Taras Miroshnychenko

Head of International Corporate Law and Fintech Practice

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+38 (073) 007-44-36

Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.

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Case: Helped open a bank account for a dating business through a Legal Opinion

Fintech
Reading time: 3 min.

Service: Legal Opinion

A client approached the law firm “Prikhodko & Partners” — the owner of an international online dating project.

The core issue was not the business itself, but its infrastructure: the client was consistently receiving refusals from banks and payment institutions (EMIs) when attempting to open accounts.

The formal reason — “high-risk activity”.

Why banks were rejecting the dating business

Banks classified the project as:

  • a high-risk digital business;
  • potentially related to the adult segment;
  • having elevated AML/CFT risks;
  • featuring a non-transparent payment structure.

At the same time, the business:

  • was fully legal;
  • did not provide adult content;
  • operated as a standard dating service;
  • had a clear monetization model (subscription + in-app purchases).

The issue was not the activity itself, but how it was interpreted by banks.

Critical phase: what happens without a bank account

  • inability to open an account → blocked operations;
  • risk of business disruption;
  • rejection by payment providers;
  • loss of partners due to “high-risk” status.

In practice, the business could not scale.

Our approach: not explanations, but a legal position

At “Prikhodko & Partners”, we do not rely on “explanatory letters”. We build a legal position that bank compliance teams can actually work with.

We broke the project down into key components:

  • service type (dating vs adult);
  • monetization mechanics;
  • user interaction model;
  • payment structure;
  • company jurisdiction.

The key objective was to demonstrate that this is not a high-risk segment in the traditional sense.

AML/CFT and financial model analysis

We reviewed:

  • source of funds;
  • transactional model;
  • customer geography;
  • high-risk jurisdictions;
  • transaction history.

Based on this, we built a profile demonstrating the absence of suspicious activity indicators and a controlled business model.

Legal structure and business transparency

We separately substantiated:

  • the company’s legal status;
  • absence of sanctions-related risks;
  • compliance of the corporate structure with banking requirements;
  • transparency of beneficial ownership.

Legal Opinion as a compliance tool

We prepared a Legal Opinion that:

  • clearly distinguishes dating from adult business;
  • explains the economic model;
  • supports a low/medium risk profile;
  • confirms compliance with AML/CFT standards;
  • forms a clear position for banks and EMIs.

This was not a “letter”, but a working compliance tool.

Account opening support

We:

  • adapted the position to specific banks;
  • responded to compliance queries;
  • explained the model through legal logic, not marketing;
  • supported the onboarding process.

Result: account opened and high-risk status removed

  • the client successfully opened an account with a European financial institution;
  • the “high-risk” classification was removed;
  • payment infrastructure was restored;
  • the business regained its ability to scale.

Why banks often misclassify high-risk businesses

In 80% of cases, the issue is not the business itself, but how it is perceived by banks.

Dating, crypto, gaming, affiliate — these categories are often automatically treated as “high-risk”.

However, risk is determined not by the label, but by structure, cash flows, and compliance.

Typical mistakes businesses make with banks

  • lack of a clear legal position;
  • business described in marketing terms rather than legal terms;
  • absence of AML/CFT justification;
  • structure appears non-transparent to the bank.

How we help businesses pass compliance

  • analyze the business as a bank compliance officer would;
  • build a position that passes KYC/AML checks;
  • prepare Legal Opinions that actually work in practice;
  • support account opening end-to-end.

“High-risk” is not a verdict — it is a matter of proper legal qualification.

The client’s dating business did not change. Only its interpretation for the bank did.

If your business is facing bank refusals, account blocks, or a high-risk classification — the question is not whether you can open an account, but how your business is legally presented.

Calculate the cost of services
1 question

Do you need to open a bank account?

Yes
No
2 question

Do you need a Legal Opinion for another matter?

Yes
No
3 question

Is your business considered high-risk?

Yes
No
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