The Weakest Link in Most Plan B Strategies Isn't the Passport. It's the Bank.

A Dominica-licensed offshore bank has emerged as being at risk of liquidation after US authorities froze assets held through one of its payment processors. The strain traces back not to the bank's own licence or conduct, but to regulatory action against the US payments processor through which it held and moved substantial funds. The lesson has nothing to do with citizenship by investment, and everything to do with it. On 15 July 2026, US prosecutors in the Eastern District of California filed a civil forfeiture complaint against roughly $84.2 million held in US accounts belonging to Capstone Ltd., a Montana-based payments processor. Prosecutors allege Capstone ran an unlicensed money-transmitting business and misled the US banks, Wells Fargo and JPMorgan Chase among them, that held its accounts. Capstone's client on the other end of those wires was EQIBank, an offshore digital bank licensed under Dominica's Offshore Banking Act and popular with internationally mobile clients precisely because it is not a traditional correspondent-dependent retail bank. By EQIBank co-founder Christopher Burke's own account, in a June court filing, the frozen funds represent roughly 80% of the bank's assets. He said the bank "cannot operate much longer" without recovering them. Dominica's Financial Services Unit placed EQIBank under enhanced supervision on 5 June 2026, and on 16 July a federal judge rejected EQIBank's own request to recover the funds, citing lack of jurisdiction once the forfeiture proceeding had begun. No EQIBank depositor is accused of wrongdoing. Stablecoin issuer Tether, which does hold funds there, said this week its exposure represented less than 0.034% of its reported total assets, a share that would work out to roughly $64 million against its reported $187.75 billion balance sheet, a calculation, not a figure Tether itself disclosed, and said it had no knowledge of Capstone's alleged conduct. For Tether, that is a rounding error, disclosed and absorbed without incident. For a depositor with meaningful savings concentrated at EQIBank rather than spread across several institutions, the same event could be existential.

The plumbing, not the passport

Clients building a Plan B spend most of their attention on the front door: which citizenship, which residency, which investment programme. The back office, where the actual money sits and moves, gets far less scrutiny, and this week is a reminder of why that is a mistake. The strain on EQIBank stems not from any finding against its own conduct or its own licence, but from a US regulatory action against a third-party payments processor two steps removed from any individual depositor. The bank, the processor and the depositor's own funds were never really separate things. This week showed how quickly that stopped mattering.