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In 2025, debanking initiatives continued to intensify, with new guidance, legislation, and other actions at both the federal and state levels aimed at so-called “discriminatory debanking.” Those actions included: 

  • Federal and state policymakers advancing “fair access” initiatives aimed at preventing financial institutions from denying or restricting services based on certain factors, including political opinions, religious beliefs, and environmental, social, and governance standards.
  • The Guaranteeing Fair Banking for All Americans Executive Order (the Executive Order) providing that federal banking regulators must eliminate “reputational risk” as a supervisory factor and requires such regulators to identify and remediate any “politicized or unlawful debanking” practices.
  • Federal agencies, including the Office of the Comptroller of the Currency (OCC) and Small Business Administration (SBA), issued parallel guidance and enforcement directives, while Congress has advanced legislation aimed at creating a uniform national standard.
  • States, such as Florida, Tennessee, and Idaho enacted their own “fair access” laws prohibiting discriminatory debanking, with similar legislation pending in several other states.

Continue reading the full GT Advisory.

Tags: ESG, florida, FRAC, GT Insight, OCC, SBA
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Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Paul Ferak Paul Ferak

Paul J. Ferak is Co-Chair of the Financial Services Litigation Practice. Paul focuses his practice on financial services litigation, business litigation, and class action defense. He has served as lead and co-lead counsel in matters across the country. He manages a national team

…

Paul J. Ferak is Co-Chair of the Financial Services Litigation Practice. Paul focuses his practice on financial services litigation, business litigation, and class action defense. He has served as lead and co-lead counsel in matters across the country. He manages a national team of attorneys across Greenberg Traurig’s offices defending financial institutions in a variety of consumer and business matters and class actions. He has defended class actions involving mobile banking, electronic payments, credit cards, mortgages, and overdraft practices. He also regularly defends matters alleging violations of various statutes affecting the financial services industry, including credit cards, banking, and mortgage laws; privacy laws; and state consumer fraud laws; as well as matters relating to allegations of breach of contract and lender liability.

Paul is one of the leaders of the firm’s franchise litigation practice. He has represented franchisors in high-stakes litigation involving claims of breach of contract, breach of good faith and fair dealing, fraud, consumer fraud, tortious interference, and violation of various franchise laws. He has broad experience handling franchise terminations, nonrenewals, and the enforcement of in-term and post-termination covenants. He has handled both class and individual franchise cases.

Paul also has handled a variety of complex business disputes, including working capital, earn-out, and other post-acquisition claims in arbitration and in court.

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Photo of John Lukanski John Lukanski

For over 25 years, John Lukanski has worked on a nationwide basis with his broker-dealer, investment adviser, and other wealth management clients to support their business needs and handle their challenging and complex matters. These matters have included internal investigations, regulatory investigations by…

For over 25 years, John Lukanski has worked on a nationwide basis with his broker-dealer, investment adviser, and other wealth management clients to support their business needs and handle their challenging and complex matters. These matters have included internal investigations, regulatory investigations by the SEC, FINRA and state regulators, and litigation and FINRA arbitrations. He also has provided compliance and regulatory counseling to his clients, and helped his clients work through FINRA Rule 4530 and U4/U5 disclosure issues.

In addition, large financial institutions, such as deposit and commercial banks and trust companies, have sought John’s services in the courts, to defend their interests in high-stakes litigation. These matters have included defending allegations of fraud, fiduciary liability, breach of contract, and business-related torts. John also has handled many cases in both federal and state courts involving restrictive covenants.

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Photo of Tracy S. Combs Tracy S. Combs

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries…

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries nationwide, including those involving the SEC, the Department of Justice, and state Attorneys General. She also counsels clients in complex business disputes, tort litigation, and cybersecurity matters. As Utah Business Journal’s Legal Elite edition stated in 2025, Tracy can “navigate a wide range of legal situations and…easily handle a crisis for any client.”

Tracy joined GT after an eight-year tenure at the SEC, where she served in a variety of roles in San Francisco and Salt Lake City. Most recently, Tracy served as Director of the SEC’s Salt Lake Regional Office, where she oversaw some of its most high-profile cases. As a former SEC trial and investigative attorney in San Francisco, Tracy brought several groundbreaking enforcement actions, including the SEC’s first public company cybersecurity disclosure case and its first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s former Cyber Unit, where she co-led its Cybersecurity & Regulated Entities group. In 2021 to 2022, Tracy served as counsel to the Director of Enforcement, advising on priority matters and coordinating with the SEC’s criminal and civil law enforcement partners nationwide.

Prior to her government service, Tracy was a litigator at a large law firm in Philadelphia and New York, with a focus on high-stakes white collar criminal matters, securities class actions, and complex commercial disputes, and clerked for the Honorable Luis Felipe Restrepo in the U.S. District Court for the Eastern District of Pennsylvania.

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Photo of Jonathan H. Claydon Jonathan H. Claydon

Jonathan H. Claydon focuses his practice on complex commercial litigation in both federal and state courts. He represents clients in a wide array of cases, focusing primarily on bank litigation, business litigation, class action defense, and employment litigation.

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Photo of Shirin Afsous Shirin Afsous

Shirin Afsous is an experienced litigator in the field of commercial litigation. As a proactive professional, she is adept at client interaction and excels at crafting strategic case plans. Her areas of experience span across a vast array of sectors including financial services…

Shirin Afsous is an experienced litigator in the field of commercial litigation. As a proactive professional, she is adept at client interaction and excels at crafting strategic case plans. Her areas of experience span across a vast array of sectors including financial services litigation, labor & employment, government contracts, and commercial disputes. Her proficiency extends beyond the borders of her home state, as she skillfully handles cases across the nation in both state and federal courts. Moreover, she is a frequent participant in administrative proceedings, often providing invaluable assistance to clients embroiled in governmental investigations. As a first chair attorney, Shirin has taken the lead in numerous matters, showcasing her leadership and litigation skills. Her deep experience encompasses a wide range of legal proceedings, from drafting and research to preparing witnesses for trial. She is skilled at conducting depositions and arguing dispositive motions, proving her versatility in different aspects of litigation.

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Photo of Catherine Yepes Catherine Yepes

Catherine Yepes focuses her practice on financial services, representing financial institutions, including domestic and foreign banks and money services businesses (such as money transmitters). Catherine has represented clients before regulatory agencies such as the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement…

Catherine Yepes focuses her practice on financial services, representing financial institutions, including domestic and foreign banks and money services businesses (such as money transmitters). Catherine has represented clients before regulatory agencies such as the Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), Florida Office of Financial Regulation (OFR), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC).

Catherine advises clients on Bank Secrecy Act compliance, with an emphasis on anti-money laundering issues. She handles business, licensing, regulatory, and compliance matters for financial institutions. Her work includes performing independent risk assessments, developing anti-money laundering and sanctions compliance programs, preparing voluntary self-disclosures and specific license applications for submission to OFAC, and assisting with enforcement actions and subpoenas. Catherine also drafts, negotiates, and reviews commercial agreements and terms and conditions.

Catherine previously served as a Staff Attorney at the Third District Court of Appeal in Miami, where she analyzed trial records, researched legal principles, attended oral arguments and assisted in drafting opinions. She also gained experience in appellate litigation during her time as an academic intern with the Supreme Court of Florida in Tallahassee.

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