The information provided in this article is for informational purposes only and does not constitute financial advice. Investing in cryptocurrencies carries a high level of risk.
The withdrawal is stuck, the account is frozen, and support keeps answering in building blocks: “A review is under way, we are not permitted to give further details.” It looks like evasion. It is precisely what the law requires.
Anyone who receives no explanation after a freeze is not facing arbitrary treatment. They are facing Section 47 of the German Money Laundering Act, the GwG. That provision expressly prohibits the provider from telling you about a suspicious activity report it intends to file or has already filed, and equally about any investigation that follows from it. Once you know this, you stop asking the wrong question and start asking the right one.
Account frozen: the key points
- Under Section 47 GwG the provider must not inform you about a suspicious activity report. The silence is a legal duty, not bad service.
- Under Section 46 GwG a reported transaction may be executed at the earliest once the consent of the Financial Intelligence Unit or of the public prosecutor has been passed to the provider, or once the third business day after the day the report was sent has elapsed without the transaction being prohibited.
- For this deadline, Saturday does not count as a business day (Section 46 (1) sentence 2 GwG).
- Crypto providers licensed in the EU are obliged entities under Section 2 (1) no. 2 GwG. The reporting duty and the ban on tipping off apply to them just as they do to banks. The report goes to the Financial Intelligence Unit, the FIU, and not to BaFin.
- A second reporting duty has to be kept apart from this one, and the two are often confused. Since December 30, 2024, providers have had to report suspected market abuse to BaFin under Article 92 MiCAR. That has nothing to do with money laundering, and nothing to do with your freeze.
- Nothing works as well as an unbroken record of where the funds came from. A letter of complaint achieves far less.
- A freeze has to stay proportionate. If it drags on for months with no discernible reason, the route via a BaFin complaint and legal representation is open.
Account frozen: what actually runs in the background
In Germany, crypto service providers are obliged entities under anti-money-laundering law by virtue of Section 2 (1) no. 2 GwG. It is the same category of duties that applies to banks, merely a separate number in the statute. If a transaction gives rise to reasonable suspicion, the provider is not merely entitled but obliged to file a report with the Financial Intelligence Unit, and to halt the transaction for the time being.
What triggers this is often a pattern rather than a specific allegation against you: an unusually large withdrawal after a long quiet spell, inflows from an environment classified as high risk, a change of residence, a change of device, a trade between private individuals.
The fact that you learn nothing is part of the design. A suspicious activity report the subject is told about would be worthless.
Account frozen: which deadlines really apply
This is worth a close look, because a great deal of vagueness circulates online.
What matters is the scope. The three-business-day deadline applies to the reported transaction. It does not mean that an account automatically reopens after three days. If the public prosecutor prohibits execution or opens proceedings, the rules of those proceedings apply, and they know no such deadline.
This is why those affected go through two very different experiences. Some cases are settled within a few days, others drag on for months. Which one your own case will be cannot be told from the outside, and the provider is not allowed to say.
Account frozen: what you can do yourself
The decisive point is unspectacular. What shortens a review is a clean, documented path for the money, from the original source through to the transaction under scrutiny.
What belongs in it:
- Purchase records. Bank statements for the initial deposit, invoices, statements from the exchange where you bought.
- The path in between. Wallet addresses and transaction IDs showing how the funds travelled from there to here. Gaps are the real problem, not the amounts.
- Tax classification. A tax return schedule or a summary from a tax tool creates plausibility, and portfolio tools deliver the history at the push of a button.
- One matter-of-fact covering sentence that ties the two together: “Please find attached the evidence on the origin of the funds for the transaction of …”.
What does not help: pressure via social networks, chasing support every day, or asking for the reason. Support is not permitted to answer, and it is not the body that decides.
If nothing moves, the route leads through a formal complaint to BaFin and, where larger amounts are at stake, through legal representation. A freeze has to remain proportionate, which means that occasion, scope and duration have to fit together. This article is no substitute for legal advice.
Account frozen: what this says about choosing a provider
Two things differ markedly between providers, and both become apparent only when it matters.
The first is access to a genuine review unit, meaning whether there is a way to submit documents in structured form or only a form that leads nowhere. The second is the supervisory framework. With a provider licensed in the EU there is a supervisory authority you can turn to and a clear legal route. With a provider outside the EU there is neither.
Which providers hold an EU licence is set out in the overview of regulated crypto exchanges. A licence does not prevent a freeze. It determines who you have claims against.
The related and worse case is the insolvency of the provider. What happens to holdings then, and how losses are classified for tax purposes, we have written up separately: Crypto exchange insolvent, are lost coins tax-deductible?
Account frozen: frequently asked questions
Is the exchange allowed to freeze my account just like that? Where there is reasonable suspicion it is in fact obliged to. That is not without limits: occasion, scope and duration have to be proportionate.
Why does nobody tell me the reason? Because Section 47 GwG prohibits it. The provider may mention neither the report nor any investigation that follows from it.
Surely the account has to be open again after three business days? No. The deadline applies to the reported transaction, not to the account. If proceedings are opened, their rules apply.
Is there any point in filing a criminal complaint against the exchange? As a rule there is not, because the freeze rests on a statutory duty. Proof of the origin of the funds is more effective, and where necessary a complaint to the supervisory authority.
Can I move my balance to another provider? Not while a review is under way. That is precisely why holding your entire stack with a single provider is risky.
Sources
- Section 46 GwG, execution of transactions
- Section 47 GwG, prohibition of disclosure
- Section 2 (1) GwG, obliged entities
- BaFin: suspicious transaction reports under Article 92 (1) MiCAR (market abuse, not money laundering)
