2025 – A year in compliance database corrections
Dec 31 2025
White Collar Crime
Throughout the course of the year, we were increasingly approached by individuals who believed that incorrect information about them displayed on compliance databases was having a detrimental impact on them – whether by unduly harming their reputation and/or preventing their ability to access banking facilities and financial products.
This type of incorrect information can stem from biased media articles, or from compliance databases failing to conduct proper due diligence or misapplying the relevant rules. This is particularly so in relation to criteria such as whether or not the individual concerned is a Politically Exposed Person (“PEP”).
We now look back over a series of articles we published during 2025, including whether compliance databases have gone too far, noting Gherson’s successes, and what you can do if you believe incorrect information is having an adverse effect on you.
Have compliance databases gone too far? The case of World-Check
Following on from comments from David Leppan (the founder of World-Check) we examined, in July 2025, whether compliance databases have gone too far and what recommendations were made.
After Gherson successfully assisted two individuals with correcting their World-Check profiles, we published an article on the process for correcting information held on World-Check.
What can I do if I am incorrectly listed as a PEP on World-Check?
We have also previously considered what you can do if you believe that you have been incorrectly listed by World-Check as a PEP.
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”
What can I do to try and challenge a wrongly imposed CIFAS marker?
We are also being approached more and more frequently 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 rules, and that all transactions were conducted in full compliance with applicable laws and regulations.
In previous blogs, we have 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
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