Recently, many users of P2P crypto transactions on exchanges such as ByBit have encountered the same problem: the bank blocks the card, places restrictions on the account, and requests a bunch of documents.
Sometimes immediately.
Sometimes after a couple of months.
Officially, it looks like this:
We have been forced to restrict transactions on your account… The decision was made in accordance with 115-FZ…
Let’s figure out what this means.
📕 What is 115-FZ?
This is the Federal Law “On Combating the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism.”
It’s a complicated name, but in reality:
- The bank is required to monitor your financial activity.
- If it appears suspicious, the bank is required to request an explanation.
- If the bank is not satisfied with the explanation, it has the right to restrict access to the account.
The bank itself decides whether to notify the Central Bank. This is not a court, prosecutor’s office, or tax authority — it is simply an internal decision by the bank, and it is almost useless to argue with it.
💸 How to comply with Federal Law No. 115-FZ when exchanging cryptocurrency via P2P
It would seem to be straightforward: you sold USDT on an exchange → received money on your card → withdrew or transferred it. But now the P2P market is changing dramatically, and behind this are gray schemes that hide behind the screen of private sellers and buyers.
Here’s how it works:
Let’s first understand what processing is and why it’s a problem. Processing is a server that processes payments, and behind it are:
- Cashiers
- Online casinos
- Illegal marketplaces
- Schemes for selling access, subscriptions, bots, etc.
All of these operate according to the same pattern:
- The processor buys access to P2P — connects the “trader” and gives them a rate that is 10% higher than the market rate.
- The trader places P2P ads on the exchange.
- The processor funnels traffic from other people’s bank cards there — or uses you as a proxy.
- The money you receive is not just a “payment from a person,” but the result of a complex chain that can lead to scams, hacking, casinos, etc.
Roughly speaking, it’s a Pandora’s box: you never know who is actually sending the money
The bank sees everything: money from unknown individuals, mass inflows, different geographies, instability — all of these are triggers for 115-FZ
🧾 What happens next
You receive a letter from the bank:
You need to provide documents confirming the origin of the funds…
And then down the list:
- Explanations for each incoming transfer
- Agreements with senders (whom you do not know)
- Proof of income (2-NDFL certificate, tax returns)
- And if the bank suspects cryptocurrency, they ask for screenshots from the exchange, transaction history, explanations of the purpose of the purchase/sale
In practice: 99% of people cannot provide any of this because these were P2P transactions with random people connected to gray processing (which you already learned about in this post)
Result:
- Card blocking
- Transaction restrictions
- Sometimes — account closure and a “black mark” in the banking system
🔒 Why the “card-card” approach no longer works
Previously, P2P was a way to bypass bank fees and quickly sell/buy crypto
Unfortunately, today it is a gold mine for gray schemes, where:
- 99% of P2P ads are connected to processing
- The details of the final recipients are used (the so-called “gray triangle”) — you think you are receiving a transfer from the buyer, but in reality it is a chain of 3-4 “layers” that you will never know about
- Banks see this, they know about it. And they ban it
We will continue in the second post…
