Nils Silinevics
Partner · AML & Crypto Compliance · Former FIU Investigator
You've been told your name or address matches a sanctioned individual on FixedFloat. FixedFloat is a non-custodial swap service based in distributed (no single HQ), regulated under varies by user jurisdiction. Unlike traditional exchanges, FixedFloat can hold your funds during AML checks even though you never created an account. The service uses Crystal Blockchain for transaction screening. FixedFloat holds transactions when Crystal Blockchain flags source addresses with high risk scores, requiring source-of-funds proof before releasing funds. 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.
FixedFloat holds transactions when Crystal Blockchain flags source addresses with high risk scores, requiring source-of-funds proof before releasing funds. FixedFloat suffered a major hack in 2024 that compromised their operations and eroded user trust. The hack also affected their compliance processes — they became more aggressive in holding transactions, partly to compensate for the hack losses and partly because their compliance infrastructure was disrupted. This background matters because it shapes how FixedFloat handles compliance — and how we approach resolving your case.
The compliance framework: FixedFloat operates under varies by user jurisdiction, overseen by unclear (no single jurisdiction). Their compliance infrastructure uses Crystal Blockchain for blockchain analytics and manual for identity verification. FixedFloat is known for fixed-rate and floating-rate crypto swaps, Lightning Network support, serving traders who want predictable swap rates and Lightning Network users — and their compliance team is calibrated to flag deviations from typical user behavior in that segment.
What triggers sanctions screening on FixedFloat:
Real case — post-hack paranoia: After the 2024 hack, a user's ongoing swap on FixedFloat was held indefinitely. FixedFloat's support — already disrupted by the hack — didn't respond for 3 weeks. The user's 1.2 BTC was stuck. We submitted a legal demand citing consumer protection obligations and the fact that holding user funds indefinitely without explanation constitutes conversion (unlawful detention of property). FixedFloat released the funds within 5 days of receiving the legal letter.
What FixedFloat requires to resolve this: Depending on the trigger, FixedFloat may ask for government-issued photo ID (verified through manual), 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: FixedFloat 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 FixedFloat: FixedFloat's post-hack compliance posture is defensive and uncommunicative. Their distributed structure (no clear HQ) makes regulatory escalation harder — there's no single regulator to complain to. We use legal pressure focused on the conversion claim (unlawful detention of property) rather than regulatory complaints. FixedFloat's lack of clear jurisdiction actually works in our favor — they can't invoke a specific regulatory framework to justify indefinite holding.
Sanctions Screening on FixedFloat — 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 FixedFloat'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 unclear (no single jurisdiction) obligations and varies by user jurisdiction. FixedFloat'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}.
The hack disrupted FixedFloat's operations, including their compliance and support teams. If your swap was held during or after the hack, response times are significantly longer than pre-hack. FixedFloat has not been transparent about the hack's full impact, which makes resolution harder. We use legal pressure (specifically, a demand for release of property) to force FixedFloat to process held transactions, regardless of their operational disruptions.
FixedFloat operates without a publicly disclosed headquarters, which creates regulatory ambiguity. This is both a problem and an advantage: there's no single regulator to complain to, but FixedFloat also can't invoke a specific regulatory framework to justify indefinite fund holding. We use general legal principles (conversion, unjust enrichment) rather than specific regulatory complaints.
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 FixedFloat flagged, and any sanctions screening details. We respond within 6 hours.