📌 Introduction
With the growing interest of individuals in cryptocurrencies and digital assets, the number of cross-border transfers directly or indirectly related to crypto activity is steadily increasing. Even when a transfer is initiated by a private individual, banks — especially correspondent banks — may apply enhanced scrutiny to such transactions. One of the most unexpected yet legitimate requests is the submission of a license or legal basis for cryptocurrency-related activities. This raises important questions: Can a bank legally make such a request? When is it justified? And what should an individual do in such a situation?
🏦 The Role of a Correspondent Bank
A correspondent bank is a financial institution that acts as an intermediary in international transfers between two banks that do not have a direct relationship. It facilitates international transactions, particularly those in major reserve currencies such as USD or EUR.
In practice, the correspondent bank bears shared responsibility for ensuring the legitimacy of the transaction, even if the sender or recipient is not its direct client.
Why Are Crypto-Related Transfers Under Heightened Scrutiny?
According to international anti-money laundering (AML) and counter-financing of terrorism (CFT) standards, cryptocurrencies are classified as high-risk assets due to the following reasons:
- The anonymity of transactions and wallet addresses;
- The difficulty in tracing the source of funds;
- Jurisdictional inconsistencies in regulation;
- The frequent use of crypto assets in grey or illegal schemes.
For an individual, this means that even a standard international bank transfer may be flagged for additional checks if a link to cryptocurrency is suspected.
📄 Can a Correspondent Bank Request a License from an Individual?
At first glance, requesting a license from a private individual seems unreasonable, as licensing requirements generally apply to legal entities that provide services to third parties. However, in practice, such a request is often phrased differently — the underlying intention remains the same: the bank seeks evidence of the legal origin of the funds and confirmation that the individual’s activity is legitimate.
