
They explain why higher risks and tougher sanctions for non-compliance make de-banking an obvious choice for banks intent on mitigating their risks. For example, where clients are politically exposed persons (PEPs), banks not only face severe sanctions should their compliance regime be breached but they also face a duty ‘to apply enhanced due diligence, risk assessments and ongoing monitoring on the basis that they pose a heightened risk of money laundering or bribery’. An estimated 90,000 individuals are categorised as PEPs.
The authors look at whether there is a right to a bank account in the UK, and whether proposed reforms will reduce de-banking.