Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
You've found your account suddenly frozen due to a potential sanctions connection on Changelly. Changelly is a non-custodial swap service based in Lithuania, regulated under Lithuanian AML Law (transposing EU AMLD6). Unlike traditional exchanges, Changelly can hold your funds during AML checks even though you never created an account. The service uses Chainalysis for transaction screening. Changelly holds swap transactions when Chainalysis flags the source address, requiring AML verification before releasing funds — even though the user never created an account. You receive a notice that your account has been flagged for a sanctions screening match, or your account is suddenly frozen without explanation. The platform is legally obligated to block accounts with potential sanctions matches pending verification.
Changelly holds swap transactions when Chainalysis flags the source address, requiring AML verification before releasing funds — even though the user never created an account. Changelly operates as a non-custodial swap service based in Lithuania, but can still hold funds during AML checks. The service integrates with major wallets like Trezor and Ledger — which means users can trigger a Changelly AML hold without ever visiting changelly.com directly. This background matters because it shapes how Changelly handles compliance — and how we approach resolving your case.
The compliance framework: Changelly operates under Lithuanian AML Law (transposing EU AMLD6), overseen by Lithuanian Financial Crime Investigation Service (FCIS). Their compliance infrastructure uses Chainalysis for blockchain analytics and Sumsub for identity verification. Changelly is known for non-custodial instant crypto swaps without account requirements, serving users who want to swap crypto without registering on an exchange — and their compliance team is calibrated to flag deviations from typical user behavior in that segment.
What triggers sanctions screening on Changelly:
Real case — non-custodial fund holding: A user initiated a BTC-to-ETH swap through his Trezor wallet's built-in exchange feature. The swap was routed through Changelly, which flagged the source address via Chainalysis. The user's 0.5 BTC was held by Changelly — but he had no Changelly account, no support portal access, and only an email address. Changelly demanded full KYC for a swap the user initiated from a hardware wallet. We documented the user's ownership of the Trezor, traced the BTC source to a regulated exchange purchase, and Changelly released the ETH equivalent in 11 days.
What Changelly requires to resolve this: Depending on the trigger, Changelly may ask for government-issued photo ID (verified through Sumsub), proof of address (utility bill or bank statement within 3 months), AML compliance review (exchange statements, bank records, payslips, tax returns, or business documents), detailed transaction explanations with on-chain evidence, and in some cases a video verification interview. The challenge: Changelly rarely tells you which specific trigger caused the sanctions screening, so you're guessing at what documentation to provide — and each rejected submission makes the next one harder.
Our approach is specific to Changelly: Changelly's unique challenge is that the user has no account relationship — only a transaction reference number. We prepare documentation that proves wallet ownership (signing a message from the source address), traces the source of funds, and provides KYC through Changelly's Lithuania-based compliance team. The key is proving wallet ownership cryptographically — something Changelly's compliance team accepts but rarely explains to users.
Sanctions Screening on Changelly — our strategy: We prepare a formal non-association declaration with evidence that you are not the sanctioned individual — different date of birth, different nationality, different address, different occupation — and submit it through the platform's compliance channels with a legal cover letter.
The submission that matters: Instead of submitting through Changelly's standard support channels (where you'll get automated responses or generic template replies), we prepare a professional legal submission — a structured compliance package with a cover letter from a Swiss law firm citing Lithuanian Financial Crime Investigation Service (FCIS) obligations and Lithuanian AML Law (transposing EU AMLD6). Changelly's compliance team processes legal submissions differently from regular user tickets — they're assigned to senior compliance officers, not support agents, and they bypass the automated response loop that delays most cases by weeks.
When standard compliance isn't enough: Some situations fall outside the normal compliance flow — inherited crypto holdings, accounts registered under another person's name, unprovable source of funds through conventional documentation, or cross-jurisdictional complications where your residence, the exchange's jurisdiction, and the fiat banking path all differ. If that sounds like your case, our complex cases practice handles scenarios that other firms decline.
Further reading: our guide on OFAC sanctions false positives in crypto covers the documentation and legal strategy in more depth.
We confirm the sanctions match is a false positive by comparing your identity details against the sanctioned individual's known attributes: date of birth, nationality, address, occupation. Partial name matches are the most common cause.
We prepare a formal non-association declaration with evidence: your passport/ID, date of birth, nationality, address, occupation, and a sworn statement that you are not the sanctioned individual. We cross-reference OFAC SDN, EU consolidated, and UN sanctions lists.
We submit the non-association declaration to {p_name}'s sanctions compliance team — not standard support. Our legal cover letter references {regulator} sanctions screening requirements and the false positive rate for common names.
Sanctions screening false positive resolved — account fully restored. We advise on name variations that may trigger future sanctions matches on {p_name}.
This is the core Changelly problem. You initiated a swap from a wallet (Trezor, Ledger, Exodus) and Changelly flagged the source address. You have no account, no login, no support portal — only a transaction ID and an email. We help by: (1) proving wallet ownership through cryptographic signature, (2) providing source-of-funds documentation, and (3) submitting through Changelly's Lithuanian compliance team with legal cover. Without professional help, Changelly can hold funds indefinitely.
No — but they can hold them indefinitely. Changelly is a Lithuanian entity subject to EU AML regulations, which require source-of-funds verification for flagged transactions. If you refuse KYC, Changelly won't return the funds, but they also can't legally confiscate them. The funds sit in a compliance holding wallet. We help you provide the minimum documentation needed to satisfy their AML obligations and get your funds released.
Platforms screen all users against OFAC SDN, EU consolidated, UN, and national sanctions lists using name-matching algorithms. If your name is similar to a sanctioned individual — even a partial match — your account is automatically flagged. False positives are extremely common, especially for names from the Middle East, Eastern Europe, Africa, and Asia. The flag doesn't mean you're sanctioned — it means the platform needs to verify you're not the sanctioned person.
Platforms screen against: OFAC SDN List (US), EU Consolidated Financial Sanctions List, UN Security Council Consolidated List, UK HM Treasury Sanctions List, and potentially national lists for the platform's jurisdiction. Each list covers different individuals and entities, and a match on any one list triggers a block.
We prepare a non-association declaration that includes: your full legal name, date of birth, nationality, passport number, current address, and occupation — compared side by side with the sanctioned individual's known details from the sanctions list entry. Key differentiators: date of birth (most definitive), nationality, place of residence, and occupation. The more differences we can demonstrate, the faster the flag is cleared.
Tell us your nationality, what Changelly flagged, and any sanctions screening details. We respond within 6 hours.