You are effectively limited to the few large banks that can handle the red tape. It wasn't designed to make US persons' life abroad miserable, even if it did succeed handily to the point some US citizens are opting to renounce their citizenship rather than keep enduring the pain. The intent was to make the IRS' compliance processes easier. The level of detail in the FinCEN reporting Americans with financial assets abroad has also dramatically risen in the last 20 years. It used to be you just sent a list of banks along with whether your assets there exceed $10,000 or not, now you have to send a detailed summary with a max account balance (adjusted for exchange rate).