[eesmith]

Many banks have SWIFT accounts (see https://en.wikipedia.org/wiki/Society_for_Worldwide_Interban... ). This has been used by the US for purposes that other countries disagree with. As a result, and quoting from that URL:

> In September 2018 the European Union foreign policy head, Federica Mogherini, proposed the development of a new "special purpose financial vehicle" intended to bypass the U.S. controlled Society for Worldwide Interbank Financial Telecommunication payments system - commonly known as SWIFT. The seven founding members of this new system are to be Iran, the European Commission, Germany, France, the U.K., Russia and China - but not the United States.

Web sites like http://non-fatca-banks.com/pk.html list which banks are members of SWIFT, because that means they are exposed to penalties should they fail to follow FACTA reporting laws. For example, the National Bank of Pakistan followed FACTA, see https://www.nbp.com.pk/fatca/index.aspx .