De-risking

Key facts (as of 29 October 2026)

• Definition (World Bank): financial institutions "terminating or restricting business relationships with clients or categories of clients to avoid, rather than manage, risk".
• Correspondent banking: 75% of large international banks surveyed reported a decline in correspondent banking relationships (World Bank).
• MTOs: over 69% of banking authorities said money transfer operators were the most affected. 28% of MTO principals and 45% of agents surveyed said they could no longer access banking services.
• FSB: a March 2018 stocktake made 19 recommendations in four areas to improve remittance providers' access to banking.
• FATF (February 2025): amended Recommendation 1 so that measures must be "proportionate" to risk, simplified measures are allowed and encouraged in lower-risk cases, and supervisors must consider firms' risk mitigation to prevent over-compliance.
• iGaming: 56 of 119 providers with published industry lists refuse gambling outright, even for licensed operators (Finzil, October 2026).

Why it happens

The World Bank's surveys identified four main drivers banks gave for closing MTO accounts:

1. profitability
2. pressure from other actors (correspondent banks or law enforcement)
3. lack of confidence in the MTO's procedures
4. reputational risk

The FSB added the perceived high AML/CFT risk of the sector, and uneven supervision of remittance providers across countries.

How de-risking cascades

flowchart TD
    A[Regulator fines or enforcement in a sector] --> B[Correspondent bank tightens appetite]
    B --> C[Respondent bank exits the sector]
    C --> D[EMIs and PSPs lose their own banking]
    D --> E[Merchants lose settlement accounts at short notice]
    E --> F[Activity moves to fewer, costlier or less transparent providers]
    F --> A

The loop matters because each exit concentrates risk in fewer providers. When one of them fails or exits, the shock is larger.

Sectors hit hardest

Concentration risk: Brazil as a case study

Brazil's regulated betting market concentrated its banking in a few hands. 15M reported on 30 September 2026 that BTG Pactual provided banking services to 14 licensed betting operators representing about 70% of the market. When MP 1.394 banned fixed-odds betting five days earlier, banks were then tasked by law with returning player balances: operators had two days to send balance lists, and banks seven days to refund players by CPF to the source account. The Ministry of Justice put the sum at R$1.325bn for 26.5m bettors. De-risking was not the cause here; a ban was. But the concentration shows how quickly a sector's banking can become a single point of failure. See Brazil.

Jurisdiction breakdown

What standard-setters say

The FATF's risk-based approach expects firms to assess and manage risk case by case. Capitalixe notes that the FATF has called blanket de-risking inconsistent with its recommendations since 2015. In February 2025 the FATF went further, amending Recommendation 1 to make proportionality explicit and to stop supervisors rewarding over-compliance. The World Bank report asked policymakers, regulators and banks to clarify regulatory expectations and correct "misperceptions that may be resulting in excessively risk-averse behavior".

Why closure letters say so little

In the UK, disclosing that a financial-crime concern prompted a review can amount to "tipping off" under the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017. Banks therefore often give generic reasons (Capitalixe). Capitalixe also reports that UK termination rules in force since 28 April 2026 require 90 days' notice and written reasons, but only for consumers and micro-enterprises.

NoteThe practical lesson is to plan for exits. Keep more than one banking and settlement relationship, in different countries and with different licence types. Finzil found the 31 iGaming-friendly providers on its directory were spread across UK (15), Maltese (9), Canadian (7) and Lithuanian (6) licences.

WarningStablecoins can reduce the number of banks a business depends on, but not to zero. Fiat still has to enter and leave. Strong KYC, source-of-funds records and accurate payment descriptions are what keep the remaining banking relationships stable.

An exit-readiness checklist

Illustrative example: an exit notice

Illustrative example. The broker and banks are hypothetical.

A CFD broker licensed in Cyprus receives a 60-day termination notice from its EMI, with no reason given. It has a second EMI in Lithuania, but that account is capped at €2m a month, below its €5m volume. It also has an onboarded stablecoin settlement route with a MiCA-authorised CASP. In the 60 days it raises the Lithuanian cap, moves introducing-broker commission payments to the stablecoin route where partners accept it, and starts onboarding with a third bank. Client deposits stay on regulated fiat rails throughout, as its regulator requires.

Timeline

Q/A

Is de-risking illegal?

Generally no. Banks can choose their clients. Standard-setters criticise it as a policy outcome because it pushes activity into less transparent channels.

Does a licence protect against de-risking?

It helps, but category-wide policies often ignore individual licences. Read a provider's refused-industries list before applying.

Can I challenge an account closure?

Options depend on the jurisdiction and customer type. In the UK, the new notice rules cover only consumers and micro-enterprises. Larger firms rely on contract terms.

Does using stablecoins make banks more or less nervous?

It depends on evidence. Banks worry about unexplained crypto flows. Clean, documented flows through licensed providers, with analytics reports, are easier to accept.

Why do PSPs get de-risked when their merchants are fine?

Banks see the PSP's whole portfolio. One bad merchant, or a sector the bank exits, can end the relationship for all.

What did the FATF change in 2025?

It amended Recommendation 1 to require proportionate measures and to encourage simplified measures for lower risks.

Sources

• World Bank, surveys on de-risking practices: https://www.worldbank.org/en/topic/financialsector/publication/world-bank-group-surveys-probe-derisking-practices
• FSB, stocktake of remittance service providers' access to banking services (16 March 2018): https://www.fsb.org/2018/03/stocktake-of-remittance-service-providers-access-to-banking-services/
• FATF, updates standards to promote financial inclusion (February 2025): https://www.fatf-gafi.org/en/publications/Fatfrecommendations/update-standards-promote-financial-conclusion-feb-2025.html
• Capitalixe, why forex brokers get debanked (28 May 2026): https://capitalixe.com/blog/forex-broker-debanked/
• FinSet, payments for CFD brokers: https://fin-set.com/payments-for-cfd-brokers
• Finzil (18 October 2026): https://finzil.com/blog/igaming-payment-challenges
• 15M, payments and fintech news: https://15m.com/news/payments-fintech/
• Planalto, Medida Provisória 1.394: https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2026/mpv/mpv1394.htm
• Ministério da Justiça, bets offline: https://www.gov.br/mj/pt-br/assuntos/noticias/bets-fora-do-ar-plataformas-cumprem-determinacao-e-encerram-apostas-no-brasil