2025 – A year in de-banking

Throughout 2024, and following several high-profile “de-banking” cases, we published a number of blogs, including “What are the proposed new laws aimed at preventing de-banking?” and “Why the proposed new laws to try and prevent de-banking do not go far enough”.

Unfortunately, throughout 2025, we continued to be approached by individuals who felt that they had been unfairly “de-banked”. This is an incredibly frustrating situation to find yourself in.

We have previously outlined steps that individuals who believe that they have been de-banked can take. These include submitting a formal complaint to the relevant bank, accompanied by a Data Subject Access Request (“DSAR”).

Below, we look back over some of the significant blogs we published throughout 2025 aimed at assisting individuals and companies who find themselves in the unenviable position of being de-banked.

I have been de-banked – am I entitled to a basic bank account in the UK?

In an April 2025 article, we explored the fundamental question of whether individuals in the UK are legally entitled to a bank account, specifically a Basic Bank Account (BBA). We examined the legal and regulatory framework that governs access to these services and analysed how the practice of de-risking can have adverse consequences for innocent customers across the UK.

What are the new rules announced by the Labour Government aimed at preventing potential de-banking situations?

In a May 2025 article, we examined the new rules proposed by the Labour Government.

Broadly, we noted that the proposed new rules would extend the notice period a bank must give to close a customer’s account (i.e. de-bank a customer) from the current two months to 90 days.

In addition, the proposed rules would require banks, in appropriate circumstances, to provide greater transparency by giving clearer reasons for their decision to de-bank a customer.

Ultimately, the changes remained similar to those we highlighted in our March 2024 article on this topic:

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

When will the new de-banking rules come into effect?

In June 2025, we examined the anticipated implementation timeline for the new rules and confirmed that they are expected to come into effect from April 2026, subject to Parliamentary approval.

However, as we have previously explained, although the new rules will go further in addressing some of the iniquities in certain de-banking decisions, the whole approach to providing adequate access to a bank account and banking facilities needs to be radically reconsidered, making it akin to a fundamental right rather than something that can be offered (and taken away) at the whim of the banks.

Has the US-style wave of crypto “de-banking” reached the UK?

In July 2025, we discussed a January 2025 Forbes article entitled “No Country For Young Fintechs: the U.K.’s Debanking of Crypto Blockchain and Web 3”. This article reported the results of a survey which found that 50% of the UK’s fintech and crypto firms have faced rejection when trying to open a bank account.

This situation begs the question: has this become a new reality, and if so, is there any light at the end of the tunnel?

As we have also noted and explored in detail, the combination of potential new UK regulations for cryptoassets and stricter rules aimed at preventing de-banking should reduce the frequency of unfair account closures.

The previous landscape for both de-banking and crypto regulation has been uncertain. However, the introduction of the new rules should hopefully lead to more certainty and, as such, fewer wrongful de-banking decisions.

De-Banking update – Gherson White-Collar Crime team cause bank to reverse wrongful decision to de-bank our client

In October 2025, we described how an individual approached Gherson Solicitors LLP after being informed by their bank – entirely without warning – that it intended to close their account. No reasons were provided for this drastic and consequential decision.

On the day of instruction, Gherson’s White Collar Crime Team immediately wrote to the bank in question. The bank responded the following day, admitting that they had made errors and would be re-opening the account. The client’s access to their account was restored almost immediately thereafter.

This case demonstrates the fact that banks continue to make wrongful de-banking decisions, which can have devastating consequences for the individuals or businesses affected, and how important timely intervention can be.

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?

We are also being increasingly approached by individuals who feel that a financial institution has wrongly 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 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 approached more and more 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