Debanking has become one of the most complex and sensitive issues facing financial institutions today. At its core, the debate reflects a difficult balancing act: managing financial crime risk while preserving fair access to financial services.
For credit unions, BSA/AML obligations are clear, but the path to compliance is not always straightforward. Heightened enforcement, evolving typologies, and emerging risks tied to digital assets and fintech relationships have increased pressure to act decisively. In some cases, that pressure can lead to overly conservative decisions that limit access for certain customers or industries.
The risk of overcorrection is real. Broad de-risking strategies may reduce short-term exposure but can introduce reputational risk, supervisory questions, and misalignment with mission-driven values. Regulators are increasingly focused not just on whether institutions manage risk, but how they do so.
Strong governance is the differentiator. Institutions that invest in clear risk appetite statements, documented decisioning, and ongoing monitoring are better positioned to justify their actions, whether that means exiting relationships or continuing to serve higher-risk segments responsibly.
As policy discussions continue and expectations evolve, credit unions must navigate debanking decisions with rigor, transparency, and balance. The goal is not zero risk, but defensible, well-governed risk management.
These conversations, including how institutions are approaching BSA/AML, fraud, and emerging financial crime risks, will continue at The 2026 Forum, where leaders will share practical approaches to maintaining access while meeting supervisory expectations.
This topic — and practical perspectives from regulators, legal experts, and industry peers — will be explored further through discussion at The 2026 Forum, April 20–22 in New Orleans.
Learn more about the Forum and view registration details →