Federal Law 115-FZ and Cryptocurrency: Why Accounts Are Blocked and How to Stay Safe

When you receive a large transfer or actively trade cryptocurrency, you may get a letter from the bank requesting documents. This is due to Federal Law No. 115-FZ “On Counteracting Legalization (and) Money Laundering (and) Terrorist Financing,” which has been in effect in Russia since 2001. However, while it previously only applied to financial institutions, today 115-FZ directly affects freelancers, cryptocurrency traders, marketplaces, and even ordinary people transferring money from abroad.

In 2024–2025, a wave of blockades and freezes is becoming a reality for many working with digital assets. Let’s understand why this is happening and how to protect your business.

Why Banks Are Increasingly Freezing Cryptocurrency Investor Accounts

Financial organizations are required to monitor every transaction. The system automatically flags as suspicious:

• funds transferred between personal accounts and digital asset trading platforms;
• money from foreign senders without explanations;
• regular payments that do not match declared employment;
• P2P exchanges without specifying the purpose of the payment.

When the algorithm detects an anomaly, the bank pauses the transaction and requests explanations from you. If no response is received or the documentation is unconvincing, the account is closed, and data is sent to Rosfinmonitoring.

What Documents Are Needed for Verification Under 115-FZ

In practice, successfully passing a bank check is aided by:

• contracts with clients and work completion certificates;
• receipts, invoices, and payment statements;
• a detailed explanation of the source of income , especially for operations with crypto assets;
• registration as an individual entrepreneur (IE) or self-employed – this significantly reduces the risk of problems;
• documentation confirming the connection between transfers and your activity.

A real example from practice: an IT specialist received payments through a cryptocurrency trading platform. When he withdrew 400,000 rubles, the bank’s system triggered. The institution required proof. The client sent a contract with the employer, messenger correspondence, and screenshots of trading operations. After three days, access to the account was restored.

Crypto Arbitrage Under the Law 115-FZ

Cryptocurrency arbitrage is a scheme where a trader buys tokens like USDT on one platform and sells them on another at a higher price. It sounds simple, but banks treat such activity with suspicion.

The problem is that frequent P2P transactions without registering as an IE qualify as hidden commercial activity, which violates 115-FZ. In 2024, arbitrageurs with turnovers even within a million rubles faced blockages.

What arbitrageurs should do:

• use multiple accounts in different institutions;
• specify meaningful purposes for P2P payments: “loan repayment,” “helping a friend”;
• officially register as an IE and sign a written loan agreement – this strengthens your position;
• carefully maintain a register of all operations and keep screenshots from trading platforms.

How to Protect Against Blockades in 2025

To work with cryptocurrency smoothly and avoid account freezes, follow these recommendations:

1. Register as an IE or self-employed if you have regular income;
2. Clearly specify the purpose of each payment – avoid empty fields;
3. Separate personal and business accounts – do not mix them;
4. Collect and store all supporting documents – screenshots, contracts, invoices;
5. Respond promptly to bank requests – delays can cost you your account.

Summary

115-FZ is not a myth but an active mechanism of state control over financial flows. For those actively trading cryptocurrency or earning income from abroad, ignoring this law is dangerous.

But if you understand the requirements, properly formalize your activities, and maintain transparency in operations, blockades will not affect you. Proper preparation and compliance with the rules are the keys to safe cryptocurrency business management.