2025 – A year in CIFAS markers and CIFAS marker removal

Throughout 2025, we were increasingly approached by individuals who have been adversely affected by a CIFAS marker in circumstances where they are adamant that there had been no wrongdoing or breach of their bank’s Terms and Conditions.

In many of these cases, the financial institutions concerned had also closed the individual’s bank account(s).

Individuals in these situations often seek advice on how to remove a wrongfully imposed CIFAS marker and whether it is possible to challenge the related bank account closure.

In some scenarios, the CIFAS marker will have been applied incorrectly, and being in this unfair situation can have a hugely detrimental effect due to the wide-ranging, complex and adverse consequences for the individual concerned.

We now look back over a series of articles we published during 2025, including guidance on challenging CIFAS markers, challenging crypto-related CIFAS markers, Gherson’s successful removal of a CIFAS marker and what a SIRA marker is.

Challenging a crypto-related CIFAS marker: what you can do

In May 2025, we explored how CIFAS markers linked to cryptocurrency activity are becoming increasingly common and how one can challenge a wrongfully imposed CIFAS marker in these circumstances.

What is a CIFAS marker and how likely is it to be unfairly imposed?

In July 2025, we examined what CIFAS is, the role it plays and the safeguards that exist to prevent unfair outcomes. We concluded by explaining what steps can be taken when a CIFAS marker has been applied incorrectly.

Gherson succeeds in removing a CIFAS marker in a client’s name

In September 2025, we described how our team was approached by an individual who believed that a CIFAS marker had been wrongfully applied against their name. After taking the client’s instructions, we made immediate representations to the financial institution that had imposed it. Shortly afterwards, the financial institution replied confirming that the CIFAS marker had been removed with immediate effect and agreed that it should never have been applied in the circumstances of the case.

Gherson was able to achieve this result quickly and efficiently, allowing our client to move forward without the severe restrictions and long-term consequences that a CIFAS marker can entail.

What is a SIRA marker and can it be challenged?

In October 2025, we examined what a SIRA marker is, how individuals can find out if they are subject to one and how to challenge a SIRA marker if one is imposed.

What can I do to challenge a wrongful decision to close my personal and/or business bank account(s)

In the meantime, we are increasingly being approached by individuals who have been “de-banked” in circumstances where they believe that they have acted in full compliance with their bank account’s Terms and Conditions, as well as all other applicable rules and regulations.

We have previously written about how these issues, including account closures, are not limited to political figures in the UK and affect many thousands of lawful individual and business customers every year. These cases have exposed the difficult balance many financial institutions and their individual and business customers must navigate to gain and maintain access to basic banking services.

To assist those whose accounts have been closed, Gherson’s Financial Crime, Investigations and Regulatory team have previously published the following blogs:

“Why has my bank account been closed?”

“Why has my business bank account been closed?”

“140,000 SMEs “de-banked” last year – why could I have been de-banked?”

“What are the proposed new laws aimed at preventing de-banking?”

“Why the proposed new laws to try and prevent de-banking to not go far enough”

“Am I entitled to a basic bank account in the UK?”

“How to challenge crypto-related bank account closures”

“De-banking and crypto – will the landscape be positively changed by the introduction of new rules for both?”

What can I do to try and challenge a wrongfully imposed CIFAS marker?

Increasingly, we are also being approached by individuals who feel that a financial institution has wrongfully imposed a CIFAS marker in their name.

If you have always acted in full compliance with your bank account’s Terms and Conditions, as well as all other applicable legal rules and regulations, then you should have a good basis to challenge the bank’s decision to implement any CIFAS markers.

A strong challenge will often involve demonstrating – through evidence – that you have not breached the bank’s Terms and Conditions or any other rules, and that all transactions were conducted in full compliance with applicable laws and regulations.

In previous blogs, we examined what a CIFAS marker is and how to try and get it removed, as well as what you can do if a CIFAS marker has been wrongfully imposed.

We have also recently explored Challenging a crypto-related CIFAS Marker: what you can do.

NAVIGATING FINANCIAL INSTITUTION-RELATED CHALLENGES

Adverse information on compliance databases

We are also being increasingly approached by individuals who believe that incorrect and/or inaccurate data held about them on compliance databases is having an adverse effect on their relationship with financial institutions, leading to issues such as bank accounts closures and difficulties in opening a bank account.

We have also written a series of blogs providing a general overview of the main functions of compliance databases such as World-Check, and explained how you can correct information about yourself on these databases.

HOW GHERSON CAN ASSIST

Gherson’s Regulatory, White-Collar and Investigations team are highly experienced in assisting you if your bank freezes or closes your account. This includes submitting a request under data protection legislation, otherwise known as a Data Subject Access Request, to ascertain what information banks and other financial institutions may be holding on you and their decision making, and then analysing the response and assisting with any appropriate challenge.

If you would like to speak to us in respect of any of the issues raised in this blog or about your specific circumstances, do not hesitate to contact us for advice, send us an e-mail, or alternatively, follow us on X, Facebook, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025