Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
You are a legitimate EU, UK, or Swiss resident with legitimate income. But because you were born in Iran, Russia, Venezuela, Syria, or another sanctioned country, the exchange has frozen your account. This is one of the most unfair freezes — and it is solvable for residents of non-sanctioned jurisdictions.
Exchanges use automated screening systems that check users against sanctions lists. These systems look at your nationality, country of birth, and sometimes even your name's ethnic origin. If any of these match a sanctioned jurisdiction, the system automatically freezes the account — regardless of where you actually live, how long you have lived there, or whether your funds are legitimate.
This is a blunt instrument. A German resident of 20 years who was born in Iran is flagged the same as someone actually living in Tehran. The exchange's compliance team may not even review the case manually before the freeze is applied.
The core legal argument is straightforward: AML and sanctions regulations apply based on residency and jurisdiction, not birth nationality. If you are a legal resident of Germany, the UK, Switzerland, or another non-sanctioned jurisdiction, the applicable AML law is the law of your country of residence. Your birth nationality is relevant only for sanctions screening — and if you are not on any sanctions list, not resident in a sanctioned country, and not transacting with sanctioned entities, there is no legal basis for the freeze.
We build the case by documenting:
We are honest about limitations. We cannot help if:
In these cases, the freeze is legally justified and no lawyer can override sanctions law. We will tell you this honestly during the free assessment.
Yes. As a German citizen and resident, your regulatory status is governed by German and EU law (MiCA). Your Iranian birth nationality is relevant only for sanctions screening — and if you are not on any sanctions list and not resident in Iran, there is no legal basis for the freeze. We document your German residency, your source of funds, and your sanctions-clear status, then demand the exchange unfreeze your account.
It depends. EU sanctions against Russia are complex and evolving. If you are an EU resident with a valid residence permit and are not on any sanctions list, your personal crypto activity should not be affected. However, some exchanges have implemented blanket freezes on all Russian passport holders, regardless of residency. We can help if you are an EU resident and not on any sanctions list.
Yes. Swiss refugee status gives you a Swiss residence permit and a travel document (Convention travel document) that is accepted for KYC purposes. You are a Swiss resident under Swiss AML law. We help you present your refugee documentation to the exchange and argue that your Swiss residency governs your regulatory status.
No. Exchanges cannot require you to renounce citizenship — that would be discriminatory. We argue that your residency, not your citizenship, should determine your regulatory treatment. You can retain your dual citizenship and still access crypto services, as long as you are resident in a non-sanctioned jurisdiction and are not on any sanctions list.
With complete documentation (residence permit, source of funds, sanctions screening), most cases resolve in 3-6 weeks. The key is engaging the exchange's compliance team through legal channels rather than support tickets. Exchanges are cautious about sanctions issues, but they also recognize that over-blocking legitimate residents creates regulatory and reputational risk.
Related resources: For resolving false-positive sanctions flags on exchange accounts, see our sanctions screening practice. Read our guide on OFAC sanctions false positives in crypto. For how name-based screening affects different jurisdictions, see AML laws by country.
All unusual situations we handle beyond standard compliance.
Resolving false positive sanctions flags on exchange accounts.
How name-based screening causes false matches and how to fix them.
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.