Yes, you are quite right it is the patriot act that is the problem. It is down to the individual banks how they go about enforcing it.
I have spent so long trying to sort this out. However, I spoke to a very helpful lady at TD Bank yesterday. They don’t have a branch in PR. However, as long as it’s a USA account it’s not an issue for us.
Anyway, the upshot is that it is entirely possible and legal to open a bank account without SNN, ITIN, EIN numbers.
We have to take our ID - passport, driving licence, utility bill from our house in PR to show our physical address (we will probably take our house deeds and perhaps other back up bits), then a E8-BEN form has to be filled out at the bank. We have a PO Box in Juncos for our mail to be sent. Apparently she explained they set up accounts for Canadian Citizens all the time.
We have to physically go into a branch to open an account, to enable them to verify who we are. All that means is, on our next visit we have to stop on the East Coast, which isn’t a problem as we have to come through USA to connect to PR from UK anyway.
I think Citi Bank probably have a similar set up to TD Bank. However, I haven’t called them up to confirm.
Also I spoke to HSBC UK yesterday too. As one of our friends has a place in Miami, he told us to try HSBC International (who he uses). We don’t bank with them here in the UK. However, if you do have a UK account that you use, they can arrange a USA account to be set up (not a dollar currency account, a proper USA bank account). The man did inform me it wouldn’t be possible just to set up a bank account with HSBC UK and not actually use it and then ask for a USA account. Which is fair enough.
I have given up with the PR banks, I was trying to communicate with them yesterday and they had changed their goal posts again, informing me that there was no possibility of opening an account unless I had a SSN (even with an ITIN number they wouldn’t open an account now allegedly). Who knows?!. It just got me super annoyed. I thought English Banks were the worst, it appears not!.
Anyway, PR bankings loss is a USA bankings gain.
Hey ho!.