Skip to content

What went wrong · Unregistered and offshore advisors

“He said he specialized in Americans abroad. I never checked who regulated him.”

Someone sold you an “international” portfolio, offshore bond, or fund — and may not be licensed anywhere.

Every expat community has its circuit of advisors who market specifically to Americans — at clubs, seminars, and residency workshops. Some are registered US brokers or advisors and are answerable in FINRA arbitration or to the SEC. Some are licensed only in the host country. Some are licensed nowhere. The first thing we do with any offshore-advisor case is establish who, if anyone, regulates the seller, because that determines whether a US claim exists at all. If a FINRA member firm or its representative was involved — even peripherally — the firm may be responsible for the sale under “selling away” and supervision rules.

Recognize it

You may have this claim if

  • An advisor you met through an expat group, seminar, or referral rather than a US firm
  • Insurance-wrapped portfolios, offshore bonds, or funds not sold in the United States
  • Layered fees that were never itemized
  • Difficulty finding the advisor on BrokerCheck or the SEC’s adviser search
  • A US-registered broker who “introduced” you to the product or advisor

The rule

What the firm owed you

FINRA Rule 3280 (private securities transactions) and Rule 3110 (supervision) make member firms responsible for outside sales by their representatives that they knew or should have known about. Where no US-registered person was involved, we will say so and point you to the right forum.

From abroad

Why distance does not matter here

Registration status is a public record we check in minutes. The rest of the claim is documents.

Guides

  1. The FINRA Six-Year Eligibility Rule, Explained for Expats FINRA Rule 12206 bars claims six years after the event. What counts as the event, why state limitations periods may be shorter, and why waiting hurts. 6 min read
  2. Offshore and Expat Specialist Advisors: Who Regulates Them How to check whether an “expat specialist” advisor is registered — BrokerCheck, the SEC’s IAPD, host-country regulators — and what unregistered means. 7 min read
  3. Selling Away: When a Side Deal Is the Firm’s Problem Your broker sold you something that never appeared on a statement. FINRA Rules 3280 and 3110 explain when the brokerage firm is responsible anyway. 7 min read
All guides

Free case review

Sound familiar? Send the statements and let us check.

Free and confidential review by Richard Frankowski. Calls scheduled in your time zone, never ours.

Call — US toll-free

+1 888 741 7503

From abroad: +1 205-390-0399

Start with the form

The other four

Often more than one applies.