If you are a non-UK resident holding a Curtis Banks SIPP, the position has recently become significantly clearer and more urgent. Curtis Banks has confirmed in writing that it no longer accepts new account openings from non-UK residents. While existing accounts remain open for now, this development signals a fundamental shift in how Curtis Banks views overseas clients, and raises serious questions about the long-term suitability of staying put, especially as they told us via email that they may require current non-UK resident clients to transfer out in the near future.
This article explains what this change means in practice, the regulatory risks that non-UK residents with a Curtis Banks SIPP already face, what your transfer options look like, and how Cameron James can help you move to a compliant arrangement designed for life outside the UK.
What Is the Curtis Banks SIPP?
Curtis Banks is one of the UK's largest specialist SIPP providers, now operating as part of the Nucleus Financial Group. Its flagship product, the “Your Future SIPP,” is primarily aimed at high-net-worth individuals. Their own target market documentation states that the product is designed for clients with pension funds of £200,000 or more, and operates on a fixed-fee structure aimed at the upper end of the UK market.
It is an FCA-regulated product, administered by UK-based trustees, and it offers a wide range of investment options, including commercial property, discretionary fund managers, and multi-platform access. For the right UK-based client, it can be an excellent product.
The problem arises when you are no longer based in the UK.
Curtis Banks Has Closed Its Doors to Non-UK Residents
Curtis Banks has confirmed in writing that it will no longer accept new account openings from non-UK residents. This is a significant and unambiguous policy change, and it reflects a direction of travel that has been visible for some time from the choices made by numerous other UK SIPP providers.
Even before this confirmation, Curtis Banks' own published Target Market Document (April 2025) made clear that the product's primary target market for country of residence is UK residents. Non-UK residents were categorised under “potential suitability” only, not the core target market, and that designation came with significant conditions attached. Applications from overseas residents were required to be made by paper and accompanied by a separate Overseas Client Declaration. That door is now closed entirely for new clients.
For existing non-UK resident account holders, the SIPP remains open for now, but the direction of travel is clear. A provider that will no longer onboard overseas clients is unlikely to invest further in its infrastructure, processes, or support for the overseas clients it already holds. If you are a non-UK resident with an existing Curtis Banks SIPP, it is reasonable to question whether this platform remains the right long-term home for your pension. There is also the risk that they follow the route of Interactive Investors and others and require non-UK Residents (especially EU or US Residents) to transfer out to a new provider.
Curtis Banks is also explicit that in all circumstances where an overseas client is involved, the plan must be advised by an adviser who is UK-based, FCA-regulated, and holds the necessary permissions. That last clause is where things start to unravel for most non-UK residents — and it is a problem that has nothing to do with Curtis Banks itself.
The Adviser Problem: FCA Regulation Does Not Travel With You
This is the core structural issue affecting the majority of non-UK residents with a Curtis Banks SIPP, and it is one that is rarely explained clearly enough.
Curtis Banks does not deal directly with clients on investment or financial advice matters. The platform is entirely distribution-led, every client must have an appointed FCA-regulated financial adviser. That means if you want to do anything material with your Curtis Banks SIPP, make investment changes, review your drawdown strategy, restructure your portfolio, you need an adviser. And that adviser must hold FCA authorisation.
Here is the problem: FCA regulation does not grant an adviser the right to advise clients who live outside the United Kingdom. Financial advice is regulated based on the country of residence of the client, not the authorisation of the adviser. In most jurisdictions around the world, providing advice, and especially ongoing investment advice, to a resident of that country requires local regulatory authorisation — a licence or registration in that specific country, except where narrow exemptions apply.
Most FCA-registered advisers hold no such authorisation overseas. They are regulated to advise UK residents, and that is the extent of their permissions. There are narrow carve-outs in some jurisdictions, for example, certain incidental or short-term engagements may be permissible in some countries.
The practical reality for many non-UK residents is this: your FCA adviser likely cannot lawfully continue advising you in the country where you now live. Some advisers are transparent about this and have already stepped back from your account. Others carry on without addressing the issue, which creates a compliance risk that falls primarily on you as the client. And some clients find themselves in a grey zone where they are nominally “advised” but in practice receiving no meaningful guidance because their adviser is unsure what they can and cannot do across borders, and does not actually have the knowledge, experience, or authorisations with suitable products to give the advice.
Curtis Banks itself acknowledges this indirectly. Its own target market documentation states that advisers must hold “the necessary permissions” for overseas client work. The reality is that very few FCA-only advisers do.
The EU Regulatory Gap
For Curtis Banks clients who have moved to an EU member state, France, Germany, Spain, Italy, the Netherlands, Portugal, and others, there is an additional layer of regulatory complexity.
Following Brexit, UK financial services firms and advisers lost their MiFID II passporting rights into the EU. This means that UK platforms and advisers no longer have automatic access to provide investment services to EU-resident retail clients. Under MiFID II rules, providing ongoing portfolio management or investment advice to an EU resident generally requires either a local authorisation in that country or an EU-recognised structure.
Curtis Banks does not hold MiFID II authorisation. Neither do most FCA-regulated advisers. This means that EU-resident clients with a Curtis Banks SIPP are in a regulatory grey zone from two directions: the platform has no MiFID II standing in the EU, and the adviser they depend on for any management cannot lawfully service them on an ongoing basis as an EU resident.
This is not a hypothetical concern. It affects your ability to receive compliant advice, your consumer protection recourse if something goes wrong, and potentially the legitimacy of investment decisions made on your behalf while you were resident in the EU without proper regulatory cover.
The US Regulatory Gap
For US citizens and green card holders, including British expats living in the United States, the situation is even more acute. The US has some of the most far-reaching extraterritorial financial regulations in the world.
Curtis Banks confirms in its Target Market Document that it can accept US nationals living in the UK and UK nationals living in the US, subject to conditions. However, what Curtis Banks does not resolve is the advice problem. Any adviser managing a UK pension for a US-resident client would generally need to be registered with the Securities and Exchange Commission (SEC) or a relevant state regulator. The vast majority of FCA-only advisers are not SEC-registered.
This means that a US-resident client with a Curtis Banks SIPP faces a situation where their pension may technically remain open, but the advice layer required to manage it, investment changes, drawdown planning, and beneficiary structuring, cannot be lawfully provided by a UK-only FCA adviser. It is, in effect, a pension that they cannot be properly advised on.
Cameron James USA is one of a very small number of firms with advisers who hold both FCA and SEC registration, specifically addressing this gap for UK pension holders in the United States.
Why Staying Put Is unlikely to be a good Long-Term Strategy
Some non-UK residents assume that because their Curtis Banks SIPP is technically still open and accessible online, everything is fine. Curtis Banks' confirmation that it will no longer accept new non-UK resident clients should dispel that assumption. A platform that has closed its doors to new overseas clients is one that has made a strategic decision about where its future lies, and that future does not include non-UK residents.
There is also the question of cost. Curtis Banks uses a fixed-fee charging structure that becomes increasingly competitive as funds grow, but that value calculation changes if you have no adviser actively managing the account to justify the overall cost of the arrangement. An International SIPP designed for non-UK residents may offer equivalent investment access at a total cost that makes more sense for your situation, whilst also being much more suitable and compliant, offering significant future proofing.
Your Transfer Options
If you are a non-UK resident with a Curtis Banks SIPP and you are reassessing your options, there are broadly three routes available.
Transfer to an International SIPP is the most commonly appropriate solution for the majority of non-UK residents. An International SIPP is structurally the same as a standard UK SIPP — it is FCA-regulated, HMRC-registered, and carries the same pension protections — but it is specifically designed for clients living outside the UK. Providers offering International SIPPs are experienced with non-UK addresses, overseas bank accounts for drawdown payments, multi-currency reporting, and the documentation requirements of non-UK resident clients. Crucially, International SIPPs are advised through a compliant structure involving advisers who hold the correct authorisation for your country of residence.
Transfer to a QROPS may be worth considering for certain non-UK residents, but the landscape has changed significantly in recent years. The 2017 Overseas Transfer Charge imposes a 25% tax on most QROPS transfers unless you live in the same country as the receiving scheme. The abolition of the UK Lifetime Allowance in 2024 also removed one of the main historical incentives for using QROPS. For most people in most jurisdictions today, an International SIPP is a more cost-effective and simpler solution — but a specialist adviser can assess whether QROPS remains advantageous for your specific circumstances.Remaining in the Curtis Banks SIPP remains technically possible for existing account holders, since Curtis Banks has not indicated it will force closures of existing overseas accounts. However, given that Curtis Banks has now confirmed it will no longer onboard new non-UK resident clients, this should be considered a short-to-medium term bridge rather than a permanent solution — particularly for clients with commercial property holdings where an immediate transfer may not be straightforward. There is also the question of whether the current adviser has the qualifications, knowledge, or ability to actually give you value-added advice, especially on your non-UK-based assets.
Why Transferring Sooner Is Usually Better Than Later
One of the most common mistakes is waiting too long to address this issue, often because everything looks fine on the surface.
The risks of delay include investment portfolios that drift out of alignment with your goals and risk tolerance; missed drawdown planning opportunities (the pension access age rises to 57 in April 2028); potential complications if your circumstances change — new country of residence, change in marital status, inheritance tax exposure — and in some jurisdictions, regulatory scrutiny of advised pension arrangements that lack the correct local permissions.
For clients who are already in drawdown or approaching the point where they will start accessing their pension, the need for compliant, active advice is most acute.
How Cameron James Can Help
Cameron James is a specialist in cross-border pension planning for UK expats and internationally mobile individuals. Unlike most UK-based advisers, Cameron James advisers hold the authorisations needed to service clients across multiple jurisdictions — including FCA and SEC registration for US-connected clients.
Cameron James can review your Curtis Banks SIPP and assess whether your current advisory arrangement is compliant for your country of residence; advise on whether transferring to an International SIPP or alternative arrangement is in your best interests; manage the entire transfer process from Curtis Banks to a suitable provider, handling all the paperwork and trustee coordination involved; provide ongoing investment advice and drawdown planning under the correct regulatory framework for wherever you live; and work alongside local tax advisers in your country of residence to ensure your pension strategy integrates with your wider financial position.
Cameron James works with clients across more than 35 countries and has deep experience with the specific documentation and compliance requirements that come with cross-border UK pension management.
Frequently Asked Questions
Can I keep my Curtis Banks SIPP if I live outside the UK?
If you are an existing account holder, your SIPP remains open for now — Curtis Banks has not announced forced account closures. However, Curtis Banks has confirmed in writing that it no longer accepts new account openings from non-UK residents, which signals a clear direction of travel. The more pressing question for existing overseas clients is whether you have an adviser who is properly authorised to manage your account from your country of residence, and whether Curtis Banks remains a suitable long-term home for your pension given its strategic withdrawal from the overseas market.
Can I transfer my Curtis Banks SIPP while living abroad?
Yes. Transferring a UK pension to an International SIPP does not require you to be a UK resident. The process is managed by advisers and trustees, and Cameron James handles this regularly for clients based around the world. You should take advice before initiating any transfer to ensure the receiving arrangement is suitable for your circumstances.
Will I face any charges for transferring out of Curtis Banks?
Curtis Banks charges a transfer-out fee. You should check your current fee schedule for the exact amount. If you hold commercial property within the SIPP, there may be additional complexity around the transfer, and it is worth taking advice on the most efficient approach before initiating anything. Cameron James advisers would confirm all fees, including Curtis Banks fees, in a regulated advice report as part of the SIPP review process.
What about QROPS — is it still worth considering?
For some expats in specific jurisdictions, QROPS remains a legitimate and tax-efficient solution. But following the introduction of the Overseas Transfer Charge and the abolition of the Lifetime Allowance, the circumstances in which QROPS clearly outperforms an International SIPP have narrowed considerably. A Cameron James adviser can model both options against your specific situation.
What if I plan to return to the UK eventually?
An International SIPP does not prevent you from returning to the UK, and many clients continue with the same structure after their return. In some cases, switching back to a more mainstream UK SIPP at that point may reduce ongoing costs. Cameron James can plan for this transition as part of a long-term advice relationship.
Next Steps
If you hold a Curtis Banks SIPP and you are living outside the UK, Curtis Banks' confirmation that it will no longer accept new overseas clients makes this the right moment to review your position. Whether you choose to transfer now or take a staged approach, the starting point is getting a clear picture of whether your current arrangement is compliant, whether it is still working for you, and what your options are.
Cameron James offers a free initial consultation to review your existing SIPP, assess your country of residence requirements, and explain your transfer options in plain terms — with no obligation to proceed.
Book your free consultation at cjfinance.co.uk or call +44 20 3411 2575.
Disclaimer: This article is for informational purposes only and does not constitute financial, tax, or legal advice. Always consult a qualified and regulated financial adviser before making any decisions about your pension. Curtis Banks SIPP information referenced in this article is drawn from Curtis Banks' published Target Market Document (April 2025).