During remarks this week at the American Bankers Association and the American Bar Association Money Laundering Enforcement conference, Treasury Acting Under Secretary Adam Szubin provided some clarity on de-risking and anti-money laundering controls.
Szubin defined “de-risking” to mean “instances in which a financial institution seeks to avoid perceived regulatory risk by indiscriminately terminating, restricting, or denying services to broad classes of clients, without case-by-case analysis or consideration of mitigation options.” Typically, de-risking is discussed in the cross-border context, but the term may be applied to some domestic financial relationships as well, he said.
