Schrems II is often treated as a “data protection” story, but for EU financial institutions it is really a live-fire test of operational resilience. One court judgment wiped out Privacy Shield overnight and forced banks and PSFs to scramble through SCCs, DPAs, and vendor contracts just to keep core services legal. That is not a legal nuance; that is a production incident with a geopolitical root cause.
At heart, this is a clash of philosophies. The EU treats privacy as a fundamental right, baked into the Charter. The US frames data largely through the lenses of national security and commercial use, where surveillance powers can quietly override contractual promises. When those worlds collide, your Microsoft tenant, CRM, or ticketing platform can suddenly sit on the wrong side of EU law.
If the legal basis for your core systems vanished overnight, how long until something actually breaks? Where would you lose control first—customer channels, back-office processing, or reporting? And who in your organisation is accountable for treating this as an IT and continuity risk, not just a footnote in the privacy policy?