Capital One Says Trump Account Closures Followed AML Review

Capital One Financial is seeking to end a lawsuit over its 2021 closure of Trump-affiliated bank accounts without requiring the court to decide whether politics influenced the decision.

In a 23-page motion, subsidiary Capital One, N.A. argues that its deposit agreement permitted it to terminate accounts for “any or no reason.” At the same time, the bank says the closures followed months of analysis by anti-money laundering professionals operating under internal policies and regulatory guidance.

The strategy gives Capital One two separate defenses. The bank denies that political discrimination drove the closures, then argues that its underlying motive is legally irrelevant because the account agreement granted it broad termination discretion.

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Capital One also says federal law can prohibit banks from revealing certain information generated through their AML processes. That leaves the plaintiffs challenging an explanation that the bank says it was not contractually required, and may not always have been legally permitted, to disclose.

The firm says documents attached to the plaintiffs’ own complaint demonstrate that AML concerns prompted the closures. It further argues that transaction patterns identified during its review were among the types of activity flagged by federal banking guidance.

Those statements remain allegations made by Capital One in seeking dismissal. The public motion does not identify the transactions or explain why each pattern raised concern. The bank noted that portions of the Second Amended Complaint and its exhibits remain sealed.

Capital One has not alleged that the Trump-affiliated entities committed money laundering or another crime. Reuters similarly reported that the filing connects the account decisions to AML concerns without accusing the Trump Organization of illegal laundering.

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The plaintiffs are the Donald J. Trump Revocable Trust, DJT Holdings LLC, DJT Holdings Managing Member LLC, DTTM Operations LLC, and Eric Trump. Their original complaint was filed in Florida state court on March 7, 2025, before Capital One removed the dispute to federal court. President Donald Trump is not personally named as a plaintiff.

Capital One notified the plaintiffs on March 8, 2021, that many of their accounts would close by June 7. The bank says it provided three months to transfer funds and subsequently granted several extensions. Reuters reported that the decision covered more than 300 Trump-affiliated accounts.

The plaintiffs allege that the closures were politically motivated and imposed financial and operational costs by forcing their businesses to transfer banking relationships. Their original complaint said the accounts held millions of dollars and supported businesses in real estate, hospitality, entertainment, tourism, media, and sports.

The court dismissed the First Amended Complaint on March 20, 2026, after finding that the governing account rules granted both parties discretion to terminate the relationship. The judge nevertheless allowed a limited discovery period and gave the plaintiffs another opportunity to amend.

The plaintiffs filed their Second Amended Complaint on July 17. It asserts three claims involving breach of contract and the implied covenant of good faith, fraudulent concealment, and declaratory relief.

Capital One is now seeking dismissal with prejudice.

On the contract claim, the bank argues that the plaintiffs cannot identify an express provision that was breached. It says imposing a good-faith restriction on an agreement permitting closure at the bank’s sole discretion would rewrite the contract.

On fraudulent concealment, Capital One argues that an ordinary bank-customer relationship does not create a fiduciary duty to disclose confidential reasons for terminating an account. It also says the plaintiffs cannot establish reliance or causation because their alleged losses resulted from the closures themselves, rather than the absence of an explanation.

The declaratory claim asks the court to determine that Capital One’s AML rationale was a political pretext. The bank argues that such a declaration would address only a decision made five years ago and would not resolve a live dispute.

Capital One says the plaintiffs have not tried to reopen the accounts and were able to secure banking services elsewhere.

The dispute is unfolding after the Trump administration changed federal policy toward politically motivated debanking. An August White House executive order declared that banking decisions should be based on individualized, objective, and risk-based analysis rather than political or religious beliefs. It also directed regulators to remove reputation risk from supervisory guidance.

Federal banking agencies subsequently finalized rules prohibiting regulators from using reputation risk as a basis for criticizing banks or encouraging account closures. The FDIC announced the final rule in April 2026.

Those changes postdate Capital One’s 2021 decision. The Trump-affiliated plaintiffs’ current claims instead depend on Florida contract and fraud law.