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On March 5, 2026, Spain's Financial Intelligence Unit (Sepblac) published guidance on best practices for reducing de-risking in the financial sector. De-risking refers to the unintended consequence of an exaggerated and partial application of anti-money laundering and counter-terrorism financing (AML/CTF) regulations, which can result in the unjustified exclusion of legitimate customers and sectors from financial services. The Financial Action Task Force (FATF), European Banking Authority (EBA), and Anti-Money Laundering Authority (AMLA) have previously highlighted the negative effects of de-risking practices, including financial exclusion and obstacles to realistic risk management. Following inspections conducted at credit institutions in 2025 focused on de-risking issues, Sepblac identified several good practices within the sector that may help mitigate this phenomenon. These practices are presented in relation to compliance with AML/CTF regulations and the complete regulatory framework, balancing different provisions to avoid overly restrictive interpretations. The guidance emphasises that these best practices should be understood as complementary to any other supervisory measures the Bank of Spain may consider in exercising its supervisory function regarding conduct and transparency. The publication reflects a broader regulatory shift toward addressing financial exclusion concerns while maintaining robust AML/CTF compliance. Credit institutions and other financial service providers should review the identified best practices to ensure their risk management approaches appropriately balance regulatory compliance with customer access and market participation.

The Spanish Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC) has issued a guide on good practices to reduce de-risking in the context of anti-money laundering (AML) and counter-terrorist financing (CTF) prevention, following an inspection of credit institutions. Based on observations made during supervisory work and the conclusions reached, good practices within the sector that could help to mitigate the problem of de-risking have been identified. These include: No systemic rejection of a specific customer category; business relationships with customers should be rejected or terminated on an individual basis. Consider alternative reinforcing measures before rejecting or terminating business relationships. Analysing, rather than automatically terminating, business relationships. Decisions not to enter into a business relationship with a prospective customer, to terminate an existing business relationship, or not to carry out an occasional transaction on AML/CFT grounds should be recorded. These good practices should be understood in relation to compliance with AML/CTF regulations, and are without prejudice to any others that the Bank of Spain may consider appropriate when exercising its supervisory responsibilities regarding conduct and transparency.

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Spain's Financial Intelligence Unit Publishes Best Practices for Reducing De-Risking

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Spanish Commission for the Prevention of Money Laundering and Monetary Offences Issues Best Practices for Reducing De-Risking Practices