Daniel Vinnik

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+38 (073) 007-44-41

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: Unlocking Crypto Assets After an AML Check: How to Prepare an Evidence Base and Protect the Client’s Interests

Fintech
Reading time: 3 min.

Service: Client support in a case concerning the freezing of crypto assets and confirmation of the source of funds.

Client: private investor / owner of crypto assets.

Jurisdictions: international element; foreign counterparties and consultants.

Period of work: 2026.

Grounds for request

The client contacted us after the actual freezing of crypto assets in the amount of over 40,000 USDT. The restrictions were related to an AML check and the need to confirm the source of funds, the economic substance of operations and the connection between transactions.

The problem was not only the amount of blocked assets itself. It was important for the client to prevent a situation where the funds remain in an uncertain status for a long time, and each subsequent request only worsens the position due to chaotic or incomplete explanations.

Additional complication

  • the operations covered several agreements, payments and digital transactions that had to be collected into one clear story;
  • some documents were not created for a compliance check, so they required systematization and legal explanation;
  • foreign counterparties expected not emotional explanations, but a formal evidence base with the logic of source of funds / source of wealth;
  • the client risked receiving a refusal only because of incomplete or incorrectly structured communication.

Actions of the lawyers of “Prikhodko and Partners”

1. Initial analysis of transactions and the factual history of funds

We analyzed the materials provided by the client, identified key transactions, determined which documents confirm the economic substance of operations, and which gaps needed to be closed with additional explanations.

2. Formation of the evidence base

Contractual documentation, invoices, acts, confirmations of fulfillment of obligations, a transaction table and explanations regarding the source of funds were prepared and systematized. The documents were collected not as a random archive, but as a logical package for a compliance check.

3. Preparation of the legal position

We formed a position that explained not only the legal grounds for owning the assets, but also the commercial logic of the operations. This approach makes it possible to reduce the risk of formal rejection due to lack of context.

4. Communication with foreign consultants

Separate materials were prepared for further interaction with foreign lawyers and counterparties who participated in the procedure for reviewing the restrictions.

Result

  • the client received a structured package of evidence to confirm the legality of the source of funds;
  • a legal position was prepared for further communication regarding review of the restrictions;
  • the chaotic transaction history was transformed into a clear evidentiary model;
  • the client received a realistic plan of further actions in the case of asset freezing.

Practical conclusions

  1. In cryptocurrency disputes, not only blockchain transactions are important, but also documents that explain their economic substance.
  2. An AML check does not tolerate chaos: every agreement, invoice and payment must form one consistent story.
  3. Proper preparation of the evidence base is often the difference between constructive dialogue and actual loss of access to assets.
  4. For crypto asset owners, it is advisable to prepare a source of funds / source of wealth package in advance, not after blocking.

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.
Calculate the cost of services
1 question

Do you need legal support during an AML check?

Yes
No
2 question

Do you want to prepare documents in advance to avoid asset blocking?

Yes
No
3 question

Have you faced blocking or freezing of crypto assets?

Yes
No
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