Concerned about your fintech getting de-banked? It’s a major worry for those who rely on sponsor banks’ licenses and architecture. This concern has grown following the collapse of Signature, Silicon Valley, and now First Republic. The U.S. Department of the Treasury recently published a 50-page document outlining its strategy to address “de-risking.” Treasury uses the term ‘de-risking’ to refer to banks terminating or restricting business with broad client categories, without analyzing and managing client risk in a more targeted fashion. According to the Department, de-risking poses challenges to both public and private sector participants in providing responsible access to financial services, advancing U.S. foreign policy, maintaining the centrality of the U.S. financial system, and combating illicit finance. Although the Treasury publication alone won’t prevent banks from unilaterally closing accounts of “riskier” client types (e.g., crypto, MSBs, correspondent banking), it might open the door for a dialogue with bank management. The goal would be to determine whether your fintech, despite belonging to a riskier category, has robust controls that set it apart from similar companies. If so, that’s your path forward.