We are increasingly approached by individuals whose personal and/or business bank account(s) have been closed in connection with crypto transactions.  These individuals are adamant that they have not breached of any of the bank’s Terms and Conditions or any applicable laws and regulations. 

In some cases, the bank’s decision to close the account(s) may have been made in error.  Being placed in such an unfair situation can have a profoundly detrimental effect on both the individual and their business due to the wide-ranging, complex and adverse consequences that may follow.

Potential issues with crypto transactions

It is generally fine to use your bank account(s) in relation to crypto transactions provided (and this is non-exhaustive) that:

• You have fully adhered to your bank’s Terms and Conditions.
• You are only dealing with UK-regulated entities and crypto exchanges.
• You are in full compliance with all the applicable laws and regulations; and
• The source of funds is clean.

However, in some circumstances banks can understandably be cautious of transactions involving crypto and may close your bank account in error.

This can have devastating consequences on both personal and business levels.

What can I do to try and challenge a wrong decision to close my personal and/or bank account(s)?

We are increasingly being approached by individuals who have been “de-banked” despite being adamant that they have always acted in full compliance with the relevant bank’s Terms and Conditions and all other legal and applicable rules and regulations.

We have previously written that other issues individuals may face, including account closures, are not limited to political figures in the UK and may affect many thousands of lawful individual and business customers every year.  These cases have exposed the difficult balance many financial institutions and their individual and business customers must strike to gain and maintain access to basic banking services. 

To assist those whose accounts have been closed, Gherson’s financial crime, investigations and regulatory team have previously written blogs titled:

• Why has my bank account been closed
• Why has my business bank account been closed?
• 140,000 SMEs “de-banked” last year – why could I have been de-banked?
• What are the proposed new laws aimed at preventing de-banking?
• Why the proposed new laws to try and prevent de-banking to not go far enough 
• Am I entitled to a basic bank account in the UK?

What can I do to try and challenge a wrongly imposed CIFAS marker?

We are also being contacted by individuals who feel that a financial institution has wrongly imposed a CIFAS marker against their name.

If you have always acted in full compliance with your bank’s Terms and Conditions, as well as all other applicable legal rules and regulations, then you should have a good basis to challenge the bank’s decision to impose any CIFAS markers.

A strong challenge will often involve demonstrating thorough evidence that you have not breached the bank’s Terms and Conditions or any other rules, and that all transactions were at all times done in full compliance will all applicable laws and regulations.

In a previous blog, we examined what a CIFAS marker is and how to try and get it removed, as well as what you can do if a CIFAS marker has been wrongly imposed. 

We have also recently discussed Challenging a crypto-related CIFAS Marker: what you can do.

NAVIGATING FINANCIAL INSTITUTION-RELATED CHALLENGES

Adverse information on compliance databases

We are often approached by individuals who feel that incorrect and/or inaccurate data about them stored in compliance databases is having an adverse effect on their relationship with financial institutions, leading to subsequent issues, such as bank account closures or  difficulties in opening a bank account.

We have also written a series of blogs on a basic overview of the main functions of compliance databases like World-Check and how you can correct information about yourself on such databases?

HOW GHERSON CAN ASSIST

Gherson’s regulatory, white-collar and investigations team are highly experienced in providing assistance on what you can do if your bank freezes or closes your account.  This includes assisting you in submitting a request under data protection legislation, otherwise known as a Data Subject Access Request, to ascertain what information banks and other financial institutions may be holding on you and their decision-making, and then analysing the response and assisting with any appropriate challenge.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on Twitter, Facebook, Instagram, or LinkedIn to stay-up-to-date.

Updated: 14 May 2025

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025

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