Yes, one doesn't have an account with a participating bank in order to receive and send payments via FedNow. It is same with Zelle; with Zelle, one sends money to an email or a phone number of an intended recipient. Both senders and receivers of Zelle need to registered with Zelle from their banking apps. USBank and Chase are notorious to close accounts who use Zelle heavily, because they see such activities as nefarious. Maybe, other banks use Zelle transaction history as another point to in order to debank people.

I don't want my banks to know who I send money to via Zelle; but they do. If banks are happy with customers writing checks to 'problematic' people, why they think that frequent Zelle activity as source of risk, as long as customers are not depositing or withdrawing cash/money orders.