Question from a reader:
“Hello. My accounts were blocked, citing Federal Law-115. The bank demands confirmation of the origin of the funds, and the situation looks deadlocked. The fact is that I have practically no official documents. Part of the money is cash savings that I collected over the years at home, and the rest is income from freelancing (design, no contracts, just transfers to a card) and some successful cryptocurrency trading through P2P platforms. I cannot provide any 2-NDFL certificates or employment contracts. The bank simply ignores my words. What to do in such a situation? Will my money be lost now?
Lawyer's answer
Federal Law No. 115-FZ “On Combating the Legalization (Laundering) of Income...” in 2026 remains one of the most stringent regulatory instruments. For the average person, encountering banking compliance often looks like an accusation without a presumption of innocence. The situation when the client does not have “iron” documents such as an apartment purchase and sale agreement or a certificate of white salary is difficult, but, as my 18 years of practice shows, it is by no means hopeless.
You need to understand the logic of the bank: it doesn’t want to steal your money, it’s afraid of the Central Bank. For a credit institution, any incomprehensible payment is a risk of license revocation. When they ask for documents, they are essentially saying: "Explain to us the economics of your operations so that we can cover ourselves with the regulator." The absence of a government-issued document does not relieve you from the need to provide explanations, and a detailed explanation can replace the document.
Strategy of “Information reconstruction”
If there are no contracts, your main weapon is a detailed written explanation. Not a “these are my personal funds,” but a detailed essay. Legal practice shows that a well-written explanatory note that reveals the economic meaning of transactions is often received more favorably by financial monitoring than a chaotic set of checks.
You must write out the chronology. If this is freelancing, describe the nature of the services: “I carried out a design project for such and such a person, we agreed on the messenger.” The following are enclosed as confirmation:
- Screenshots of correspondence with the customer;
- links to portfolios with these works;
- Screenshots of translations, where the dates coincide with the delivery of the project.
This is called indirect evidence of the reality of economic activity. For the KYC (Know Your Customer) procedure they have weight.
The subtleties of working with cryptocurrency and P2P
The algorithm of actions with cryptocurrency has already been developed. Banks block transfers from third parties (drops), seeing them as a risk. Yours
