AUSTRAC says "‘Debanking’ (or ‘derisking’) can have a devastating impact on legitimate businesses. It also reduces the capacity of Australia’s anti-money laundering and counter-terrorism financing (AML/CTF) framework to prevent and detect money laundering (ML), terrorism financing (TF) and other serious crimes by discouraging transparency and potentially forcing customers into unregulated channels."

That's a view that is not very well represented in the general arguments against de-banking which are, usually, indignant (and fundamentally false) claims that amount to saying that everyone has a right to a bank account of their choice.

AUSTRAC recognises that certain business are in sectors that are inherently high risk. And what AUSTRAC recognises as higher risk include remitters, DCEs and financial technology (fintech) businesses. But it also says "Financial institutions may also consider other businesses, such as some not-for-profit organisations, the sex work industry, adult stores, gun shops and some cash-intensive businesses, to be higher risk for other reasons."

This statement from AUSTRAC is extremely important in all areas, not only those of the current note:

A risk-based approach does not imply a ‘zero failure’ approach to combating financial crime. Even if a financial institution implements appropriate risk-based systems and controls, AUSTRAC recognises that no reporting entity can reduce financial crime risk to zero.

AUSTRAC 's message is here: https://www.austrac.gov.au/business/how-comply-and-report-guidance-and-…