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Venable partner Ed Wilson was quoted in a May 7, 2015 American Banker article on the regulatory risks behind the relationship of financial institutions and their customers. Last month, the United Kingdom's Financial Conduct Authority (FCA) said heightened regulatory risk would no longer serve as a legitimate reason to end customer relationships. Following the move, many U.S. institutions believe domestic agencies could adopt a similar policy.

"The first thing they did in this [statement], as a matter of bank regulatory policy, is say that the FCA is going to examine the basis on which a bank makes these decisions, and it cannot just be AML," said Wilson. "The FCA is saying that the failure to exercise what it considers to be appropriate due diligence resulting in classes of potential bank customers being turned away is a consumer protection issue, in much the same way the law has developed in the U.S. with regard to credit decisions."