Trump Sues JPMorgan Chase for Five Billion Dollars
A Landmark Case of Political “Debanking”
On January 22, 2026, President Donald Trump filed suit in Miami-Dade County state court against JPMorgan Chase & Co. and its chief executive, Jamie Dimon, seeking at least five billion dollars in damages. The complaint centers on the closure of Trump’s bank accounts—and those of his affiliated entities—in February, 2021, an action that the plaintiff attributes to purely political motives. The lawsuit arrives amid a broader, increasingly contentious debate over “debanking,” a phenomenon that has emerged as one of the most polarizing regulatory issues of recent years on both sides of the Atlantic.
What Is Debanking, and Why Does It Matter?
Debanking refers to the unilateral closure of accounts, or refusal to provide financial services, by banks to customers who have committed no financial crime. The practice differs fundamentally from legitimate account terminations predicated on documented violations of anti-money-laundering or counter-terrorism-financing regulations, sanctions breaches, or identified money laundering.
The primary mechanism through which banks engage in debanking involves the assessment of “reputational risk”—a nebulous concept that refers to the perceived reputational harm of association with a particular customer, irrespective of that customer’s actual conduct. Rather than conducting individualized risk assessments, institutions impose blanket prohibitions on entire categories of clients: nonprofits, cryptocurrency firms, politically sensitive sectors, or high-net-worth individuals from jurisdictions deemed high-risk. The problem has been documented in detail in a Thomson Reuters report on debanking and the balance between risk management and financial inclusion.
The issue is compounded by inadequate notice and a lack of explanation—account closures often proceed with minimal warning (sometimes thirty days or less) and without any justification provided to the customer, effectively precluding meaningful recourse.
Further reading
- When the War on Money Laundering Targets the Innocent
- The Man Who Lost Three Hundred Million Pounds Because His Bank Got Suspicious
The Heart of Trump v. JPMorgan
The lawsuit rests on several legal theories. Against the bank, Trump alleges trade libel and breach of the implied covenant of good faith and fair dealing. Against Dimon personally, the complaint invokes the Florida Unfair and Deceptive Trade Practices Act (FDUTPA).
Trump contends that JPMorgan Chase unilaterally terminated a decades-long banking relationship, despite the fact that his accounts—which held hundreds of millions of dollars—had been maintained in good standing. The bank did provide a sixty-day notice period to transfer funds.
According to the complaint’s allegations, the crux of the matter was not the closure itself but rather the placement of Trump’s name and those of his affiliated companies on an internal warning list. As the Times reported, Trump claims this was “a blacklist used by banks to flag individuals and entities with a history of misconduct”—though media accounts emphasize that the precise nature of this list remains unclear and constitutes an element of the plaintiff’s narrative rather than an independently verified fact.
In the complaint, Trump argues that JPMorgan’s unilateral decision stemmed from political and social motivations and “woke” beliefs that the bank needed to distance itself from his conservative political views.
The Bank’s Position and the Broader Context
JPMorgan Chase responded with a statement disputing the merits of the claims, declaring that the suit “has no merit”. The bank emphasized that it does not close accounts for political or religious reasons, but only when they pose legal or regulatory risk to the company, pointing to regulatory expectations as a factor that compels such decisions.
The bank simultaneously expressed support for the Administration’s efforts to prevent the “weaponization” of the banking sector—a significant element of the political backdrop.
The case fits within a larger pattern. In 2024, attorneys general from sixteen states sent a letter to Bank of America expressing concern over discriminatory practices toward conservative and religious groups. Florida Attorney General James Uthmeier opened an investigation into JPMorgan in December, 2025. Trump’s complaint also cites the case of the National Committee for Religious Freedom, whose accounts JPMorgan allegedly closed in 2022, purportedly for failing to disclose donor information.
The Cascading Effect
Trump argues that placement on an internal warning list triggers a cascading effect—other financial institutions, seeing a red flag from one of the world’s largest banks, decline to establish relationships. This phenomenon is well documented in compliance literature: de-risking practices lead to systematic financial exclusion of legitimate customers regardless of demonstrated A.M.L. risk.
Among the entities affected in Trump’s case are his national golf club, a Miami resort and restaurant, the Briarcliff Manor development project, and a Chicago retail company.
Other Debanking Litigation—Capital One
This is not Trump’s first lawsuit against a financial institution over such matters. In March, 2025, Trump’s family company sued Capital One for alleged “political discrimination” related to the closure of hundreds of accounts. The bank had reportedly informed the company in March, 2021, that it would terminate their decades-long banking relationship within approximately three months—shortly after the end of Trump’s first term.
The American Regulatory Response to Debanking
Trump’s lawsuit acquires particular significance in light of his own Administration’s actions against debanking. In August, 2025, the Administration issued an executive order directing federal banking regulators to eliminate debanking practices, including the removal of “reputational risk” as a permissible basis for debanking in supervisory guidance and materials.
The order directs the Small Business Administration to notify partner institutions and requires them to identify customers debanked for political or unlawful reasons and to take remedial action. The Office of the Comptroller of the Currency confirmed that large banks had engaged in debanking of “disfavored industries” and initiated a comprehensive review of B.S.A./A.M.L. supervision. Joint rulemaking by the F.D.I.C. and O.C.C. is under way, aimed at restricting the use of “reputational risk” as justification for account closure.
The European Perspective—Similar Problems, Different Responses
Debanking is not confined to the United States. In the European Union, the Payment Accounts Directive (2014/92/EU) establishes a fundamental right of access to basic payment accounts, with exceptions narrowly defined as cases of A.M.L./C.F.T. noncompliance.
The key principle from Article 16(4) of the Directive: refusal to open an account is permissible only when an institution cannot meet A.M.L. due-diligence requirements—not merely because a customer appears on a sanctions list or raises vague reputational concerns.
Particularly significant is a recent case before the Court of Justice of the European Union involving the Slovenian bank OTP banka d.d. The bank refused to open a basic payment account for a consumer listed on the O.F.A.C. list, despite clear customer identification, verified beneficial ownership, documented legitimate purpose (opening a basic account), and no demonstrated inability to meet A.M.L. due-diligence requirements.
Advocate General de la Tour, in his 2026 opinion, found that O.F.A.C. listing alone cannot serve as the sole basis for refusing to open a basic account. Enhanced due diligence is warranted, but outright refusal requires demonstrating an inability to meet A.M.L. requirements. It should be noted that these conclusions are contained in the Advocate General’s opinion—the Court’s judgment has not yet been rendered.
The question of proportionality in processing data of persons holding public functions has been addressed in earlier C.J.E.U. jurisprudence. In its Grand Chamber judgment of August 1, 2022, in Case C-184/20 (OT v. Vyriausioji tarnybinės etikos komisija), the Court ruled that national provisions requiring online publication of private-interest declarations by directors of institutions receiving public funds are incompatible with E.U. law insofar as they disclose nominative data concerning the declarant’s spouse, partner, or close relations. The Court emphasized the necessity of balancing anti-corruption objectives against personal-data protection, stating that “an objective of general interest cannot be pursued without taking account of the fact that it must be reconciled with the fundamental rights affected by the measure.” Although the case concerned asset-disclosure transparency rather than debanking, it illustrates the C.J.E.U.’s approach to proportionality requirements when restricting individual rights in the name of the public interest.
Britain as a Model for Reform
The United Kingdom has published draft Payment Services and Payment Accounts (Contract Terminations) (Amendment) Regulations 2025, introducing significant changes to protect customers from arbitrary debanking.
According to analyses by Addleshaw Goddard and Bird & Bird, the new regulations mandate extended notice periods (a minimum of ninety days, not sixty), require written explanation of closure reasons, and limit exceptions to documented A.M.L. violations, suspected financial crime, threats of violence, or abusive conduct.
The regulations emphasize the need for objective grounds, notification, and explanation, while the F.C.A. report on payment-account access indicates a need to clarify and control the use of “reputational risk.” The aim is not an outright ban on invoking this factor but rather its narrowed, proportionate application based on individualized risk assessment.
Implications for Compliance Practice
From the perspective of banking law and compliance, Trump v. JPMorgan raises fundamental questions about the limits of bank discretion in terminating customer relationships. Banks possess broad latitude in deciding with whom to do business—a function of A.M.L./K.Y.C. requirements and responsibility for customer risk profiles. The question is where justified regulatory caution ends and discrimination begins.
Also significant is the status of internal warning lists. If entry into a bank’s internal database effectively leads to exclusion from the entire financial system, questions arise about the proportionality of such measures and the possibility of challenge.
Finally, there is the matter of political neutrality in financial institutions. American law contains no express prohibition against differentiating among customers on the basis of political views in the private sector (unlike discrimination based on race, religion, or sex). Trump will need to demonstrate that the bank’s practices violate other statutes or standards.
Prospects for Litigation
The case has been filed in Miami-Dade County state court in Florida. Trump is represented by attorney Alejandro Brito, of Coral Gables, Florida.
From a procedural standpoint, the plaintiff faces significant evidentiary challenges. Demonstrating that the bank acted out of political motives rather than regulatory concerns will require access to JPMorgan’s internal correspondence and decision-making processes—which the bank will likely contest on grounds of trade secrecy and compliance protection.
The five-billion-dollar figure appears calculated primarily for media effect. Actual pecuniary damages—given the sixty-day period to transfer funds—may prove difficult to establish at such a level.
Implications for Practice in Poland and Beyond
Although Trump’s case concerns American jurisdiction, the debanking phenomenon has direct relevance to other markets, including Poland. Poland has experienced specific debanking pressures, including the overuse of STIR blockades by tax authorities (seventy-two hours initially, extendable up to three months), increasingly triggered for participation in transaction chains or high V.A.T. refund claims without demonstrated tax fraud.
Polish businesses engaged in international supply chains encounter heightened account scrutiny and closure risk under de-risking frameworks. Tightened consumer-credit regulations have restricted access to the legitimate lending market for nonbank lenders.
For practitioners and businesses affected by debanking, the key measures are maintaining exemplary K.Y.C. documentation exceeding regulatory minimums, implementing robust A.M.L./C.F.T. controls, diversifying banking relationships, and proactively engaging legal advisers specializing in banking regulation.
In the event of account closure, one should demand written explanation citing the specific regulatory basis, file formal complaints with the regulated institution’s procedures, escalate matters to the relevant supervisory authority, and consider judicial review based on the absence of individualized risk assessment, lack of documented A.M.L. violation, or procedural-fairness violations.
Trump v. JPMorgan illustrates the mounting tension between banking-sector autonomy and societal expectations of equal treatment regardless of political views. The regulatory consensus emerging in 2025 and 2026—reflected in British legislation, the American executive order, and the Advocate General’s opinion at the Court of Justice of the European Union—points toward clear principles: the requirement of individualized assessment rather than blanket exclusion of entire customer categories, mandatory transparency and explanation, proportionality of measures to demonstrated risk, and protection of the right of access to basic payment services.
Whatever the outcome of the litigation, the debate over debanking and its legal boundaries will surely intensify—in the United States and in other jurisdictions grappling with the same dilemmas.
Founder and Managing Partner of Skarbiec Law Firm, recognized by Dziennik Gazeta Prawna as one of the best tax advisory firms in Poland (2023, 2024). Legal advisor with 19 years of experience, serving Forbes-listed entrepreneurs and innovative start-ups. One of the most frequently quoted experts on commercial and tax law in the Polish media, regularly publishing in Rzeczpospolita, Gazeta Wyborcza, and Dziennik Gazeta Prawna. Author of the publication “AI Decoding Satoshi Nakamoto. Artificial Intelligence on the Trail of Bitcoin’s Creator” and co-author of the award-winning book “Bezpieczeństwo współczesnej firmy” (Security of a Modern Company). LinkedIn profile: 18 500 followers, 4 million views per year. Awards: 4-time winner of the European Medal, Golden Statuette of the Polish Business Leader, title of “International Tax Planning Law Firm of the Year in Poland.” He specializes in strategic legal consulting, tax planning, and crisis management for business.
