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: Unblocked bank account in the EU (Revolut Bank UAB, Lithuania)

Fintech
Reading time: 3 min.

Service: Unblocking a bank account abroad
Client: individual, EU resident
Financial institution: Revolut Bank UAB (Lithuania)
Date of account freezing: 24 July 2025
Grounds for freezing: Account Freezing Order issued by Vilniaus apskrities vyriausiojo policijos komisariato Vilniaus miesto penktasis policijos komisariatas

The client lost access to the account, funds, and all financial operations. At the same time:

  • the client did not receive any official copy of the police order;
  • written and electronic requests to the Vilnius police remained unanswered;
  • checks via Interpol and World–Check revealed no negative records;
  • Revolut refused to provide details, referring to its obligation to comply with law enforcement authorities’ requirements.

Additional complication

On the day of the account freezing, EUR 1,149 was debited from the client’s account in favor of a third individual as a “mandatory fund return”. At the same time:

  • the client had never received any funds from this person;
  • the account statements contained no incoming transactions that could be subject to a return;
  • Revolut’s explanations were limited to the wording “insufficient evidence to dispute a recall request”.

This significantly increased the client’s legal risks.

Actions of the lawyers of “Prikhodko & Partners”

  1. Legal analysis of the grounds for freezing

We analyzed:

  • the provisions of PSD2 (Directive (EU) 2015/2366) regarding the bank’s obligation to provide the client with basic information on account restrictions;
  • EMD2 (Directive 2009/110/EC) in the context of protecting the rights of electronic money users;
  • AMLD5 (Directive (EU) 2018/843) regarding the proportionality of financial monitoring measures;
  • the practice of the Bank of Lithuania as the supervisory authority over Revolut Bank UAB.
  1. Preparation of a formalized complaint to Revolut

In December 2025, we prepared and submitted a detailed complaint letter in English with the following demands:

  • to confirm the validity and details of the Account Freezing Order;
  • to provide the legal qualification of the debit of EUR 1,149;
  • to explain the absence of any notifications to the client from the police;
  • to formally record the client’s cooperation and readiness to provide all AML documents.
  1. Communication with the Vilnius police

In parallel, an official request in Lithuanian was prepared and submitted to the police commissariat in compliance with the administrative procedure, without any self-incriminating wording.

  1. Strategic pressure through the regulator

After receiving the final response from Revolut’s Complaints Analyst (December 2025), in which the complaint was formally rejected, we:

  • recorded procedural violations by the bank;
  • prepared a position for filing a complaint with the Bank of Lithuania as the out-of-court dispute resolution authority;
  • separately formed the legal framework for potential judicial protection.

Result

As a result of consistent legal actions and properly structured communication:

  • the restrictions on the client’s account were lifted;
  • Revolut restored access to funds and operations;
  • no additional sanctions or tax consequences arose for the client;
  • suspicions against the client by the financial institution were removed without referral of the case to court.

Practical conclusions

  1. Account freezing is not a verdict, even when initiated by a law enforcement authority.
  2. Fintech companies often act overly cautiously, but are obliged to comply with the principle of proportionality.
  3. Independent calls or chaotic explanations by the client may worsen the situation.
  4. A well-structured legal position with references to European directives significantly increases the chances of unblocking.

How we can help

The law firm “Prikhodko & Partners” provides support in:

  • unblocking bank accounts in the EU and other countries worldwide;
  • unblocking accounts in Revolut, Wise, Paysera, and other fintech platforms;
  • AML/CTF checks and dispute cases;
  • communication with banks, payment institutions, and EU regulators;
  • preparation of legal positions for regulators and courts.

If your account is frozen, it is a matter of strategy, not panic. We know how to handle it properly.

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