Inclusion is a popular topic. The West has recently aimed at placing all members of society on an equal footing: minority groups, the elderly, the disabled, women, men and others. Inclusion is a movement steered at giving all human beings the same opportunities and removing ― as far as possible ― any discrimination or barrier to fulfillment. 1
It would have been inconceivable not to integrate finance into this concept of inclusion. The goal of financial inclusion is to make finance accessible to as many people as possible.
Conversely, de-risking is a form of exclusion. For professionals subject to the fight against financial crime ― whether financial institutions( FIs) or other operators ― it involves withdrawing from certain activities or territories, or even refusing to serve certain clients deemed too risky. 2 The risk of financial or reputational loss can indeed be too great in some cases compared to the profit a product can generate. To be viable, a company thinks primarily in terms of profit. De-risking avoids costly preventive measures for the company and for a company de-risking is often seen as business-friendly.
Where inclusion leads to a unifying effect, de-risking produces an opposite result; for this reason, we can assert that de-risking is a threat to financial inclusion.
This is but theoretical. What is it like in the EU? What does real life teach us?
From a real-life point of view, de-risking threatens financial inclusion
Table 1: Types of de-risking and their impact on financial inclusion
Types of de-risking
Withdrawal from geographic areas. Entire geographic areas can be underserved by banking professionals. For instance, withdrawal from activities operated in so-called“ tax havens” or from activities operated in a country listed on the international sanctions list.
Impact on financial inclusion
FIs and an entire country may be deprived of access to correspondent banking, credit or even from the SWIFT system, leaving them financially cut off from the rest of the world.
Exclusion of certain clients deemed too risky by FIs.
Some states within the EU indicated that in order to avoid high-risk customer presence in some cases, residents of countries like Afghanistan, Syria and Iran were cut off or not accepted as customers, based only on citizenship. 3 Yet, financial inclusion is a persistent challenge in Afghanistan, with nine out of 10 Afghan adults excluded from the financial system. 4
Lower-value retail customers can be excluded( e. g., migrant workers).
Lack of access to banking services deprives these populations of their autonomy and reduces their potential for expansion.
Nonprofits often have a hard time when it comes to opening an account.
Certain distribution channels or products may be avoided by FIs due to fears of fraud, financial losses or regulatory fines.
This is the case with cash-intensive businesses, gambling and virtual currencies.
New products, such as cryptocurrencies, can scare FIs because of their partial and uneven regulations. Failure to engage in these markets can be detrimental.
ACAMS Today | September – November 2025 71