De-risking and PEPs: Financial Inclusion and the Limits of Controls in the EU and the United Kingdom

This report examines the relationship between politically exposed person (PEP) status, anti-money laundering controls and access to financial services. Focusing on the European Union and the United Kingdom, it considers domestic and foreign PEPs, family members and close associates, former public office holders, beneficial ownership, and evidence concerning the source of wealth and funds. It distinguishes preventive scrutiny from a presumption of criminal activity or the existence of a sanctions prohibition. The analysis explores when refusal or termination of a banking relationship may rest on an individual assessment and when categorical exclusion raises questions of proportionality or data accuracy. It addresses basic payment accounts, the French bank designation procedure, UK account termination rules, commercial screening profiles and avenues for complaints and redress. The report explains the limits of both financial inclusion guarantees and institutional discretion, preserving the distinction between correcting information and securing access to a particular financial product.