Kantonalbanken; 21 of the 24 cantonal banks carry a full state guarantee (Staatsgarantie): the canton is subsidiarily liable for the bank's obligations (Zürcher Kantonalbank — with a guarantee, Banque Cantonale Vaudoise — without). A building society is a mutual owned by its members, specialising in savings and mortgages and legally not a bank (Nationwide — the world's largest). A credit union is a non-profit cooperative of members with a common bond (Navy Federal in the US). State banks and development institutions finance policy, not profit (KfW, EIB, China Development Bank).

Partnership private banks are the Geneva construct. Historically the partners bore unlimited personal liability for the bank's obligations, with their entire private wealth; on 1 January 2014 Pictet, Lombard Odier and Mirabaud gave up unlimited liability and moved into a corporate-partnership form (SCA). But the essence remains: the bank has no external public shareholders, it is run by owner-partners whose capital and reputation serve as a buffer, and the decision horizon is generational rather than quarterly. That is why the incentive profile of such a bank differs from a listed group.

By delivery model: how access is arranged

A classic branch bank keeps its branch network as the primary channel (Lloyds, Commerzbank, Bank of America). A direct (digital) bank has no branches but belongs to a classic bank and runs on its licence (Marcus by Goldman Sachs, ING Direct). A challenger is a new licensed bank competing with the large ones (Starling, Monzo).

A neobank is a digital bank, and a fundamental line runs through the category. A licensed neobank holds a full banking (deposit) licence: the app is the bank and deposits are insured directly (N26 and Revolut — EU licences, ZA Bank — a Hong Kong virtual-bank licence). A neobank on a partner model (BaaS) is an app that is not a bank: deposits are held by a partner licensed bank, and insurance runs through it (the US app Chime works through The Bancorp Bank and Stride Bank). Banking-as-a-Service is where a licensed bank "rents out" its licence and API to a fintech, embedding accounts in someone else's brand (Solaris, Column).

EMIs and payment institutions are not banks at all. Licences under PSD2 / EMD allow the issuance of electronic money and the making of payments, but give no right to lend from client funds, open no direct account at the central bank, and instead of deposit insurance apply safeguarding — the segregation of client money in an account at a partner bank. If an EMI goes bankrupt, the client relies not on a state guarantee but on the safeguarding having been arranged correctly (Wise, Stripe; Revolut in the UK held an EMI licence before obtaining a banking one). A layer below sits the infrastructure serving the payment companies themselves — correspondent accounts and vIBANs, for example Clear Junction. The full breakdown of licences, safeguarding and a provider rating is in the separate material on neobanks; operating payments and multi-currency revenue are usually run through this rail, not through a bank.

By specialisation

An Islamic bank operates under sharia: riba (interest) is forbidden, and income is earned through trade and leasing — murabaha (sale at a disclosed mark-up), ijara (leasing), musharaka (partnership), sukuk (asset-backed Islamic "bonds"); a Sharia board sits above the bank (Al Rajhi Bank — the world's largest, Dubai Islamic Bank, Kuwait Finance House). An offshore (international) bank works on a restricted licence (IFE, "class B"), serves non-residents and does not work with the local market — the separate section below is devoted to it. A bank with crypto-asset custody holds crypto and fiat under one banking licence (Sygnum and AMINA Bank — both with a FINMA licence); such a bank differs from a crypto-neobank by holding a banking licence.

Jurisdictions

Offshore Banks by Jurisdiction

An offshore (international) bank works on a restricted licence and serves non-residents rather than the local market. The selection logic here is different from onshore jurisdictions: most classic offshore centres have no deposit insurance at all, and what becomes decisive is not the protection limit but access to correspondent links and the jurisdiction's reputation in the eyes of compliance. The groups below run from centres with real deposit protection to those where there is none and none is intended.

Custody and Settlement Infrastructure

Several key institutions are important alongside banks but are not banks themselves. Euroclear and Clearstream — European central securities depositories; settlements for bonds, stocks, and funds issued by European companies pass through them. Their function is clearing and settlement of securities transactions; they open no bank account. Details — Euroclear and Clearstream.

Trust companies engage in fiduciary asset management — this is an independent industry with its own licences, not directly related to banks, although large banks usually have their own trust division. Details — trustee.

Palais Coburg in Vienna — a private vault for valuables: physical gold, watches, documents, jewellery. This is a store of physical valuables with a distinct legal regime; it is not a bank account.

Clearing and correspondents: how money actually moves

Between "the bank sent the transfer" and "the money arrived" sits an infrastructure of three levels: messaging, clearing and settlement. SWIFT is a messaging network (now on the ISO 20022 standard), not a settlement system: banks pass instructions over it, but the money moves along national rails. The dollar clears through Fedwire (the Fed's RTGS, each payment final and individual) and CHIPS (private netting of large sums, including most cross-border dollars); the euro through TARGET2/T2 (the Eurosystem's settlement engine) within the SEPA rules; the pound through CHAPS (the Bank of England's RTGS) and Faster Payments; the yuan through CIPS (China's cross-border RMB clearing system, which relies on SWIFT for messaging). Only a limited circle of participant banks has direct access to each of these systems; everyone else clears the currency through a correspondent that does have it. A bank's ability to make a payment in a given currency is determined not by whether it can send a SWIFT message but by whether it (or its correspondent) has entry to that currency's clearing system.

This is also why sanctions and de-risking are so painful. A correspondent is liable to OFAC, OFSI and the EU for whose payments it lets through; when a sanctioned or high-risk client appears, the correspondent cuts the relationship to avoid secondary sanctions — and the bank loses its only door to clearing the currency, even while fully solvent. Disconnection from SWIFT adds the loss of the messaging layer on top of that. For those who work with crypto-fiat flows, this control is covered separately — OTC and bank control.

What You Need to Understand Before Opening a Bank Account

Source of Wealth and Source of Funds — Two Different Questions

Source of Wealth (SoW) — where the client's capital came from in the first place: the sale of a business, investments over years, an inheritance, twenty years of salary. This is the story of accumulation.

Source of Funds (SoF) — where exactly the money now arriving on the account comes from: an asset-sale agreement, an invoice from a specific company, dividends from a specific structure. This is the story of the transaction.

Confirmation must be documentary: tax returns, purchase and sale agreements, bank statements, audited accounts of the source company. For a large private client, a separate pack with the brief logic of the capital's origin is usually needed, not merely an archive of documents.

Apostille is Mandatory

CRS and FATCA — No Exceptions

Sanctions Compliance

Any international bank screens a client against the UN, OFAC, EU, UK lists and its own internal restrictions. A match on a beneficiary, director, counterparty, address, goods or payment route can lead to a refusal to open an account or the closure of the relationship.

Case from Practice

AuM Minimums for Private Banking

Minimums are published informally; the sites usually say "from 1 million," but the actual threshold for proper service is higher:

If the assets are smaller, a bank may open an ordinary account but will not provide the level of service for which it makes sense to go to a private bank in the first place.

Estate Planning — Separate Service

Bank Rating: Tiers

The classification below is an editorial assessment by private.law; it is not an official reliability rating. The level reflects the priority when matching a bank to a client.

How to Choose a Bank: Four Filters

The first filter is the booking jurisdiction, not the brand. It determines the regulator, the deposit-protection regime, the currency infrastructure and the onboarding speed. Singapore and Hong Kong cover the Asian loop and settlement with Asia (HSBC Hong Kong is a typical gateway), Switzerland and Liechtenstein — conservative capital custody (UBS, LGT), the United Kingdom — operating banking around British assets, the UAE — a neutral hub with entry to premium tiers from AED 200K. The two leading private banking centres are compared point by point separately — Switzerland or Singapore.

The second filter is the threshold. In Singapore the premium segment starts from S$200K (Standard Chartered Priority) and S$350K (DBS Treasures, UOB Privilege, OCBC Premier); in the United Kingdom premier tiers are available from £75–100K; full private banking starts from US$5M at the Singapore flagships and "on request" at the Swiss houses. Capital below the private threshold argues for the upper premium tier (the S$1.5M segment) rather than storming a private bank.

The third filter is the sanctions profile. Citizenship, residence and the structure of the source of funds determine which compliance is realistically passable: since 2022 Swiss banks apply enhanced due diligence to sanctions-sensitive profiles, while Singapore, Hong Kong and the UAE onboard faster when the origin of funds is transparent. There is no universal yes/no — the decision rests with the compliance of the specific bank.

The fourth filter is the task. A settlement hub for business, a deposit held under state insurance and a managed investment portfolio are three different roles that rarely combine in one institution. A working construction is a bundle: a settlement bank, a deposit bank in a jurisdiction with strong depositor protection and a wealth platform for investments.

Sources and Limit Updates

The update as of 4 July 2026 draws on: Bank of England/PRA and FSCS for the £120,000 limit; SDIC for the S$100,000 limit; Hong Kong Deposit Protection Board for HK$800,000; FDIC for $250,000; European Commission for €100,000; FINMA and esisuisse for CHF 100,000.

The reliability and 2023-failures sections draw on: FSB for the 2025 G-SIB list and buckets; FINMA for the Credit Suisse takeover and the AT1 write-down; FDIC for SVB, Signature and the systemic-risk exception; FATF and the EU AML-list update of 29 January 2026 for the status of offshore jurisdictions; HKMA for the HK$800,000 limit from 1 October 2024; Deposit Insurance Agency of Georgia for the GEL 50,000 limit from 1 April 2026.

Frequently asked questions

How to choose a bank by jurisdiction

Task first, country second: operating payments are handled by a neobank, the reserve is held at a bank with deposit protection, family capital at a private bank. Then three filters: the insurance limit per depositor per licence (United Kingdom £120,000, US $250,000, EU €100,000, Singapore S$100,000, Hong Kong HK$800,000), correspondent access to the currencies you need, and the bank's risk appetite for your profile — residence, beneficiaries, source of funds. A bank is chosen to fit the payment route, not by brand.

Where is deposit protection highest in 2026

Among the large jurisdictions the nominally highest limit is Hong Kong: HK$800,000 (about US$100,000) since 1 October 2024. The United Kingdom — £120,000 since 1 December 2025, the US — $250,000 (and separately per ownership category), the EU — €100,000, Switzerland — CHF 100,000, Singapore — S$100,000. The limit applies per depositor per banking licence, not per brand.

What to do with an amount above the insurance limit

Spread it across independent licences and jurisdictions: four banks in four legal regimes are four independent deposit-insurance systems. Beyond that, the choice of the bank itself matters: G-SIB status with capital buffers and TLAC, the credit rating, the share of uninsured deposits. The 2023 failures showed that rescuing uninsured depositors is a one-off political decision, not a rule.

How a bank differs from a payment service (EMI)

A bank has three structural features: the right to accept deposits under state deposit insurance, the right to lend from accepted funds and a direct correspondent account at the central bank. EMIs and payment institutions hold client money through safeguarding at partner banks' accounts — on such an institution's bankruptcy the client relies on the correctness of the segregation, not on a state guarantee.