Influence

A Fieldnotes investigation reveals that a network of extreme right-wing groups is waging a multi-state financial deregulatory campaign centered on claims of discriminatory banking practices. The dark money-fueled effort, which alleges that banks are "debanking" fossil fuel companies, the cryptocurrency industry, firearms manufacturers, and right-wing political groups, represents an evolution of the network’s years-long opposition to environmental, social, and governance (ESG) investing. The overarching goal of this particular coordinated attack remains the same, however: To block financial institutions from considering the risks posed to and by their investments, including climate change.

 

Emails obtained by Fieldnotes show Alliance Defending Freedom (ADF) at the center of the effort to advance anti-“debanking” legislation in multiple states. In one instance, ADF passed along model legislation to Mississippi Secretary of State Michael Watson, adding that "[w]e thought that comparing debanking to redlining is a helpful way to message this bill, so we would invite dialogue from ya'll about fine tuning that angle of messaging as well." Less than a month later, a Mississippi Republican introduced legislation in the state senate that was almost identical to the ADF-authored model.

Redlining refers to discriminatory maps the U.S. government created in the 1930s that depicted communities with Black individuals as inherently riskier to lend money to than white communities. ADF, meanwhile, has been designated a hate group by the Southern Poverty Law Center, was central to overturning Roe v. Wade, continues to attack reproductive and LGBTQ+ rights, and sees diversity as a threat to white Christian values—which makes its decision to evoke the discriminatory practice of redlining striking. Nonetheless, the comparison would become ADF’s leading talking point during legislative hearings in at least four states.

Additional materials show ADF tapped Utah treasurer Marlo Oaks to help spearhead initiatives around debanking. Oaks is a prominent voice in the anti-ESG movement as well as a key leader in the State Financial Officers Foundation (SFOF), a group that has taken the lead in attacking climate disclosure in the financial industry. Documents show SFOF mobilizing treasurers to sign onto debanking issue letters and creating its own debanking taskforce and hotline. ADF's relationship to Oaks, and SFOF's newfound focus on debanking, suggests ADF has integrated itself into the larger anti-climate policy network in which SFOF has been a key coordinator.

 

Other right-wing groups that are part of the anti-debanking effort include the Foundation for Government Accountability (FGA), the Competitive Enterprise Institute (CEI) and the Federalist Society, all three of which, like ADF, have ties to Leonard Leo, the conservative billionaire who has been dubbed Donald Trump’s “court whisperer” for his role in selecting Supreme Court justices. 

 

ADF, FGA, CEI and the Federalist Society likewise all have ties to conservative mega-donor Charles Koch and his late brother David. 

 

 

Debanking, also called “de-risking,” is a somewhat amorphous term but generally refers to when a bank suddenly closes a customer’s account because of concerns around heightened risk, often with little or no explanation. There are real concerns that certain people have been and are subject to debanking, including formerly incarcerated individuals, Muslim Americans, truckers who protested Covid-19 restrictions, and small business owners. However, allegations that banks are unfairly "debanking" fossil fuel companies, the cryptocurrency industry, firearms manufacturers, and right-wing political groups are largely unfounded—even as ADF attempts to legitimize those claims by evoking racist banking practices such as redlining.
 

ADF and its allies have made “debanking” a conservative bête noire with help from President Trump and Republicans on Capitol Hill. This past January, just days after returning to the White House, Trump called out Bank of America for their alleged debanking practices and called on JPMorgan Chief Executive Jamie Dimon and others “to open your banks to conservatives,” adding “because what you’re doing is wrong.” Soon after, the GOP chairman of the House Oversight and Accountability Committee, Rep. James Comer (R-KY), announced he would investigate allegations of debanking of the cryptocurrency industry. And the Senate Banking Committee, led by Sen. Tim Scott (R-S.C.), followed suit in February with a hearing titled, “Investigating the Real Impacts of Debanking in America.”

Groups like ADF, FGA and CEI have sowed confusion around debanking to push forward their deregulatory agenda. Rather than combat debanking by strengthening oversight of the banking industry, right-wing groups and politicians have used such concerns to justify watering down and even eliminating financial regulation and consumer protection measures. In 2023, Rep. Andy Barr (R-KY) introduced legislation that would mandate the elimination of DEI policies within financial institutions “and even require them to do business with groups that violate their corporate policies or beliefs,” according to the Southern Poverty Law Center. In April 2025, Barr and Rep. Richie Torres (D-NY) introduced legislation that “mandates that all federal banking agencies eliminate reputational risk as a consideration in supervisory guidance, rules, and enforcement actions.” And Elon Musk and the Department of Government Efficiency (DOGE) have attempted to gut the Consumer Financial Protection Bureau (CFPB), the very regulatory agency tasked with protecting consumers against debanking. (Musk has gone so far to argue that the CFPB should be “deleted.”) 

The Equality in Financial Services Act

ADF’s debanking-themed model bill, known as the Equality in Financial Services Act, has been widely introduced across state legislatures, making it one of the most common bills in the wider anti-ESG trend. The legislation seeks to combat alleged banking “discrimination” against risky sectors such as the oil & gas and firearms industries as well as extremist hate groups. At least 46 bills similar to the ADF model have appeared in 21 states since 2024, according to Pleiades Strategy. Tennessee passed a version of ADF’s bill in 2024, Florida passed distinct laws with strikingly similar provisions that same year, and Idaho passed a version of the ADF model in 2025. ADF has likewise lobbied for or otherwise supported versions of “debanking” bills in at least 12 other states: Alabama, Arizona, Iowa, Idaho, Kentucky, Louisiana, Mississippi, Montana, Tennessee, Virginia, West Virginia.

 

The bill also penalizes financial institutions, including donor-advised funds, that carry out a risk assessment based on a variety of factors ahead of providing services. Penalizing donor-advised funds for considering the risks of funding hate groups protects ADF's own self-interest as a group that has been deemed a hate group. As ADF’s lobbyist Brian Knight told legislators in West Virginia earlier this year: "As with all speech protections, you have to protect the knaves to protect the saints. … There are people who have put forward my organization, Alliance Defending Freedom, as a hate group. They put us next to the Nazis. We don't advocate for violence. We don't advocate for hate. We advocate we use the law and we use public policy for traditional Christian values." 

 

Knight previously worked at the Mercatus Center, which was founded by Charles Koch and continues to be directed by advisors and executives at both his company and nonprofits.

ADF’s Model Bill Introduced in Mississippi

Emails obtained via public records request show ADF passed along “debanking resources” and model legislation to Mississippi’s secretary of state prior to the start of the 2024 legislative session. The bill was introduced almost verbatim by a state senator within weeks. 

 

On December 21, 2023, ADF State Government Relations Manager Matthew Nicaud sent Mississippi Secretary of State Michael Watson and his team ADF’s model legislation, along with a one-pager and frequently asked questions page on debanking. Nicaud welcomed feedback on the documents and emphasized that ADF “want[ed] to create a custom tailored bill for Mississippi and would love to get your input on that.” 

 

Weeks later, Mississippi Sen. Joey Fillingane introduced a version of ADF’s model legislation, officially called the Equality in Financial Services Act, as Senate Bill 2118 when the 2024 legislative session began in January. A side-by-side comparison of its text and the ADF model bill shows Fillangane introduced the ADF bill largely word for word, with the exception of Section 6 and 7 being unique to the introduced version. 

 

Reached for comment, an ADF spokesperson, Jacqueline Ribeiro, declined to answer questions about whether her organization worked directly with Fillingane or lawmakers in other states who have pushed similar legislation. 

 

The Mississippi bill died in committee without a hearing, while related efforts have run into opposition in several other states. The Louisiana Bankers Association, for instance, expressed concerns that the version introduced in its state in 2024, HB914, was attempting to combat a problem that might not exist, and that it would lead to “frivolous lawsuits.” The Montana Chamber of Commerce likewise opposed the version introduced there in 2025, SB240, with chamber lobbyist Charles Robinson arguing that "there's a reason that all banks or credit unions in Montana, large and small, uniformly opposed Senate Bill 240 because it's not about Montanans being denied loans because they're not woke enough—that's not happening.” Robinson also expressed concern that SB240 would penalize banks “if they deny financial services based on criminal activity that they suspect and refuse to reveal that to a customer to protect an investigation.”

 

The ADF effort to penalize banks that don’t provide financial services to those they deem too risky protects financially-risky companies and industries—and in turn also protects groups like ADF itself. 

 

Timeline:

 

December 21, 2023: ADF’s Matthew Nicaud sends debanking resources and ADF’s model bill to MS secretary of state and team, writing that ADF is interested in creating a “custom bill” for the state 

 

January 19, 2024: Senator Fillangane introduces the Equality in Financial Services Act 

 

March 5, 2024: The Equality in Financial Services Act dies in committee

ADF Taps an Anti-ESG Leader

ADF’s campaign around debanking included tapping a leading ESG critic, Utah treasurer Marlo Oaks, to help.
 

Since 2021, Oaks has been at the forefront of the anti-ESG effort both in Utah and across the country. He led and organized a push against the Utah Department of Labor rule that would allow retirement plans to consider climate change risks in their investment strategy and helped spearhead a letter opposing a climate-related disclosure rule under consideration by the Municipal Securities Rulemaking Board (MSRB), a self-regulatory financial organization. In 2022, he hosted a panel at SFOF’s February meeting alongside leading ESG critics Andy Puzder and SEC Chairman nominee Paul Atkins, titled “How Do We Protect the Role of the Fiduciary?” And in 2023, Oaks was a keynote speaker at a climate conference hosted by the Heartland Institute, a longtime climate denial organization. 

 

Public records suggest that ADF was eager to cultivate a relationship with Oaks. In October 2022, ADF’s Corporate Engagement and Communications Specialist Daniel Cochrane got in touch with Oaks after meeting the treasurer at the Heritage Foundation’s annual Resource Bank Meeting. During that meeting, the Heritage Foundation awarded its Innovation Prize to ADF for its “Viewpoint Diversity Score Index,” an index that analyzes how closely corporations align with white Christian-centric values and repudiate DEI and ESG initiatives.

 

Following the Resource Bank Meeting, Cochrane had a specific ask for the treasurer: Would he join an “open letter” ADF was planning to circulate “in conjunction with investors and financial professionals on debanking and free speech?” Cochrane added that with Oaks’ “leadership on the larger ESG issue, [his] name would add tremendous weight to the movement.” Cochrane was persistent in coordinating with Oaks and followed up with his office the following month to see if the treasurer would be interested in scheduling a conversation regarding “this broader threat [of debanking] and further discuss possibilities to push back.”  

 

By December 2022, documents reveal, ADF saw Oaks as a key ally in the organization’s debanking push. Oaks and Utah Treasury Policy and Communications Deputy Brittany Griffin agreed to meet with JPMorgan Chase regarding what ADF called the bank's “track record of debanking people and groups for ideologically biased reasons.” Cochrane also thanked Oaks and Griffin for their “willingness to approach Treasurer Moore [of West Virginia] and [Scott] Fitzpatrick [of Missouri] about joining the call.” By collaborating with Oaks and tactically trying to connect with other state treasurers, ADF tapped into the existing anti-ESG network to put the debanking strategy into motion.

State Financial Officers Foundation

Other state treasurers have also joined the debanking movement by way of SFOF, a corporate-backed group of state treasurers and Republican political operatives. As it did with its role in the anti-ESG push, SFOF continues to act as a key coordinator of opposition to climate action in the financial industry, including opposition to “debanking.” 

 

In March 2023, 14 Republican treasurers and auditors wrote to JPMorgan Chase urging the bank to take measures to address its alleged “debanking” practices. Documents reveal SFOF coordinated the letter and sent state treasurers an accompanying messaging guide reiterating the group’s call for “Chase to treat all customers equally” and pushing back on any anticipated claims that the bank does not discriminate against certain clients. SFOF coordinated a similar letter signed by treasurers to Bank of America, Glass Lewis, and ISS. These letters presumably originated from SFOF’s Debanking Taskforce. SFOF’s website features a “debanking hotline” where individuals can alert the organization of instances in which they believe they have experienced debanking. A similar debanking hotline was set up in Florida following the passage of H0989 in 2024. This year, in opposition to a version of the ADF bill in Virginia, a Virginia Credit Union League lobbyist said that nobody has called the hotline in Florida.

 

Since March 2023 other state treasurers have declared their alignment with ADF and its campaign against alleged debanking. In April 2024, Mississippi Treasurer David McRae solidified his commitment in a statement that cited ADF’s belief that “no one should be denied access to basic financial services because of their beliefs.” In August 2024, Louisiana Treasurer John Fleming acted on alleged debanking concerns by issuing a statement explaining that he had “recommended that Bank of America not be approved as an authorized fiscal agent in the State of Louisiana.” ADF applauded Fleming in a post on X: “No American should be denied access to financial services because of their political or religious beliefs.”

Other Groups Involved

Other prominent right-wing groups, including the Foundation for Government Accountability (FGA) and the Competitive Enterprise Institute (CEI), have pushed their own debanking agenda. In February 2024, FGA published a paper, titled “States Must End Political and Religious Debanking,” encouraging states to pass debanking legislation and reminding state officials that they can enlist their attorneys general “to investigate or seek remedies for any violations [of debanking].” In December 2024, CEI hosted a “Financial Weaponization Summit” that included discussion about debanking and “Operation Chokepoint 2.0”—a term of art among the Fox News set referring to allegations that the U.S. Department of Justice’s oversight of banks unfairly cut off financing to certain industries, most notably the crypto industry.

 

On January 27, 2025, the Federalist Society’s Freedom of Thought Project hosted a panel discussion on debanking that included speakers from right-wing think tanks Cato Institute and Consumers’ Research, as well as the director of the Consumer Financial Protection Bureau.

 

These groups claim they are engaging in their crusade against debanking to protect customers’ rights to fairly access capital and banking services, but the allegations they insist need addressing are to date largely unfounded, unconfirmed, or both. Their agenda, then, would appear to be less about protecting customers from overzealous banks and more about protecting their wealthy donors’s financial interests.

This post was updated on July 15th to correct the number of introduced bills similar to the ADF model legislation.