In Ukraine, there has been a significant increase in the number of cases of bank blocking of individual accounts. According to Telegraf, customers may not even receive a warning and learn about access restrictions only when they try to use their funds.

Such actions are based on the NBU Resolution No. 65 on financial monitoring of May 19, 2020, which gives banks broad powers to verify financial transactions, block, and forcibly close accounts.

According to the publication, lawyers named the following as the main reasons for blocking:

• Trigger words in the purpose of payment, in particular, “for crypto,” “currency exchange,” “for goods/services” when received on a private account and “debt repayment” if such transfers are regular
• Transactions related to cryptocurrencies — receipts or transfers to exchanges and brokers, which still do not have full legal regulation in Ukraine
• Inconsistency of transactions with the client’s financial profile — a sharp increase in income without notifying the bank and providing documents on changes in income
• Regular or numerous transfers from different persons — the bank may suspect entrepreneurial activity without registration of an individual entrepreneur (IE)
• Atypical or frequent cash withdrawals — each bank has its own criteria for “large amounts,” ranging from UAH 10,000-20,000 to UAH 50,000 or more
• Inability to officially confirm the source of income — banks may require declarations, OK-5/OK-7 certificates, documents on the sale of property, inheritance, etc
• Ignoring bank requests or submitting incomplete/false information. It is important for individual entrepreneurs to upload their tax returns to a mobile application or online banking twice a year

As a reminder, according to a report by the European Bank for Reconstruction and Development, from July 2023 to July 2024, Ukrainian users bought $882 million worth of bitcoin.

Ivan Maryniuk, the Head of Tax Practice at Ilyashev & Partners Law Firm, summarized:

“The main reasons for blocking are the unconfirmed source of funds, inconsistency of transactions with the client’s financial profile, regular receipts from a large number of different payers, which banks consider as unregistered business activities. We can also add transactions that have signs of crypto activity (conversion of cryptocurrencies into fiat funds through P2P or unidentified intermediaries), as well as large one-off cash receipts without a previous history of such transactions.”

Monitoring is automatic:

• Special software algorithms analyze transactions
• If a risk criterion is triggered, the robot blocks access to the account
• The client may not receive a warning

This means that even those users who do not break the law but whose financial activity seems suspicious to banking algorithms may be vulnerable.

It is worth noting that the draft law on virtual assets adopted in the first reading in early September 2025 received more than 2,500 amendments.