De-Banked: It Could Happen to You.

My wife called our local branch to find out what the problem was. In the past the bank unilaterally closed the account because of suspicious activity they felt could be linked to possible identity theft. In every case, once we either confirmed or denied the validity of a flagged charge, our account was returned to its normal status.When we tried to find out what the issue was, the bank said that there was no information on file as to why the account had been zeroed out, and that we would need to bring the issue up with corporate headquarters.

We called the number provided, only to be told that Citizens Bank had closed our accounts. We were told that Citizens Bank had sent a letter containing more information.I rifled through a stack of unopened mail and found the letter in question.

“This letter is to inform you that Citizens has elected to discontinue its account relationship with you by closing [my account] effective January 13, 2026. ”

There was more.

“Citizens has the contractual right to close your account at any time,” the letter declared, adding that “Citizens is under no obligation to disclose to you its reasons for closing the account. At this time, therefore, Citizens’ policy prevents the disclosure of any information concerning the decision to close the accounts.”

According to a December 2024 report issued by the House Judiciary Committee, “Debanking occurs when a bank closes an individual or corporate account because the account holder, or their actions, are subjectively determined to pose a financial, legal, or reputational risk to the financial institution.”

According to this report, “The term “debanking” stems from de-risking, which involves ‘terminating or restricting business relationships with clients or categories of clients to avoid, rather than manage, risk.’”In short, I have done nothing wrong.My (former) bank manager agrees with me.But something, or someone, triggered a “de-risking” concern among the corporate heads at Citizens, and they terminated our relationship.

No due process, no possibility of appeal.One doesn’t begin to comprehend just how dependent we are on the digital economy until it is taken away from you.

All my family’s bills are paid electronically, drawing on funds that used to exist in the accounts that no longer exist.My debit card was my wallet.Cash was the stuff I carried with me to Russia, because my American digital financial profile doesn’t work in Russia.When you are “de-banked”, you are literally disconnected from the modern world.And because they took my money, I don’t even have the possibility of falling back on cash reserves.“De-banking” is designed to destroy the targeted individual.So, asking who or what was behind this decision is a legitimate point of departure when examining this larger issue.

We return to the House Judiciary report: “The filing of a Suspicious Activity Report (SAR) is one of the primary reasons for account closure. The other is a high-risk designation. Debanking can occur as a result of an anti-money laundering and reputational risk regime administered by the federal banking agencies where certain types of customers are designated as ‘high-risk.’”

This is why I sat down with my local branch manager and explained what I was doing—the sources of money that were coming into my account, and why I was taking out large cash withdrawals. I, of course, was careful never to surpass the $10,000 threshold, but simple math allows one to add up the withdrawals made and reach the conclusion that I had, indeed, withdrawn $10,000.I made three trips to Russia in 2025—August, October, and November.On each trip, I took $10,000 in cash—fully declared to my banking institution.

Again, the OCC: “A financial institution is required to file a suspicious activity report no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing a suspicious activity report. If no suspect was identified on the date of detection of the incident requiring the filing, a financial institution may delay filing a suspicious activity report for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction.”

The “initial detection” moment for my cash withdrawals would have been in early August. 

The next “detectable event” would have occurred in October, and the last one in November.

Complicating issues further is that my daughter was married on November 1, and there were cash transactions taking place regarding various wedding expenses.  According to the OCC, “Unusual Transactions” involve “large deposits/withdrawals, frequent transactions without a clear purpose, or activity inconsistent with the customer’s profile.” Another factor to be considered is “Complex Patterns”, which involve a “complex series of transactions, unusual wire transfer patterns, or attempts to avoid reporting thresholds (like the $10,000 cash transaction rule).”

A third relevant factor is what is called “Lack of Legitimacy”, where transactions have “no clear business purpose or legitimate activity behind transactions.”

This is why I spent so much time explaining to my local banker what I was doing, and why I was doing it.  And this is why I believe my local banker did not file any SAR’s related to my Russia travel.  But someone did.  The last large cash withdrawal related to my Russia travel took place in early November 2025.  The 30-day threshold would require the bank to issue a SAR by early December 2025.  This was not done.  Now, it is possible that the Citizens Bank fraud detection unit flagged these transactions on its own volition. There is a history of such activity—back when I submitted invoices to RT for compensation for articles I wrote, I would put the title of the article in the document title. Once, I used the term “Syria”, and Citizens Bank flagged the transaction and froze my accounts. When I contacted Citizens Bank, they said the transaction was flagged because I was engaged in activity with Syria, a sanctioned entity. They said that the flag was triggered by the Office of Foreign Asset Control, the Department of Treasury sanctions enforcement arm. I wrote a letter to OFAC informing them that their actions ran afoul of my First Amendment rights, and that I was preparing to take action. I subsequently received a call from an OFAC official, who informed me that they had nothing to do with it. He said each bank had its own OFAC compliance department, and that these departments often acted on their own volition, believing they were implementing OFAC policies. I called Citizens Bank back, got in touch with their OFAC enforcement group, and we quickly resolved the issue. But SARs are different. Federal law does not require banks to explain why they close an account, and in cases where a SAR is filed, banks are statutorily prohibited by the Bank Secrecy Act from disclosing the reason for account closure because it could indirectly notify the subject of a SAR that a SAR has been filed. 

Paul Tonko
2269 Rayburn HOB • Washington, DC 20515