Report D-15 examines de-risking — the refusal or termination of financial relationships and transactions because of perceived risk — in the context of politically exposed persons (PEPs). Its main focus is the European Union and the United Kingdom, with the French right-to-an-account mechanism used as a national example.

The report’s central argument is that PEP status does not in itself indicate corruption, money laundering, sanctions exposure or criminal activity. Rather, it triggers enhanced scrutiny and risk-management obligations. Treating the classification as an automatic reason to deny services therefore changes the logic of preventive regulation by replacing individual risk assessment with categorical exclusion. At the same time, the absence of a general prohibition on servicing PEPs does not create an unconditional right to every financial product. A refusal may be justified where mandatory customer due diligence cannot be completed or where a specific risk cannot lawfully be managed.

The study distinguishes between three elements: the legal basis for intervention, the factual source of concern and the measure ultimately imposed. A need to clarify one international transfer, for example, does not automatically justify closing a domestic account used for ordinary payments. Likewise, the high cost of compliance may influence a bank’s commercial decisions, but commercial cost and legal prohibition are not the same thing.

Particular attention is given to former PEPs, family members and close associates, corporate ownership, source of wealth and source of funds, commercial screening databases and automated risk models. The report stresses the importance of accurate and current information. A previous public function may remain relevant, but historical information should not be presented indefinitely as a current position. Correcting an inaccurate PEP profile, however, does not necessarily require a bank to restore services if independent and lawful concerns remain.

In the EU, the analysis also considers consumers’ access to payment accounts with basic features. France provides a specific example through the Banque de France account-designation procedure. For the United Kingdom, the report examines the rules effective from 28 April 2026, including changes concerning notice periods and explanations for the termination of certain payment contracts.

The overall conclusion is that financial inclusion and effective risk management are not mutually exclusive. A legally robust decision should follow a clear chain: reliable facts, an applicable legal rule, an individual assessment, a proportionate measure and an accessible review mechanism. This approach allows AML controls to remain effective without turning public office or family association into a permanent basis for financial exclusion.