Here Is What You Need to Know – and What to Do Next.
If you are a US resident with a UK pension or investment account held with Bestinvest, you may already have received a letter like the one below. Or you may be about to.
Bestinvest, a trading name of Evelyn Partners Investment Management Services Limited, is actively writing to clients who have disclosed a US residential address, advising them that their accounts will be closed within 30 days. The firm’s position is unambiguous: it does not hold the regulatory permissions required to continue serving clients based in the United States, and it is acting on that limitation.
This blog explains what that means in practice, why it is happening, what the broader implications are for non-UK residents holding investments with UK-domestic platforms, and how Cameron James is positioned to help.
The Letter Bestinvest Is Sending to US Residents
The following is the substance of correspondence Bestinvest has been sending to affected clients:
| “As you have confirmed your address and you currently reside in the United States of America (USA), we will unfortunately have to discontinue our service relationship.” “Bestinvest are only authorised by the Financial Conduct Authority (FCA) to provide investment services to clients based in the United Kingdom. Because you now reside in the USA, and we have been made aware of it, your relationship with us also must comply with US securities laws and regulations.” “We do not have the necessary US regulatory approvals and permissions to allow us to continue to provide investment services to you. We are therefore required to ask you to seek the services of another financial services provider with the necessary US regulatory permissions and close down your account.” “In accordance with your terms and conditions with Bestinvest, we will cease to provide investment services to you with effect from 30 days from today.” |
The letter also notes that if your portfolio value exceeds 250,000, you may be eligible for discretionary investment services through Evelyn Partners’ separate US-facing proposition. For everyone else, the instruction is clear: find another provider.
Clients holding a SIPP with Bestinvest receive separate transfer-out paperwork, as the process for moving a SIPP differs from a General Investment Account or ISA. The 30-day window applies regardless of account type.
Why Is This Happening?
This is not a policy change or a sudden tightening of Bestinvest’s terms. It is the logical consequence of a regulatory framework that has always applied, now being enforced more systematically.
FCA Authorisation Does Not Travel to the US
Bestinvest is authorised and regulated by the Financial Conduct Authority. FCA authorisation permits the firm to provide regulated investment services to clients in the United Kingdom. It does not, and has never, authorised the firm to provide ongoing investment services to clients residing in the United States.
To serve US residents as an investment adviser, a firm must be registered with the Securities and Exchange Commission (SEC) or qualify for a specific exemption. Bestinvest has neither. Its custodian, SEI, does not comply with IRS reporting requirements for US individuals. The result is that the moment a client discloses a US address, the relationship becomes non-compliant under US securities law.
Bestinvest is doing the correct thing in ending these relationships. The problem is not with Bestinvest’s response – it is that many UK residents who later moved to the US spent years on a platform that was never equipped to serve them in their new country of residence.
The Trigger: Residency Disclosure
What typically triggers the closure process is a routine residency check. Bestinvest, like other UK platforms, periodically asks clients to confirm their address. When a client’s address on file is a PO box – often used by expats who want to maintain a nominal UK address – the platform requests a residential address. Once a client discloses they are in the US, the compliance process begins.
The correspondence seen in practice follows this pattern: the platform requests a residential address, the client provides a US address, the platform confirms it cannot continue the relationship, and a 30-day notice period begins. Clients who have been using a PO box or a relative’s UK address for years may find this happens suddenly and with limited notice.
The Broader Problem: Why UK-Domestic Platforms Cannot Serve Non-UK Residents
Bestinvest’s position is not unusual. It is the standard reality for virtually every UK direct-to-consumer investment platform. The issues fall into five interlocking categories.
1. Regulatory Perimeter
UK platforms are designed for UK residents. FCA authorisation covers UK-based clients. Serving clients in the US requires SEC registration. Serving clients in France, Germany, Spain, or elsewhere in the EU requires the appropriate national authorisation or MiFID II passport equivalent. Serving clients in Australia requires ASIC authorisation. Serving clients in the UAE requires DFSA or SCA registration.
Most UK platforms hold none of these permissions. When a client moves abroad, the platform’s ability to continue providing regulated services ends at the UK border. The Bestinvest closure letters are a visible example of this playing out in practice. There is a general leniency around workplace schemes, but personal pensions don’t receive the same treatment, and thus standard local platform registration rules can apply.
2. US Securities Law: A Higher Bar
Of all overseas jurisdictions, the US creates the most acute compliance challenge for UK platforms. The SEC takes a strict extraterritorial view of investment adviser regulation. A UK firm managing money for a US resident is, in the SEC’s view, providing investment advisory services in the US – and must be registered accordingly unless an exemption applies.
The practical consequence is that UK platforms almost universally exclude US persons entirely. Bestinvest’s closure letters make this explicit. AJ Bell, Interactive Investor, Hargreaves Lansdown, and most other major UK platforms carry similar restrictions. This is not a coincidence – it reflects a deliberate regulatory boundary.
3. Banking and Payment Infrastructure
UK investment platforms are built around UK bank accounts. Direct debits, BACS, and CHAPS transfers all assume a UK current account. Many UK banks close or restrict accounts for customers who move abroad, leaving non-UK residents without a practical way to fund, withdraw from, or repatriate assets held on UK platforms. International wire transfers carry fees, delays, and minimum amounts that do not suit regular investing or pension drawdown.
4. Foreign Exchange Costs and Currency Risk
If you live and spend in US dollars, your UK pension or investment account is denominated in sterling. Every contribution and every withdrawal passes through a currency conversion. UK platforms offer no competitive FX rates for international transfers, and no capability to manage the structural currency risk that arises when your income and your assets are in different currencies.
For a US resident drawing income from a UK SIPP, an unmanaged sterling/dollar position represents a meaningful and ongoing drag on retirement income – entirely separate from investment performance.
5. Dual-Jurisdiction Tax Complexity
A UK SIPP held by a US person sits at the intersection of two tax systems that do not speak to each other particularly cleanly. Key issues include:
- The UK-US Double Taxation Agreement (DTA) at Article 17 governs how UK pension income is taxed, but the interaction with US state taxes, Social Security, and Medicare is not straightforward.
- A UK SIPP may be treated by the IRS as a foreign grantor trust, potentially triggering Form 3520 annual reporting obligations.
- UK investment funds held outside a pension wrapper are typically classified as Passive Foreign Investment Companies (PFICs), creating punitive US tax treatment including excess distribution rules and a mark-to-market election requirement.
- ISAs receive no recognition from the IRS. Income and gains within an ISA must be reported on a US tax return as if the wrapper did not exist.
- Withdrawals from a UK pension by a US resident may be subject to UK withholding tax in addition to US income tax, with DTA provisions governing the available relief.
A UK execution-only platform is not equipped to navigate any of this. Bestinvest’s letter itself acknowledges this gap, recommending that clients seek professional tax advice to review the appropriateness of their investments from a US tax perspective. That advice is correct – but it is advice Bestinvest cannot itself provide.
What Happens to Your SIPP if Your Account Is Closed?
The Bestinvest closure letters make a distinction that matters: SIPP transfer-out paperwork is separate from that for GIAs and ISAs, because the transfer process is different.
When Bestinvest closes your account, your investments will continue to be held with the current product provider, but Bestinvest will no longer act as your servicing agent. The product provider – in Bestinvest’s case, the SEI custody arrangement – may then contact you separately regarding their own policy on non-UK residents.
Your options at that point are broadly:
- Transfer the SIPP to an International SIPP provider designed for non-UK residents, which can hold the assets, accept future contributions if applicable, and facilitate drawdown in a structure that is compliant from both a UK and US perspective.
- Take pension benefits if you are at the minimum pension age (currently 57 from 2028), which may allow you to crystallise the fund, pay taxes and move assets into a more internationally appropriate structure, which may work for small accounts.
- Transfer to a QROPS, but this is not easily doable, nor advisable, for a US Resident.
The right answer depends on your age, the size of your pension, your US tax position, and your long-term retirement plans. It is a decision that should be made with proper regulated advice from an adviser who holds the appropriate authorisations in the US.
How Cameron James Can Help
Cameron James is a cross-border financial planning practice built specifically for internationally mobile clients. Our advisers work with UK nationals in the US, US persons with UK pensions, and dual-jurisdiction individuals who need advice that spans both regulatory and tax frameworks simultaneously.
If you have received a closure notice from Bestinvest – or if you hold a UK pension or investment account and you live in the US – here is how we can help.
Regulatory Authorisation in the Right Places
Cameron James Ltd is authorised and regulated by the FCA. Our US Client advisers hold individual SEC authorisation marketing under Cameron James USA, which means they are properly authorised to provide investment advisory services to US residents. This is the regulatory structure that Bestinvest does not have – and the reason its letter tells you to find a provider that does.
International SIPP Access
We work with International SIPP providers designed for non-UK residents. Unlike Bestinvest’s arrangements, these providers:
- Accept non-UK resident pension holders
- Comply with IRS reporting requirements applicable to US persons
- Offer multi-currency functionality, including US dollar withdrawal capability
- Provide a range of investment options suited to cross-border wealth management
- Can be structured to minimise tax leakage across UK and US jurisdictions
- Work with SEC authorised advisers to provide compliant advice and make the platform compliant in the eyes of the SEC
UK-US Tax Planning
We work with qualified tax professionals on both sides of the Atlantic to ensure that pension withdrawals, investment restructuring, and asset consolidation are planned in a way that minimises your combined UK and US tax exposure. This includes Article 17 DTA analysis, IRS Form 3520 reporting considerations, PFIC compliance for investments held outside the pension wrapper, withholding tax efficiency on UK pension withdrawals, and FBAR and Form 8938 obligations for US persons with UK financial assets.
Currency Management
We advise on FX strategy as part of the overall financial plan – including the timing of currency conversions, the use of specialist FX services rather than bank rates, and the management of sterling/dollar currency risk within a pension drawdown strategy.
| Cameron James – cross-border financial planning for UK-US clients: – FCA authorised (Cameron James Limited, FCA reference 945566)- Individual adviser SEC authorisation via Beacon Global Advisor Network, LLC (CRD 288833)- International SIPP access for US residents with UK pensions- UK-US DTA, FBAR, Form 8938, and IRS Form 3520 planning- Pension drawdown structuring across both jurisdictions- No platform or product ownership conflicts |
What to Do If You Have Received a Bestinvest Closure Notice
The 30-day window in Bestinvest’s closure letters is short. Acting quickly matters, both to avoid your account being closed without a plan in place, and to ensure any pension transfer is initiated with enough time to complete properly.
Immediate priorities:
- Do not simply sign and return the transfer-out paperwork without taking advice on where the pension should go. A poorly planned transfer can have lasting tax consequences in both the UK and the US.
- Confirm the total value of all accounts held with Bestinvest – SIPP, GIA, and ISA separately – so you have a clear picture of what needs to move.
- Note that an ISA cannot be transferred to an overseas equivalent. We work with ISA providers that allow US connected persons alongside an SEC authorised adviser.
- Contact Cameron James to arrange a free initial consultation before the 30-day window closes.
A Cameron James adviser will review your complete position, confirm what options are available to you, and set out a clear plan for moving your assets to an appropriate structure – one that is properly authorised to serve you where you actually live.
Regulatory notice
Cameron James Limited is an Appointed Representative of Blacktower Financial Management Limited, authorised and regulated by the Financial Conduct Authority (FCA reference 945566). Cameron James advisers provide investment and financial advisory services to US persons through Beacon Global Advisor Network, LLC, a registered investment adviser with the Securities and Exchange Commission (SEC CRD No. 288833). Cameron James the firm is not SEC-registered; individual advisers hold SEC authorisation in their own right. The information in this blog is for general guidance only and does not constitute regulated financial or tax advice. Pension transfer decisions, including transfers to International SIPPs or QROPS, are significant and should only be made following regulated advice specific to your circumstances. Tax rules and pension regulations vary by jurisdiction and are subject to change.
