Best practices for reducing de-risking

The de‑risking phenomenon related to AML/CFT is a relatively new concept, being an unintended consequence of an exaggerated and partial application of AML/CFT regulations, without considering the complete regulatory framework and the balance among different provisions.

The FATF, the EBA and AMLA have highlighted the negative effects that de‑risking practices may cause, by unjustifiably excluding legitimate customers and/or sectors, potentially leading to situations of financial exclusion and hindering a realistic management of risk.

In 2025, Sepblac carried out inspections at credit institutions focused on the issue of de‑risking from the perspective of the application of AML/CFT regulations. Once these inspections were completed, and considering the observations made during them, several “good practices” have been identified within the sector that may help mitigate this issue. These good practices should be understood in relation to compliance with AML/CFT regulations, without prejudice to any others that the Bank of Spain may consider in the exercise of its supervisory function regarding conduct and transparency.