As Winston & Strawn has detailed in earlier articles and alerts, the Trump administration has prioritized addressing “politicized or unlawful debanking” (i.e., when financial institutions close or refuse to open customer accounts based on a customer’s political affiliation, religion, or involvement in legal but politically disfavored industries), using executive orders, agency bulletins, and internal investigative probes to tackle the subject. The administration’s actions are starting to produce measurable results.

In the absence of active enforcement by federal banking regulators, many financial institutions are choosing this moment to take a second look at their compliance policies and procedures. Recent administrative actions implicating access to financial services may particularly require financial institutions to reevaluate their Consumer Due Diligence (CDD) procedures and Consumer Identification Program (CIP).

On 30 January 2025, the European Commission published its first annual report on the implementation of EU export controls and the modernised Dual-Use Regulation. The report marks an important milestone in the development of EU export control policy, providing a consolidated overview of the data for 2022 with a view to enhancing transparency in this area.