2. Methodology
8. To assess the scale, impact and reasons of de-risking at EU level, the EBA carried out a series of information-gathering exercises throughout 2020 and 2021:
• Firstly, the EBA gathered information from CAs:
- as part of the questionnaire that circulated to AML/CFT CAs and was prepared in summer 2020 for the purpose of the EBA's Opinion on ML/TF risks, the EBA included a dedicated section on de-risking in order to gain insight into the CA's assessment of the scale of the issue in their jurisdictions;
- through a series of structured discussions throughout 2020 and 2021 at the level of three of its standing committees dealing with AML/CFT, consumers' protection and financial inclusion, and with payment services. The purpose of these exchanges was to gain comprehensive insights from all relevant CAs and to cover all the angles of de-risking;
-in autumn 2021, the EBA conducted in-depth interviews with five AML/CFT NCAs about their experience of de-risking and the initiatives they had taken to address it.
• Secondly, in addition to information gathered through CAs, the EBA reached out to external stakeholders through a public 'Call for Input' launched in June 2020 to understand better the scale and impact of de-risking in the EU. The Call included a first set of questions that targeted institutions that take decisions to de-risk, to identify the drivers of de-risking, whereas the second set of questions targeted those affected by these decisions. In total, 293 respondents contributed to the Call, including 11 financial and credit institutions and consumer organisations.