Thematic review of the de-risking phenomenon

In March 2025, the Financial Supervisory Authority (FIN-FSA) conducted a survey of deposit banks operating in Finland for a thematic review of the extent of the de-risking phenomenon¹ in Finland. The survey also examined how banks take into account the aspects of financial inclusion and access to banking services in their procedures and decision-making, when customer relationships are established, services are restricted and customer relationships are terminated, in particular due to the obligations of anti-money laundering regulation.

The survey included 10 deposit banks operating in Finland, and it covered the customer relationships of banks with both legal persons and private persons. The study is a continuation to the previous two thematic reviews on de-risking in 2022² and 2023³.

Key observations and conclusions of the thematic review and FIN-FSA’s recommendations

According to answers obtained from the thematic review, banks seem, for the most part, to be following the recommendations of the FIN-FSA's previous thematic reviews in customer relationships with both legal persons and private persons.

Legal persons as customers

An important observation in the thematic review was that the rejection rate of legal persons' account applications is on the rise. In 2024, around 11% of all customer account applications were rejected, mostly for reasons other than those arising from anti-money laundering legislation. The number of terminations of account customer relationships with legal persons is also on the rise, with approximately half of these terminations being due to obligations under anti-money laundering legislation.

The FIN-FSA believes that the observations indicate a de-risking phenomenon related to legal persons. On the other hand, it also indicates that banks use different criteria when selecting customers.

Private persons as customers

A key observation regarding customer relationships with private persons is that the rejection rate for account applications remains low. Only about 0.8% of all customer account applications were rejected in 2024. This is likely explained by the statutory obligation of banks to provide basic banking services to private persons. The number of terminated account customer relationships with private persons shows a clear rise, but the reasons for the terminations show that among them are accounts that are closed because customers have not used them, which does not necessarily have negative consequences for customers. 

According to the FIN-FSA, the rise in the number of terminated customer relationships and the most common reasons for termination may indicate that banks have specified their practices and guidelines in line with anti-money laundering legislation. To some extent, the increase in the number of terminated customer relationships can also be explained by the de-risking phenomenon.

Recommendations to banks

Documentation and statistics related to establishing and terminating customer relationships

There are still shortcomings in banks’ statistics and documentation related to the establishment and termination of customer relationships, which makes it difficult to form an overall picture of the de-risking phenomenon. Deficiencies in statistics also weaken the bank's ability to form an overall picture of its own risk-taking.

The FIN-FSA recommends that banks introduce procedures to collect statistics on rejected and terminated customer relationships and the reasons for the rejections and terminations. Data should be collected on both private persons who are customers and legal persons who are customers according to the form of association. The statistics should show the number of customer relationships rejected and terminated as a result of the anti-money laundering regulation in relation to the total number. If necessary, the statistics should be made available to the FIN-FSA.

Processing times for customer payment account applications

There is no precise data available in the banks on the processing times of customers' payment account applications, as most banks do not use actual monitoring systems for the processing times of payment account applications. There is no statutory obligation regarding processing times for payment account applications or their monitoring. However, basic payment accounts are subject to a processing time of 10 banking days as stipulated by law. According to the banks' own estimates, the total processing times of payment account applications are on average at a reasonable level.

The FIN-FSA considers it important that the banks should have a more accurate overall picture of the processing times, so that access to banking services can be ensured within a reasonable time. The FIN-FSA recommends that banks respect the 10-day processing period that applies to payment accounts for basic banking services in respect of all payment account applications from private persons when the payment account application relates to the customer’s primary banking relationship. The FIN-FSA also recommends that banks monitor and compile statistics on the processing times of these payment account applications.

Taking financial inclusion into account 

The FIN-FSA points out that it is important for banks to assess the impact of their risk management activities on customer relationships also from the perspective of financial inclusion. The procedures for limiting and declining a customer relationship must also take into account the interests of the customer and what is reasonable. If the impact of risk management from the perspective of financial inclusion has not been assessed, it is difficult for the bank to adjust its own risk management measures so that they are reasonable and proportionate to the risk.

The FIN-FSA recommends that an assessment of the impact of risk management measures from the perspective of financial inclusion is made in the company's risk assessment of the risks of money laundering and terrorist financing.

Subsequent measures by the FIN-FSA

The FIN-FSA will apply continued supervision on banks whose operating practices were found to be inadequate. In its supervisory activities, the FIN-FSA also monitors whether banks’ customer due diligence procedures are appropriate and reasonable and how the risk-based approach is implemented in practice in the said procedures.

For further information, please contact

Sanna Atrila, Chief Legal Advisor, sanna.atrila(at)fiva.fi

Appendix

Thematic review report (in Finnish)

¹A phenomenon in which a financial institution, instead of managing risks, seeks to avoid risks in a customer relationship by either terminating or limiting business relations with customers or even entire groups of clients deemed to be high-risk.
²Thematic review of unwarranted restriction of banking services for high-risk clients (2022) (in Finnish).
³Thematic review of availability of banking services to foreigners moving to Finland (2023).

The corresponding Finnish-language supervision release was published on 29 August 2025.