Davis Polk AML/CFT head Dan Stipano was quoted in Lexology discussing debanking and AML obligations.

Dan noted that there is a “tension” between the administration’s debanking posture and financial institutions’ AML obligations.

“Banks should never take on any customer where they cannot manage the risk,” he said.

Dan stated, “Given institutions need to assess whether they have the expertise, resources and controls to manage risk when offering services to potential clients, new debanking rules could make banks feel pressured to take on customers whose risk profile they are not suited to deal with.”

“Banks should therefore document why they are making any decisions that could be interpreted as political debanking - be it lack of expertise, resources or training - to ensure they can defend themselves if challenged,” he added.

“Trump debanking saga could expose banks to AML risks,” Lexology (December 11, 2025) (subscription required) 

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