EU rules regarding anti-money laundering, counter-terrorist financing and sanctions law (AML/CFT) have increasingly shifted responsibilities to detect crime from public entities to companies . AML/CFT law requires “obliged entities”, like banks, to collect large amounts of financial and other personal data about their customers.

The way banks implement these rules in the EU has led to a systemic negative impact on human rights, often because of over-compliance, risk-aversion and weak accountability. This has been the case in the Netherlands where, among large number of human rights breaches by banks, Dutch ING Bank has even publicly apologised for discriminating against its customers based on profiling.