Article
Jenec And The Limits Of Automatic De-risking In EU Banking Law
The Court of Justice of the European Union has ruled that banks cannot automatically refuse to open basic payment accounts solely because an applicant appears on a third-country sanctions list, such as OFAC. While such designations constitute relevant risk factors, financial institutions must conduct individual, proportionate assessments demonstrating that AML and sanctions-related risks cannot be adequately managed through appropriate measures.
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