Do banks block accounts due to involvement in cryptocurrency transactions?

Russian banks are not required to automatically block accounts upon detecting cryptocurrency-related transactions. However, in accordance with Federal Law No. 115-FZ (“On Counteracting the Legalization (Laundering) of Criminally Obtained Incomes and the Financing of Terrorism”), banks are obligated to assess the economic substance of transactions. In the absence of a clear economic purpose, a bank may suspend the transaction or block the account. Such blocking is particularly likely if: • the transactions appear atypical or non-transparent; • supporting documents confirming the lawful origin of funds are not provided; • there are indicators of cash-out schemes or suspicious transfers. Additionally, under Federal Law No. 161-FZ (“On the National Payment System”), banks are required to respond to complaints and alerts from regulators, which may also result in account restrictions. Thus, involvement with cryptocurrency alone is not a sufficient basis for account blocking. However, a lack of transparency or failure to provide proper documentation may result in the freezing of transactions and the imposition of enhanced due diligence measures.