On 6 February, the Wolfsberg Group and Institute of International Finance submitted comments via email and online in response to the EBA’s public consultation on ‘de-risking’ announced on December 6. The joint comments highlight the importance of alignment with the FATF definition of ‘de-risking’, that financial institutions should have the ability to apply a risk based approach to non for profit organisations (NPOs) in line with FATF Recommendation 8, recognition that have their own role in understanding the risks that they face and finally that commercial and risk management decisions also factor into financial institutions’ decisions on providing/maintaining banking services to customers.