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Expert in international corporate, IT, and crypto law. Has extensive experience in business setup and support in the USA, EU, LATAM, and the Middle East. Specializes in corporate structuring, compliance, KYC/AML, IP, GDPR, as well as regulation of crypto and fintech projects.

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Case: Prepared an Evidence Base to Confirm the Source of Funds in EU Banks

Reading time: 3 min.

Service: AML / banking support; preparation of explanations and documents for financial institutions.

Client: individual with international financial operations.

Jurisdictions: EU countries.

Period of work: 2026.

Grounds for request

The client contacted us due to restricted access to funds in accounts at several European banks. After a series of international transfers, the banks initiated additional checks and requested confirmation of the source of funds.

The situation required a fast but careful response. In such cases, overly emotional correspondence with the bank or an incomplete package of documents may assign a high-risk profile to the client.

Additional complication

  • checks were conducted simultaneously by several financial institutions;
  • banks assessed not only individual payments, but the client’s overall behavior and the economic logic of operations;
  • some documents required adaptation to the expectations of compliance departments;
  • there was a risk of account closure, long-term freezing of funds or transfer of information to competent authorities.

Actions of the lawyers of “Prikhodko and Partners”

1. Analysis of financial history and risk profile

We assessed the structure of incoming funds, payment purposes, the logic of fund movement and documents that the client could provide to confirm their position.

2. Preparation of explanations for banks

Clear explanations were prepared regarding the source of funds, the economic substance of payments, counterparties and the grounds for conducting operations.

3. Systematization of documents

We prepared a list of necessary documents and helped the client build an evidence base in such a way that it corresponded to the logic of banking compliance.

4. Strategy for further actions

The client received recommendations on communication with banks, the procedure for providing responses, preservation of evidence and involvement of local consultants in case of escalation.

Result

  • the client received a structured position for passing compliance checks;
  • a package of documents regarding the source of funds was prepared;
  • the risks of chaotic or incomplete communication with banks were minimized;
  • the client received a practical plan of further actions in case the blocking continues.

Practical conclusions

  1. European banks increasingly assess not only documents, but also the overall logic of the client’s financial behavior.
  2. The availability of funds itself is not a problem; the problem is the inability to quickly and documentarily explain their origin.
  3. Preparation for an AML check should include not only statements, but also contracts, invoices, explanations and a consistent chronology.
  4. In bank blocking cases, it is important not to argue with compliance, but to provide it with a verifiable and legally correct response.

How we can help

  • analyze the client’s situation and identify legally relevant risks;
  • prepare the evidence base, documents and legal position for communication with counterparties, banks, platforms or donors;
  • support negotiations, claim communication and further legal actions;
  • build a legal model that works not only “on paper”, but also in the client’s real operational activity.

If a European bank has restricted access to funds, requested documents or initiated a compliance check, the lawyers of “Prikhodko and Partners” will help prepare explanations, collect an evidence base and build correct communication with the financial institution.

Calculate the cost of services
1 question

Do you want to prepare a package of documents in advance for passing an AML check?

Yes
No
2 question

Have you faced restricted access to an account or funds?

Yes
No
3 question

Has the bank requested documents from you regarding the source of funds?

Yes
No
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