How Banks Block Fintech Startup Accounts and how to Avoid it

How Banks Block Fintech Startup Accounts and how to Avoid it

Banks block fintech startup accounts when the money-laundering, sanctions or reputational risk of a customer outweighs its value. There are almost always signals before a block, and most cases can be prevented. We go through why banks block accounts, which actions trigger it and what to do in advance to keep an account stable.

Checked on 21 October 2026. Rules and sources are current as of this date.

Why banks block fintech startup accounts

The professional term is de-risking: a bank refuses a customer, or a whole category of customers, it considers risky for money laundering. The European Banking Authority (EBA) in its 2022 opinion names typical reasons: risk above the bank’s appetite, lack of expertise to assess the business model, or compliance costs that exceed the expected profit.

Many refusals follow from a formal rule: if the bank cannot complete customer due diligence (CDD), it must not carry out the transaction and must end the relationship (Art. 14(4) of Directive (EU) 2015/849). From 10 July 2027 this rule will be replaced by Regulation (EU) 2024/1624 (AMLR).

Tipping-off

The law forbids a bank to tell a customer about a review or a suspicious transaction report (Art. 39 of Directive 2015/849). That is why notices sound vague.

6 main triggers of a block

Opaque ownership and source of funds

A chain of holdings with no clear beneficial owner and no proof of where the money comes from. On structuring, see our article on choosing a jurisdiction for your company.

High-risk niche and geography

Crypto, iGaming, payments, traffic arbitrage, as well as users and counterparties from sanctioned jurisdictions.

Activity does not match what was declared

You described SaaS, but the account shows third-party payments, split payments, pass-through flows or a sudden jump in turnover. More on transaction laundering and miscoding.

Weak AML/KYB, no licence

Policies exist only on paper, no monitoring, counterparties unchecked, compliance run by a part-timer. For the types of licences, see Licensing, compliance and AML/KYC.

Weak finances

No revenue and a short runway: the bank doubts you can sustain compliance procedures.

Silence in response to requests

A late or incomplete answer to a request for information (RFI) is by itself grounds to restrict the account.

Example: JPMorgan and stablecoin startups

According to The Information (December 2025), JPMorgan had closed or frozen the accounts of BlindPay and Kontigo, stablecoin startups working in Latin America through the payments provider Checkbook. The bank reportedly flagged activity linked to Venezuela and other US-sanctioned locations; Checkbook’s CEO tied the closures to a surge in chargebacks, and a bank spokesperson said it was not about stablecoins. The bank has not officially disclosed the details. The takeaway: the bank assesses not the “legality” of the product but its own exposure to the regulator.

How to avoid a block: 6 steps

  1. Choose a bank for your model

    Ask in advance whether it works with your niche and which documents, volumes and jurisdictions are acceptable.

    Start here
  2. Prepare a full onboarding package

    Business model and money-flow diagram, ownership structure with beneficial owners, source of funds, licences, AML/KYC policy, counterparty checks (KYB) and a geography map.

  3. Declare your volumes and stick to them

    A serious deviation from the profile is a classic trigger. Warn the bank in advance about growth, a new jurisdiction or a change of beneficiaries.

  4. Keep at least two accounts

    With different providers, for example a bank and a payment institution (EMI/PSP): one block should not stop the business.

  5. Build your own AML/KYC control

    A policy, customer identification, transaction monitoring and a responsible officer. The bank needs to see that you manage the risk.

  6. Answer requests fast and in writing

    Appoint someone to handle the bank and attach a short explanation to every answer.

Tip

It is best to sort out structure and licensing before launch. We help under Company structure and legal support for fintech and payment services.

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Case analysis

Hypothetical example, not a real case

A fintech startup receives a bank notice that its account will be closed in 30 days with no reason given. A sensible order of action is to ask at once for the reasons in writing, assemble and send a package of documents on the business, the sources of funds and counterparties, open a backup account at another bank in parallel, and prepare to move payments so that settlements are not lost.

If your account is already blocked

  1. Do not ignore the bank’s requests

    A late answer itself becomes grounds for restrictions. Reply on time and in writing.

    Urgent
  2. Find out the nature of the restriction

    Sanctions screening, internal assessment, automated monitoring or a data error: the strategy depends on it. Ask in writing which documents are needed.

  3. Bring in a lawyer

    A letter from a law firm is read differently by a compliance team than a founder’s emails, and the dialogue moves faster.

The bank assesses not the “legality” of your product but its own exposure to the regulator.The LegalBit team

Checklist: is your account safe

Documents and structure

The bank knows your model and agrees with it. Beneficial owners and ownership chain documented. Source of funds confirmed. You have a licence or a rationale for none. Financial statements and runway available. At least two accounts with different providers.

Operations and control

AML/KYC policy and transaction monitoring in place. KYB procedure for counterparties. Map of geographic exposure prepared. Someone is responsible for the bank relationship. Turnover matches the declared profile. The bank is warned of changes.

Frequently asked questions

Why did my bank block my account without explaining why?

Anti-money laundering rules prohibit a bank from telling a customer that a review is under way or that a suspicious activity report has been filed (known as tipping-off). That is why notices are often generic: “additional review required” or “change in bank policy”. You can still ask in writing: the bank may not state the reason, but it will usually tell you which documents and information it needs to lift the restrictions.

Can a bank close a fintech company’s account without giving a reason?

Usually the account terms allow the bank to terminate with prior notice, so it is not always obliged to explain. In the EU, however, payment institutions are entitled to access to accounts on an objective, non-discriminatory and proportionate basis (PSD2 Article 36), and a bank must give the supervisor duly motivated reasons for rejecting a payment institution. The EBA treats blanket refusals of whole customer categories as a sign of ineffective risk management. Your actual rights depend on the jurisdiction and your contract.

How long does the review take before a block is lifted?

It depends on the bank and the complexity of your structure: from a few days if your documents are in order and prepared in advance, to several weeks or months if the bank asks for more detail on the ownership chain and the source of funds. The more complete your first package, the shorter the review.

What bank should a fintech startup choose?

One that understands your model and already works with companies in your niche, not simply the cheapest. Ask the bank directly whether it accepts customers in your category, which licences and documents it needs, and which turnover and jurisdictions are acceptable. Do not build your operations on a single account: keep at least two with different providers.

Can a lawyer help if my account is already blocked?

Yes. A lawyer can prepare the document package and the business-model explanation, respond to the bank’s requests, assess whether your contractual and regulatory rights have been breached, and set up the structure so that the block does not recur. The earlier you involve one, the better: some contractual deadlines are short.

See also: Transaction Laundering and Miscoding: The Hidden Threats to Your Fintech Business; What is Know Your Customer (KYC) and why is it essential for cryptocurrency exchanges?; EMI and Payment Institution Licence in the EU, UK and Canada; Accepting crypto payments in business. Services: legal services for fintech and payments.

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