Tanguy Prévinaire, Head of Compliance at PostFinance. (Montage: Paperjam)

Tanguy Prévinaire, Head of Compliance at PostFinance. (Montage: Paperjam)

As anti-money laundering and countering the financing of terrorism (AML/CFT) measures are strengthened, the question arises of how to ensure that everyone has access to essential banking services without compromising financial security. This tension, at the heart of European debates, calls into question the balance between regulatory vigilance and social responsibility.

Since European Directive 2014/92/EU, every resident of the European Union has been entitled to a basic payment account. This system, designed to enable everyday transactions (deposits, withdrawals, transfers, card payments), is intended above all to prevent financial exclusion, an aggravating factor in social insecurity. However, in practice, access to this right is sometimes fraught with pitfalls, particularly for people in vulnerable situations: lack of standard supporting documents, uncertain migratory status, atypical career paths.

Know your customer (KYC) and transaction monitoring (KYT) obligations are essential for preventing financial risks. But, paradoxically, they can exclude those who need them most. The inability to provide certain documents can lead to an account being refused, despite the legal framework. This situation illustrates a dilemma: how to reconcile security and inclusion without sacrificing one to the other?

European regulators, including the European Banking Authority and the European Central Bank, are arguing for proportionate application of the rules. The idea is to adapt requirements to the actual risk profile rather than applying uniform standards. In Luxembourg, the CSSF is encouraging a principle-based rather than a rule-based approach, but harmonisation of practices remains incomplete. Acceptance policies still vary between institutions, influenced by their risk appetite and operational capabilities.

Some jurisdictions are experimenting with innovative solutions, such as alternative verification procedures in partnership with local authorities and NGOs. These initiatives show that it is possible to reconcile regulatory rigour with equitable access to banking services.

Guaranteeing financial inclusion is not just a matter for banks or regulators. It is a collective challenge, involving public authorities, economic players, NGOs and civil society. Universal access to basic banking services is a lever for social cohesion, but also a factor for economic stability.

Financial inclusion and regulatory compliance are not conflicting objectives. They must be seen as complementary, in a spirit of proportionality and cooperation. The challenge is not to choose between security and accessibility, but to build bridges between the two, so that finance remains a tool for integration and not a factor of exclusion.