Posted by Rachel Tookey, Stewart Plant and Leontia McArdle on 12 March 2024
Tagged to Consumer Duty, Payments, Regulation

The de-banking of customers, and the legal and regulatory implications that can arise, are not new issues. However, those issues have come into sharp focus following recent publicity surrounding a high-profile account closure. This article considers what payment services firms can expect next following the increased scrutiny from customers, media, government and the regulators.


It has always been the case that payment services providers (PSPs) must be on heightened alert when providing financial facilities to a politically exposed person, due to the higher risk of money laundering and bribery challenges. When presented with financial crime concerns, PSPs face a balancing exercise of meeting regulatory obligations by stopping wrongful use of payment services, whilst not inadvertently tipping off a customer – which can be a fine line to tread.

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