The report examines situations in which individuals or companies are not listed under sanctions regimes but nevertheless face restricted banking services, delayed transactions, account closure or refusal of access. Its central point is that absence from a sanctions list does not itself guarantee financial access. Restrictions may arise from the parties to a transaction, ownership structures, AML/CFT requirements, mistaken identity, source-of-funds concerns or the bank’s own commercial policy.

The analysis begins by identifying exactly what has been restricted: a single transfer, outgoing transactions, access to an existing balance, account opening or the banking relationship itself. It then separates five principal grounds: mandatory asset freezing, prohibition of a particular transaction, AML/CFT review, mistaken identity and contractual termination. Each requires different evidence and a different remedy. A false match calls for correction of the customer profile, incomplete due diligence calls for resolution of a specific evidential gap, and a binding legal prohibition requires consideration of applicable exceptions, licences or other lawful routes.

Particular attention is given to individual risk assessment and de-risking. The report shows how automated alerts, nationality, adverse media, PEP status or high compliance costs can develop into practical financial exclusion. A risk-based approach does not require a bank to accept every risk, but it does require consideration of whether the identified concern can be managed through additional documents, a more limited product, advance notification of unusual payments or other proportionate controls.

The practical sections address false name matches, outdated commercial risk databases, source of funds and source of wealth, large cross-border payments, intermediaries and delayed transfers. The report also examines access to basic payment accounts under EU law and the French droit au compte procedure, including its relevance to individuals, businesses and associations. France is analysed in detail, with comparisons to the United Kingdom and the United States and discussion of available complaint and judicial routes.

ARGA’s position is that over-compliance should be demonstrated through a specific defect in the decision: use of the wrong legal regime, mistaken identity, failure to apply an available exception, unjustified extension of one transaction problem to all services, or procedural failure. Effective protection therefore requires linking each legal ground to the relevant evidence and a realistic remedy. Success should be measured by actual functionality restored — access to the account, funds, transfers and essential banking services — rather than by a formal statement that a review has been completed.