De-risking

Spec sheet // Glossary // DE-RISKING
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Glossary · AML

De-risking

Also called debanking, account exiting

Definition

De-risking is when banks close or refuse accounts for whole categories of customers, such as money service businesses, charities or correspondent banks, to avoid risk rather than manage it case by case. Regulators and FATF treat wholesale de-risking as inconsistent with the risk-based approach because it pushes activity into less transparent channels.

MANAGE THE RISKEXIT THE SEGMENT
Fig. 1 · De-risking
FATF Recommendation 1 revision · SI 2025/688 · Executive Order 14331
Key rulesFATF Recommendation 1 revision · SI 2025/688 · Executive Order 14331
Applies toUK payment service providers
RegionsGlobal · UK · US
01

How it works

De-risking usually follows a cost review. When enhanced due diligence on a customer segment costs more than it earns, or a past enforcement action raises perceived exposure, a bank exits the segment. Affected customers lose payment access or move to smaller providers. Correspondent banking has seen many exits, cutting some countries' access to dollar and euro clearing.

Rules now push firms to justify exits. FATF's February 2025 changes stress proportionate measures and simplified due diligence for lower risk. UK payment providers must give 90 days' notice and reasons when ending payment contracts made from 28 April 2026. In the US, a 2025 executive order targets politicised debanking. Firms now document individual risk decisions instead of segment-wide exits.

Step 1Assess individuallyRate each customer's risk rather than whole segments.
Step 2Mitigate firstConsider enhanced due diligence and monitoring before exit.
Step 3Document decisionRecord the specific risk reasons for any closure.
Step 4Give noticeProvide required notice periods and reasons to customers.
02

The rules

Global · February 2025FATF Recommendation 1 revisionAmendments to FATF Recommendation 1 and Interpretive Notes 1, 10 and 15

Replaces commensurate with proportionate and encourages simplified measures for lower risks to support financial inclusion.

Countries and FATF-regulated firms
UK · 28 April 2026SI 2025/688Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025

Requires at least 90 days' notice and reasons when terminating framework contracts entered into from 28 April 2026.

UK payment service providers
US · 7 August 2025Executive Order 14331Guaranteeing Fair Banking for All Americans

Directs federal banking regulators to remove reputation risk from guidance and act against politicised or unlawful debanking.

US banks, credit unions and other financial institutions
03

Common questions

Is de-risking illegal?

Closing an individual account for documented risk reasons remains lawful. Regulators object to blanket exits of whole customer groups without individual assessment. In the UK, notice and reason requirements now apply to many payment account terminations.

Which customers are most affected by de-risking?

Money service businesses, charities working in high-risk regions, fintechs, correspondent banks in smaller economies and some politically exposed persons have been most affected. Many lose access to mainstream payment services as a result.

Why does FATF see de-risking as a problem?

FATF says wholesale exits undermine financial inclusion and push money into informal channels that are harder to monitor. Its 2025 changes ask countries and firms to apply proportionate, risk-based measures instead.