Financial Overcompliance: Banking Restrictions Affecting Non-Designated Individuals

This ARGA Observatory report examines banking restrictions imposed on individuals who are not subject to sanctions designations. It addresses access to basic payment accounts, the French droit au compte procedure, politically exposed person status, mistaken identity and evidence of the origin of funds. Three judicial cases and six hypothetical scenarios illustrate how to identify the basis of a restriction, prepare supporting documents and pursue complaints or legal remedies. The report distinguishes sanctions obligations from other compliance requirements and banks’ risk-management decisions. This publication includes the Russian and English versions.