Davis Polk AML/CFT head Dan Stipano discussed with MoneyLaundering.com President Trump’s Executive Order prohibiting banks from denying or terminating services based on an individual’s political or religious beliefs – practices often referred to as “debanking.”

“Banks should await direction from the regulators, but banks accused of wrongful debanking will be subject to enforcement action once a regulation is in place,” Dan explained. “They may be able to do so now on the theory that debanking is an ‘unsafe or unsound practice.’”

Discussing what to expect moving forward, Dan said, “This is clearly going to be a priority for both the administration and the regulators.” He added that “they are in lockstep, so banks need to take this seriously, starting by getting out in front of any actions by reviewing their policies, procedures and accounts for customers they may have wrongly debanked.”

“Take Trump’s De-Banking Threats Seriously, Former Regulators Advise,” MoneyLaundering.com (August 15, 2025) (subscription required) 

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