47. Turning to the institutions that make decisions to de-risk some of their customers (that include CIs and PIs/EMIs), those that submitted their contributions to the Call for Input reported that they refuse to onboard new customers or make decisions to offboard existing customers in accordance with their AML/CFT obligations, and that they do not de-risk entire categories of customers. They indicated they would typically de-risk customers that belong to the following categories:

• Customers with links to jurisdictions that are associated with higher ML/TF risks. Jurisdictions associated with higher risks include 'high-risk third countries' as identified by the European Commission as having strategic deficiencies in their AML/CFT regime pursuant to Article 9(2) of AMLD and for which enhanced due diligence (EDD) is required under AMLD. They also include those jurisdictions that give rise to particular ML/TF concerns or risks but are not included on the Commission's list. Customer groups most affected in this category are mostly legal entities (including NPOs) operating in or having business relationships with these jurisdictions, but also individuals from these jurisdictions (e.g. asylum seekers).

• Customers that fall within the scope of US legislation. Customer groups in this category are so-called 'accidental Americans' (i.e. customers to whom the US Foreign Account Tax Compliance Act - FATCA applies). CIs offering USD clearing also report that they cannot conduct business with individuals or entities that are listed under the US sanction regime (that can differ from the sanction regime applied in the EU or the UN).