Davis Polk AML/CFT head Dan Stipano was quoted in MoneyLaundering.com from a panel at the Association of Certified Anti-Money Laundering Specialists’ (ACAMS) 2025 Assembly in Las Vegas, which focused on debanking.

Dan noted that documentation will provide banks some cover from punitive action, but warned that they must still prepare for tough, potentially high-stakes questions if they deny services to customers engaging in activities favored by the current administration, such as cryptocurrency-related commerce.

“If a financial institution has the expertise and banks lots of crypto customers, it’s hard to say they should be denied accounts,” he said. “But if you’re a bank that doesn’t do that business at all, you’re probably in a better position.”

“Amid De-banking Fallout, Documentation Gives Banks Cover,” MoneyLaundering.com (September 26, 2025) (subscription required)

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