| Key takeaway: If you are a UK national living overseas and you find an adviser through a UK-based directory such as Unbiased, you should be aware that the FCA-regulated firm listed almost certainly cannot lawfully advise you in your country of residence. The very act of advertising that they can may itself be unlawful. |
For expats and non-UK residents seeking financial advice on UK pensions, investments, or cross-border tax planning, the internet is awash with directories promising to connect you with a qualified, FCA-regulated adviser. The reality is more complicated, and for consumers, potentially harmful.
This article explains why UK adviser directories are structurally ill-suited to facilitating expat financial advice, outlines the regulatory issues, and identifies what to look for instead.
The Core Problem: FCA Regulation Does Not Apply to Non-UK Residents
The FCA regulates financial advice given to UK residents. Its authorisation is entirely irrelevant to whether an adviser can advise individuals resident in other countries. Advising an expat living in Dubai, Australia, Spain, or the United States requires local regulatory authorisation in the relevant jurisdiction. FCA permission plays no part in that analysis.
This is not a grey area. For most countries, including the United States, the European Union, and the UAE, providing financial advice, unless a narrow exemption is available, or soliciting clients without the relevant local licence is a legal offence. It does not matter that the adviser holds an FCA number.
The concept of “reverse solicitation” (where an overseas individual proactively approaches a UK firm without being solicited) is sometimes cited as a workaround. But this defence is narrow, and by definition cannot apply where the adviser has actively marketed their services to expats. A listing in an expat-facing directory, or any marketing materials that explicitly target overseas residents, very likely eliminates the possibility of claiming reverse solicitation, especially if the directory specifies jurisdictions, such as the EEA.
| In plain terms:The moment an FCA-only adviser advertises that they can help expats, they could be deemed to have solicited expat clients. That single act could invalidate any reverse solicitation defence and place them outside the bounds of lawful advice for those clients. |
The “Expatriate Finances” Toggle: A Misleading Signal
Several UK adviser directories, including Unbiased, allow advisers to select an “Expatriate Finances” or equivalent toggle on their profile. In doing so, those advisers are publicly representing that they are able to advise clients living abroad.
The problem is that the directories do not verify whether those advisers actually hold the overseas regulatory permissions required to make that representation lawful. As a result, consumers using these services from abroad are led to believe they are accessing FCA-regulated financial advice when, in most cases, they are not, and, if they are, unlikely to have PI cover for the adviser.
This is not a minor technicality. It means that clients may be receiving advice from someone who is not authorised to give it in their country of residence, is not covered by professional indemnity insurance for that advice, may not be subject to the compensation framework they believe applies, and may be recommending products that the adviser is not licenced to recommend in that jurisdiction or are not suitable for someone resident in that jurisdiction.
Four Types of Non-Compliance Found in Expat Adviser Listings
Advisers in directories such as Unbiased who market themselves as able to advise expats tend to fall into one of four categories, each with different compliance implications:
| Category 1: Box-TickersAdvisers who have simply selected the expatriate toggle without meaningfully targeting or serving overseas clients. Non-compliance is limited in practice, though the listing is still potentially misleading. These are, by and large, harmless, as they will likely advise the prospective client that they can not help. |
| Category 2: Multijurisdictional Firms with Overseas PermissionsFirms which hold both FCA authorisation and genuine overseas licences. These firms can lawfully advise expats in several jurisdictions, but only through their overseas-regulated entity, not their UK FCA entity. The FCA authorisation is irrelevant to the expat client relationship. The issue here is misleading marketing: the directory listing links to the FCA-regulated firm, creating the impression of FCA-regulated advice, when any legitimate advice will all but certainly be delivered under an entirely different regulatory framework. Consumers need to understand this distinction clearly. |
| Category 3: FCA-Only Firms Falsely Claiming Expat CapabilityFirms that hold FCA authorisation only, with no overseas advice permissions, but who nevertheless market themselves to expats and advise them. This is both unlawful and potentially harmful. Many such firms have backgrounds connected to firms with poor regulatory histories. Some use platforms and product providers who themselves may be facilitating non-compliant activity for non-UK residents, albeit ignorantly, and for which more suitable products are not advised, as they cannot advise them, as they only work with correctly regulated advisers. |
| Category 4: Firms Routing Overseas Advice Through Their UK EntityArguably the most serious category. These are firms that are FCA regulated but also hold overseas regulatory permissions, but route the advice on UK products through their UK FCA firm, where they can. This can constitute fraud on the client and the relevant overseas regulator, and given that, it is all but certainly never going to be covered by their PI provider. |
Illustrative Examples: Patterns Seen in Practice
The following examples are drawn from patterns observable in publicly accessible information across adviser directories. They are presented to illustrate the types of conduct described above, rather than to make specific allegations about any firm.
Example A: Category 4 – Overseas Licences Used to Acquire Clients, Business Routed Through UK Entity
One firm appearing in a major UK directory under an expat-facing category was founded by individuals previously employed, some in senior positions, at an overseas advisory operation that was shut down following regulatory violations. The firm held overseas licences, which it used to market to overseas residents, but the UK business itself was then placed through its UK FCA entity, the entity visible in the directory, and for which there is no legal connection to those overseas entities, despite the similar names and the names being trading styles on the FCA register. Multiple SIPP providers are understood to have reported them to both the FCA and the SEC. The firm’s US-facing website was subsequently forced to be taken down by their SEC Principal firm.
Example B: Category 3 – FCA-Only Firm Falsely Marketing FCA Protection to Expats
A second firm listed under expat services in a major UK directory held only FCA authorisation, with no overseas regulatory permissions of any kind. Despite this, the firm’s website explicitly targeted UK nationals living in the UAE and Qatar, displayed the FCA and FSCS logos in a manner that implied full UK consumer protection for overseas clients, and used the logos of well-known investment platforms and fund managers without any indication of whether permission had been obtained, which was incredibly unlikely. The firm’s website also described the principal adviser as a Pension Transfer Specialist, a designation not supported by the adviser’s entry on the FCA Register. No local regulatory authorisation for either country targeted was held.
Example C: Category 3 – Marketing to US-Connected Clients Without SEC Registration
A third firm in the same directory explicitly marketed its services to US citizens and green card holders living in the UK, as well as to expats with US financial ties. The principal’s professional background included a connection to a US-facing advisory firm that was fined and terminated by the SEC for misconduct, including QROPS transfer advice with undisclosed commissions. The firm in question was not SEC-registered and therefore could not lawfully advise on or manage US securities, a fact reflected in its need to outsource all US investment management to third parties. One of the firm’s advisers was actively positioning themselves on professional networks as a specialist for US-connected individuals, despite holding no US regulatory qualifications. Marketing tax advice to expats as though it were a regulated service compounded the picture.
Example D: Directory Due Diligence Failure – Non-FCA Entity Listed as FCA Regulated
In at least one case identified in a UK directory, the firm listed was not FCA-regulated at all, and nor was the individual adviser shown. A search of the FCA Register returned no results for either the firm or the named individual. This represents a failure of the most basic directory due diligence, and illustrates that the premise of using a UK adviser directory to find “FCA-regulated advice” cannot be taken for granted, even at the level of verifying whether a listing is genuine.
Example E: Category 4 – UK Directory Entry Links to FCA Entity; Expat Advice Given Through Separate EU Firm
A further example of the Category 4 structure: a firm listed in a UK directory under an expat-facing category linked its profile to its FCA-regulated UK entity. However, the firm operated a separate EU-regulated entity through which EU resident advice was actually provided. A prospective client finding the firm via the directory would have no reason to understand that the entity they were engaging with through the platform was not the entity that would ultimately advise them, and that the regulatory protections applicable to their advice were therefore entirely different from those implied by the directory listing.
The Platform Facilitator Problem
It is not only advisory firms whose conduct is relevant here. Product and platform providers also have a role to play, and some have been slow to act.
Transact, for example, has reportedly allowed FCA-regulated advisers to place US-connected individuals into funds that have attracted tax issues. The SEC has been actively investigating platform providers whose structures have been used to facilitate advice to US persons without appropriate authorisation, and several have already taken action. Transact, to their credit, is now actively reviewing their non-UK resident exposure and making sure that compliant advice is being provided.
Interactive Investor’s decision to exit the US-connected client market reflects a belated but appropriate recognition that the regulatory exposure in this area is real and growing.
What a Legitimate Expat Adviser Directory Looks Like
For comparison, it is worth noting what a properly structured expat adviser directory requires. The Yardstick Agency’s directory for international advisers, for example, requires firms to demonstrate during an onboarding process that they hold the regulatory permissions to advise clients in the specific jurisdictions they claim to cover. Prospective clients can search by their country of residence and know that any firm returned in their results is authorised to advise them there.
That is the appropriate standard. Advisers on such a directory are not merely FCA-regulated: they are locally regulated in the relevant overseas jurisdiction, and they are permitted to market their services to clients in that jurisdiction. None of those conditions are met by the expat-facing listings in standard UK adviser directories.
What This Means for Consumers
If you are living outside the UK and searching for advice on your UK pension, SIPP, QROPS, or cross-border financial arrangements, the following questions are essential before engaging any adviser:
- Is the adviser, or the specific entity that will provide your advice, regulated in your country of residence, not just in the UK?
- Does the adviser hold a Pension Transfer Specialist qualification if your pension includes safeguarded benefits?
- For US citizens or green card holders: does the adviser hold SEC registration? Advising on US securities without it is unlawful.
- Is the firm’s professional indemnity insurance valid for advice given in your jurisdiction and for how you become a client?
- Is the entity named in the directory the same entity that will actually advise and be responsible for your case?
If an adviser cannot provide clear, documented answers to all of these questions, that is a significant red flag.
How Cameron James Approaches Cross-Border Advice
Cameron James operates differently. We do not use third-party directories or outsourced lead generation. Our clients find us through our own content: published blogs, our YouTube channel, and referrals from existing clients. We take this approach because we believe that informed clients make better decisions and have better long-term outcomes.
Our advisers are individually authorised across the jurisdictions in which we operate.
We are transparent about which regulated entity is advising each client, how that advice is insured, and what the regulatory protections are. We do not use umbrella marketing, which implies FCA protection for clients who will not receive it.
Frequently Asked Questions
Can an FCA-regulated adviser advise me if I live abroad?
Unlikely. FCA authorisation is not relevant to determine whether an adviser can advise you in your country of residence, unless they can utilise a narrow exemption. Without the use of those exemptions, all that matters is whether the adviser holds the local regulatory permission required in your specific jurisdiction. FCA authorisation covers advice to UK residents only and confers no rights whatsoever in relation to overseas clients.
What is reverse solicitation, and can it be used to justify expat advice?
Reverse solicitation is a narrow exception that applies where a client independently seeks out a firm without being solicited. If an adviser appears in an expat-facing directory, on a webpage targeting expats, or in any marketing directed at overseas clients, reverse solicitation very likely cannot apply. The solicitation has already taken place.
I am a US citizen living in the UK. Does this affect which advisers can help me?
Yes, significantly. US citizens and green card holders are subject to US tax obligations regardless of where they live. Advising on US securities, retirement accounts, or tax-efficient investment strategies for US persons requires SEC registration. Most UK-only advisers do not hold this. You should ensure any adviser you work with is SEC-registered and familiar with FBAR, FATCA, and the US-UK Double Tax Agreement.
Why do directories allow these listings if they are problematic?
Most UK adviser directories do not verify overseas regulatory permissions during onboarding. They rely on advisers self-certifying their capabilities. Until directories require evidence of overseas authorisation as a condition of listing under expat-facing categories, the problem will persist. A simple fix would be to require any adviser ticking an expat capability toggle to confirm in writing which overseas jurisdictions they are licensed in. Most would decline, because they know they hold no such permissions under their FCA entity.