Banks restrict consumers’ access to payment accounts more than is necessary to manage money laundering risks. We want to see stricter requirements on banks to make assessments of consumers on an individual basis. Banks should also consider whether they can offer a more limited range of services instead of closing a customer’s account.
It is essential for consumers to have access to financial services in order to participate in society. Not having a payment account makes it difficult to make payments, receive deposits and, in some cases, for a consumer to keep their employment. It is therefore important that banks apply the anti-money laundering requirements in a way that ensures that consumer access to payment accounts is not unnecessarily restricted.
There is a risk that a bank's assessment as whether to offer a consumer an account is too broad, informed by characteristics of a group of customers rather than by the risks that the individual consumer poses. This approach can make it unnecessarily difficult, if not impossible, for certain consumers to get access to a payment account.
We support the Payment Inquiry's proposal to introduce a new legal requirement for banks to conduct a review of whether there is an alternative to account closure in some instances. This review should be mandatory in instances where the customer's circumstances or characteristics could lead the bank to determine that there is a heightened money laundering risk associated with the consumer's account. An example would be where a customer lacks standard identification documents. In such a situation, the bank should conduct a review of the customer's circumstances to determine whether they could offer an account with more limited services instead of closing the account.
However, we are concerned that it is not only existing customers who may have their accounts closed unnecessarily. Consumers are often denied access to a payment account at the point of application. Banks should therefore also be legally required to make a similar review to determine potential alternative options for consumers who would otherwise have their account application denied. Any new legal requirements introduced should be written in such a way that they are compatible with existing anti-money laundering legislation.
"All consumers need access to a payment account in order to live and work in Sweden. It is essential that banks work to counteract money laundering, but consumers' right to a payment account should not be restricted unnecessarily. Imposing stricter requirements on banks to consider alternative solutions to account closure can reduce this risk," says Malin Alpen, Executive Director of Payments at Finansinspektionen.
We also agree with the Inquiry that the State should work to make Swedish digital payment infrastructure more resilient. We also call for greater clarification regarding co-operation and areas of responsibility when it comes to crisis management between government authorities, including between FI and Sveriges Riksbank, and support greater collaboration between authorities and government departments.