Miami, Not New York

The Federal Reserve’s latest data put Banco de Sabadell’s Miami branch at $11.6 billion. For a European bank whose US clients are Latin American, the city is decided before the vehicle.

In late September, BBVA was reported to be seeking regulatory approval for a new Miami office dedicated to investment and corporate banking, five years after it sold its US retail franchise. Whatever form that office takes, it follows a path other Spanish banks have used for years, and the Federal Reserve’s structure data for US offices of foreign banks, updated on October 6, 2026, shows where it leads.

At June 30, 2026, Banco de Sabadell’s Miami branch reported $11.6 billion in assets, up from $10.4 billion a year earlier. Sabadell’s only other US office in the data is a representative office in New York. ABANCA reports a single US branch, also in Miami, at $910 million, up from $795 million. Allfunds, the Madrid-based fund distribution bank, keeps a representative office in Miami.

The client decides the city

None of this is an accident of geography. A European bank whose US business is built around Latin American clients, whether private banking, trade finance or corporate lending to families and groups with interests on both continents, finds those clients in Miami. The language, the time zones and the advisors are there. New York remains the center of US dollar clearing and the wholesale markets, and banks whose US business is primarily institutional still choose it. For a bank following its clients rather than the market, however, the location question tends to answer itself before the vehicle question is asked.

That ordering matters because Florida and New York license foreign banks under different statutes and through different supervisors. A Miami branch, agency or representative office is licensed by the Florida Office of Financial Regulation under Chapter 663 of the Florida Statutes, alongside the Federal Reserve’s review under the International Banking Act. A New York office answers to the Department of Financial Services. The documentation overlaps, but the supervisory relationship a bank will live with for decades does not, and it is set by the city chosen at the start.

Scope follows the client too

Sabadell and ABANCA both operate uninsured, state-licensed branches. That vehicle supports lending, treasury and trade activity and serves clients who are not US retail depositors, while US retail deposit-taking is left to insured banks. For a bank whose US clients are largely non-US residents and companies, that scope is rarely a constraint. More often, it is a fit.

A representative office sits one step earlier on the same path. It may conduct research and marketing, but it may not take deposits or make loans. Allfunds uses one in Miami, Sabadell keeps one in New York alongside its Miami branch, and CaixaBank, with which the Atlantis team has worked, established its representative office in New York. Each reflects a choice about what the bank needed the office to do on its first day.

Three questions to settle first

For a mid-size European bank considering a first US office, three questions usually settle the location. Where do its existing Latin American and US-connected clients already bank and live? Is the business it intends to book driven by clients or by markets? And which supervisor is it prepared to build a long working relationship with? The vehicle, whether representative office, agency or branch, then follows from the scope of activity the bank needs at opening, and can be upgraded as that scope grows.

The Federal Reserve’s data will not make that decision for anyone. It does show that a mid-size Spanish bank has built a single Miami branch into an $11.6 billion office, and that its peers keep choosing the same city. Atlantis advises European and Latin American banks on that choice and on the applications that follow, from the first conversation through opening for business, and we would welcome the conversation.