On 31 March 2023, the European Banking Authority (EBA) published the following documents intended to challenge unwarranted de-risking and safeguard access to financial services to vulnerable customers:

• Final Report – Amending Guidelines EBA/2021/02 on customer due diligence and the factors credit and financial institutions should consider when assessing the money laundering and terrorist financing risk associated with individual business relationships and occasional transactions (ML/TF Risk Factors Guidelines) under Articles 17 and 18(4) of the Fourth Anti-Money Laundering Directive. The Final Report contains a new annex to the ML/TF Risk Factors Guidelines which set out factors credit and financial institutions should consider when assessing the money laundering / terrorist financing (ML/TF) risks associated with a business relationship with customers that are Not-for-Profit Organisations (NPOs). The annex will clarify the steps that institutions should undertake to get a good understanding of how an individual NPO is set up and operates, as well as the factors credit and financial institutions should consider when assessing the ML/TF risks associated with a business relationship with customers that are NPOs.
• Final Report – Guidelines on policies and controls for the effective management of money laundering and terrorist financing (ML/TF) risks when providing access to financial services. The guidelines complement the ML/TF Risk Factors Guidelines by specifying further the policies, procedures and controls credit and financial institutions should have in place to mitigate and effectively manage ML/TF risks in accordance with Article 8(3) of the Fourth Anti-Money Laundering Directive, including in situations where the provisions in Article 16 of the Payments Accounts Directive apply, which introduces the right of individuals to open and maintain a payment account with basic features.

Both sets of guidelines will apply three months after publication in all EU official languages.