A bank account outside the CRS: Dominican Republic, Puerto Rico or El Salvador, and the bank that wanted a year's rent up front

Punta Cana, October 2026. Our team is sitting in the first bank, the documents went in by email beforehand, and still the list arrives: a signed lease, paid a year in advance and confirmed by a lawyer or notary, a residency permit, two reference letters from people who know you in the country and a reference letter from your own bank. A few hours later, at a different bank, the same account is close to opening without any lease at all. That is how our video of 22 October 2026 showed it.

The Dominican Republic is one of three stops that our video of 18 October 2026 presented as routes to an account outside the automatic exchange of information: the Dominican Republic, Puerto Rico and El Salvador. Here we compare the three from the bank's side. What do the OECD lists say, which documents are required, what does the deposit guarantee pay, and where can you open an account from a distance? Residence and permits are a subject of their own; for those, our colleagues at VidaLibrePlan are the network's address.

What the OECD says about the three

Whether a country exchanges account data automatically is set out in the OECD Global Forum's status of commitments for the automatic exchange of financial account information. The current edition is dated 30 September 2026. The Dominican Republic and El Salvador sit in its last group: developing countries not asked to commit and that have not yet set a date for their first exchanges.

The United States appears in none of the exchange groups. A footnote records that the US has exchanged information automatically under FATCA since 2015 and has signed intergovernmental agreements to do so. Puerto Rico follows that route: as a US territory, Puerto Rico is not part of the CRS.

Outside the CRS does not mean outside every channel, though. The Dominican Republic has a Model 1 FATCA agreement with the United States, in force since 17 July 2019 according to the US Treasury. That channel runs to Washington, not to Europe. For El Salvador, the Treasury's table lists no such agreement.

Dominican Republic: what the banking supervisor requires

What a bank has to collect is set by the Superintendencia de Bancos in its Instructivo sobre Debida Diligencia, its due diligence instruction. The third version applies under Circular SB 005/22 of 2 March 2022 and, according to the supervisor, remains in force. Its Annex I lists the details for individuals, local and foreign alike: name as shown on the ID card or valid passport, nationality, ID or passport number, place of birth and residence, date of birth, marital status, occupation, employer, phone and email.

The annex then names the documents: a copy of the passport or home-country ID, for foreigners a copy of the document issued by the immigration authority, the Dirección General de Migración, expressly with or without permanent residence, and proof of income. For employees that is a letter from the employer or a bank statement showing the salary. Self-employed foreigners present their latest tax return filed with the tax authority of their own country.

A lease paid a year in advance is not on that list. The annex also explains why banks may still ask for more: each bank weighs the documents according to its own risk appetite, and whatever its internal policies add on top stays untouched. Its list of risk factors contains one point aimed squarely at foreigners without residence: whether a non-resident customer's needs could be better served somewhere else.

And from a distance? The instruction allows banks to take on new customers through channels without physical presence, but only for products rated low or medium risk, with controls that match the high risk of that route, and with transactions limited until verification is complete. Anyone without residence in the country should therefore plan for an appointment in person.

A year's rent up front: how the two banks decided

That latitude was on full display in Punta Cana. Our team had emailed the documents to several banks in advance. For the standard route at the counter, the first bank wanted:

• a signed lease, paid a year in advance and confirmed by a lawyer or notary,
• a residency permit in the country,
• reference letters from two people who know you in the Dominican Republic,
• a reference letter from your bank, which some app-only accounts simply do not issue,
• and documents that in part even had to carry an apostille.

The second bank worked without a lease. After about two hours in the branch for two personal accounts, the opening was as good as done; head office reviewed it overnight, and only the signatures remained. Same file, two banks, two answers.

What that means for you: the supervisor sets the floor, the bank sets the ceiling. Arrive with your passport, proof of income and your latest tax return, and you cover the supervisor's list. A lease and reference letters are house rules of individual banks, and they can be clarified beforehand instead of surprising you at the counter.

What deposit insurance pays in the Dominican Republic

The deposit guarantee sits in Article 64 of the Ley Monetaria y Financiera 183-02, the monetary and financial law. The central bank runs a Fondo de Contingencia funded by mandatory contributions from the banks. Under letter c, as amended by the Monetary Board on 15 December 2020, public deposits are guaranteed up to 1,860,000 Dominican pesos from the fund's available resources, and up to 30 per cent of the privileged liabilities of the bank in dissolution. The guarantee applies only within the dissolution procedure of Article 63.

Two things follow. The cap is set in pesos, and it depends on what the fund holds at the time. Anyone holding larger sums is better off spreading them across several banks and countries; how the schemes compare is set out in Deposit guarantees worldwide.

For residence, tax and daily life in the Dominican Republic, see VidaLibrePlan.

Puerto Rico: US law, US dollars and two kinds of institution

Puerto Rico is a US territory and pays in US dollars. For your account that means two things. As a US territory, Puerto Rico is not part of the CRS. And banks in Puerto Rico are classed as territory financial institutions, not as foreign banks for FATCA purposes: the US Treasury regulations define them as financial institutions organised under the laws of a US territory and state expressly that such an institution is not a foreign financial institution.

On the island there are two worlds. The traditional local banks work like banks on the mainland: if you want an account, you go in person. In return, an institution based in Puerto Rico can be FDIC insured, because the federal deposit insurance statute counts Puerto Rico as a State. The FDIC covers USD 250,000 per depositor, per insured bank, for each account ownership category.

The second world is the International Financial Entities, IFEs for short, which the English version of the statute calls international financial institutions. They need a licence from the Commissioner of Financial Institutions (OCIF) under the International Financial Center Regulatory Act, Act 273-2012, last amended by Act 44-2024. They take deposits only from foreign persons, meaning customers neither resident nor incorporated in Puerto Rico, and only with the supervisor's prior authorisation. Their paid-in capital is, as a rule, at least USD 10 million.

These institutions are built for non-residents: US dollar accounts, some in further currencies too, opened from a distance. We state the other side plainly: there is no FDIC insurance for IFE accounts, and no statutory deposit protection either.

In Puerto Rico we accompany the account opening: remotely, in US dollars, without residence. How it works and what it costs is on the page Open a bank account in Puerto Rico.

El Salvador: US dollars, bitcoin and a small deposit guarantee

El Salvador pays in US dollars too. Under Article 3 of the Ley de Integración Monetaria, Legislative Decree 201 of 30 November 2000, the dollar has unrestricted legal tender status; the Banco Central de Reserva still relies on that article today. For your account that means no exchange rate risk against the dollar.

Bitcoin remains legal tender. Since the reform of the Bitcoin Law by Legislative Decree 199 of 29 January 2025, however, accepting it is voluntary, and only individuals and wholly privately owned companies may accept it. The bitcoin infrastructure our team describes in the video, from the taxi to the small shop, therefore rests on people who choose to take part.

The deposit guarantee is small. From 1 January 2026 to 31 December 2027 the Instituto de Garantía de Depósitos covers USD 12,054 per person and per member institution. Anyone who holds more in a Salvadoran account carries the rest themselves.

On the OECD list El Salvador sits in the same group as the Dominican Republic, with no date for a first exchange. In the video of 18 October, the aim in San Salvador was to open a standard account. Residence, tax and stays in El Salvador are covered by VidaLibrePlan.

The three routes side by side

• Dominican Republic: no CRS date yet according to the OECD, a FATCA agreement with the US, deposit guarantee up to 1,860,000 pesos, the supervisor's document list plus each bank's house rules, in practice an appointment in person.
• Puerto Rico: not part of the CRS as a US territory, banks classed as territory financial institutions, US dollars. Local banks in person and with FDIC cover up to USD 250,000; IFEs remotely and without FDIC insurance.
• El Salvador: no CRS date yet according to the OECD, the US dollar as legal tender, bitcoin voluntary, deposit guarantee of USD 12,054 per person and institution.

A simple order follows. If you want a dollar account without travelling, you end up in Puerto Rico. If you are on the ground anyway and can handle house rules, the Dominican Republic has banks that decide quickly on a clean file. And if you live in El Salvador, you have the dollar in daily life but a deposit guarantee better suited to a salary account than to a reserve. Which other countries sit outside the exchange is set out in our list of non-CRS countries.

What stays at home

Opening and holding an account abroad is legal. The income stays taxable where you live, and none of this is about hiding anything. Whether you live in the UK, Norway, Sweden, Denmark or Finland, interest from an account in Santo Domingo, San Juan or San Salvador belongs on your tax return like any other foreign income. The absence of an automatic report changes what your tax office receives on its own; it changes nothing about what you owe and what you declare.

What an account outside the CRS gives you is privacy from an automatic data stream, a second currency and a second banking system next to the one at home. Tax freedom it never gives.

The three destinations show what matters with any account outside Europe: know the supervisor's list, ask about the bank's house rules beforehand, and know how much the deposit guarantee really carries. Settle that before the first appointment, and you sit at the counter with an account that fits, not with a year's rent paid in advance.