Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
Changelly is EU-based and passported into Germany under EU AML law. That means BaFin (Federal Financial Supervisory Authority) has authority — and so do we. Swiss legal team with EU compliance expertise. 90%+ success rate.
Changelly is Czech-based → EU AMLD5 compliant; can serve German customers
BaFin treats crypto custody as a regulated financial activity — exchanges need a BaFin crypto custody license to serve German customers legally
This matters because it determines which regulatory body has authority over your case — and whether you have a direct complaint path or need cross-jurisdictional legal action.
What this means for you: Changelly is EU-based and passported into Germany. That means BaFin (Federal Financial Supervisory Authority) has authority — and so does the platform's home EU regulator. We can file complaints with both, increasing pressure on Changelly to resolve your case.
under KWG §2(1) sentence 1 no. 7-10 (crypto custody license), you can file a complaint with BaFin against any licensed crypto custody provider
Under German Banking Act (Kreditwesengesetz, KWG) + GwG (Geldwäschegesetz, AMLD5 transposition), Changelly must conduct customer due diligence and can freeze accounts during AML investigations. However, they must also:
If Changelly doesn't meet these obligations, we escalate to BaFin (Federal Financial Supervisory Authority) and file a formal legal submission. For a broader comparison of how Germany's rules stack up against other jurisdictions, see our AML laws by country reference.
crypto held >1 year: tax-free; <1 year: income tax up to 45% + solidarity surcharge
If your Changelly account is frozen, you may still need to declare your crypto holdings on your Germany tax return — even if you can't access them. Under Germany law, the tax obligation may apply regardless of whether the funds are accessible. We recommend consulting a German tax advisor.
If the freeze causes you to miss a tax deadline, we can provide documentation for the BaFin (Federal Financial Supervisory Authority) and tax authority explaining the situation.
A German trader's swap on Changelly was frozen because the sending address had interacted with a flagged entity. Changelly's compliance tool (Chainalysis) flagged the transaction. We traced the address history and prepared a chain-analysis report. The account was restored after we provided a legal submission citing BaFin (Federal Financial Supervisory Authority)'s guidelines and the client's transaction history.
Details anonymized to protect client confidentiality. Swiss professional secrecy applies.
We analyze your Changelly account, transaction history, and Germany regulatory context to identify the exact trigger. Was it a Chainalysis risk flag? A sanctions screening match? A source-of-funds demand? Each requires a different strategy.
We prepare documentation compliant with German Banking Act — not just Changelly's standard templates. This includes source-of-funds proof, transaction tracing, and any required BaFin-specific forms.
We submit through Changelly's compliance channels — not standard support. Our submission is in German-language correspondence with BaFin accelerates resolution; formal legal submission in German carries more weight and references BaFin guidelines. We coordinate with BaFin even though Changelly is not registered.
We verify everything works and advise on preventing recurrence on Changelly. If Changelly doesn't respond within no statutory maximum holding by exchanges, but BaFin expects resolution within 'reasonable time' — interpreted as 3 months, we escalate to BaFin and pursue cross-jurisdictional action in Czech Republic (EU) if needed.
Tell us what happened. A senior crypto compliance lawyer — not a chatbot, not a junior — will read your case and respond within 6 hours. Swiss professional secrecy applies from your first message.