THE DEPARTMENT OF THE TREASURY’S DE-RISKING STRATEGY
EXECUTIVE SUMMARY

For this study, Treasury focuses on “de-risking” as the practice of financial institutions terminating or restricting business relationships indiscriminately with broad categories of clients rather than analyzing and managing the risk of clients in a targeted manner. Such a practice is not consistent with the risk-based approach that is the cornerstone of the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) regulatory framework for U.S. financial institutions under the Bank Secrecy Act (BSA) and implementing regulations.

As detailed in this strategy, de-risking undermines several key U.S. government policy objectives by driving financial activity out of the regulated financial system, hampering remittances, preventing low- and middle-income segments of the population, as well as other underserved communities, from efficiently accessing the financial system, delaying the unencumbered transfer of international development funds and humanitarian and disaster relief, and undermining the centrality of the U.S. financial system. As such, the strategy aims to provide potential solutions to promote financial inclusion by reducing barriers to the legitimate use of financial services as much as possible, while supporting efficient, safe, and affordable domestic and cross-border transactions.

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