Davis Polk AML/CFT head Dan Stipano was quoted in Risk.net discussing the exclusion of reputational risk from decisions to debank customers. 

Noting that some of these cases will be cut and dried, Dan said, “In reality, it will be hard not to consider reputation risk to some degree. For example, what if a customer has known ties to a drug cartel?”

He noted that the banks will take their cues from their supervisors. “They’ll go through their policies, and they’ll scrub them and remove all references to reputational risk, which is exactly what the banking agencies have done.” 

However, Dan also said, “[Controversy around reputational risk is] not a new issue at all.” The article pointed to his 2014 testimony during his time at the OCC addressing this issue. 

Dan said that reputation risk is seldom a focus of bank examiners or the reason why banks don’t do business with certain parties. Instead, he pointed to the Bank Secrecy Act, which requires banks to track and report certain transactions and issues suspicious activity reports, as the source of most debanking.

“Amid debanking drama, banks try to say ‘no’, safely,” Risk.net (June 10, 2026) (subscription required)

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