Traditional banks
Proof of origin and account restrictions
Transactions relating to crypto assets are also increasingly subject to traditional credit institutions and payment service providers increasingly subject such transactions to review and control measures.
Customers of traditional banks, such as savings banks and cooperative banks, are affected. The same applies to customers of large commercial and direct banks such as Deutsche Bank, Commerzbank, ING, DKB or N26. Payment service providers such as PayPal or Wise also carry out corresponding checks.
For larger deposits or withdrawals in connection with crypto exchanges, credit institutions regularly require additional evidence. Customers must provide suitable documentation to prove the origin of the funds used and, if applicable, the cryptocurrencies held (so-called source-of-funds or source-of-wealth certificates).
Until the origin of the funds is clarified, banks regularly resort to various measures in practice.
Frequent measures taken by credit institutions
- Rejection of SEPA credit transfers
- Request for proof of origin
- Restriction of individual account functions
- Termination of the business relationship with reference to internal risk assessments
In individual cases, this results in complete account blocking or termination of the current account without notice of the current account. The background to this is regularly money laundering law auditing obligations (Sections 10 et seq. GwG), contractual termination rights of the bank as well as internal compliance and risk assessments of the institutions.
Measures vis-à-vis the customer must be within the scope of the statutory requirements and contractual agreements and comply with the principle of proportionality.
For those affected, it is often difficult to understand which documents are required to clarify the origin of the funds and whether the measures taken are justified – especially if crypto exchanges also temporarily withhold payouts at the same time.
Legal support
From a legal perspective, it is necessary to check whether the measure is covered by the contractual agreements and meets the legal requirements. A structured legal review can help to assess the proportionality of the measure and bring about clarification with the bank or payment service provider.
Initial assessment via the online mask
You can use the online form above to describe your concerns in a structured manner. The information provided will enable an initial preliminary examination of the facts of the case and help us to assess whether and in what form legal action should be considered.
The use of the online form does not constitute a mandate and does not replace a comprehensive legal examination. Concrete prospects of success, recommendations for action or a legal assessment in individual cases will only be made after explicit commissioning.