AML Account Unblocking

Legal support within AML Account Unblocking is a comprehensive legal and regulatory strategy aimed at restoring a client’s access to bank or cryptocurrency accounts and assets restricted due to financial monitoring procedures (AML/CFT), compliance reviews, or risk assessments conducted by banks, payment systems, or crypto exchanges.

This is not merely correspondence with a bank — it is a structured legal strategy that combines evidence preparation (Source of Funds / Source of Wealth), interaction with compliance departments, regulatory engagement, and, where necessary, judicial protection.

In practice, most AML restrictions arise from a risk-based compliance model, where financial institutions are required to assess transactions, counterparties, and sources of funds and may temporarily suspend operations or decline payments. The key is not simply to “provide explanations,” but to submit structured, legally sound evidence aligned with regulatory standards (National Bank of Ukraine, FATF) and the institution’s internal compliance policies.

In such projects, GOLAW acts as the client’s representative in compliance procedures while simultaneously ensuring legal protection in cases of formalistic or abusive institutional conduct. We:

(i) determine the most effective route — compliance dialogue, claim-based, regulatory, or litigation;
(ii) prepare a structured SoF/SoW package and manage communications with the bank/exchange;
(iii) file complaints with the National Bank of Ukraine or other regulators;
(iv) represent the client in court where required.

What we do

• Analysis of blocking grounds and legal position (including NBU’s financial monitoring approach)
• Preparation of structured SoF/SoW package confirming legitimate source of funds/wealth (crypto and fiat)
• Communication with bank/exchange compliance departments and preparation of responses to additional inquiries
• Complaints and regulatory submissions to the National Bank of Ukraine or relevant supervisory authorities; preparation of good-faith evidence
• Litigation track: claim preparation, evidence preservation, interim relief (where applicable)
• Development of internal AML procedures for businesses (B2B) to minimize repeated blocking risks
• Support in interactions with international financial institutions and payment systems