bank asks questions about cryptocurrency use within my company what do I answer
Cryptocurrency question is part of client due diligence, not scope 3
The bank asks this as part of client due diligence under the Anti-Money Laundering and Counter-Terrorist Financing Act (Wwft), not as a sustainability question. Cryptocurrency is standard on banks' lists of elevated-risk indicators, so the question recurs at every periodic review, regardless of sector. Answer factually: does the enterprise itself trade in cryptocurrency (as a business activity), does it receive payments in crypto from customers, or does it hold crypto as an investment part of its assets? Those are three different situations and the bank wants to know which applies, not whether the company "does something with crypto".
If the answer is no: that is sufficient, the bank does not need proof of absence. If the answer is yes, the bank usually asks follow-up questions about the source of the funds used and about the wallet or platform details; this aligns with the broader question about the source of the company's assets, which often appears in the same questionnaire. Keep internal records of which accounts and platforms are used — this is the same type of documentation as for the banks where the company maintains accounts, and the bank can request an overview of these if the answer to the cryptocurrency question is yes.
Where this follows from: client due diligence Wwft
The obligation for ongoing client due diligence is set out in the Wwft; this act requires the bank to continue monitoring the business relationship and to ask additional questions in case of unusual or high-risk transactions — including crypto — and where necessary to conduct further investigation. This is an obligation of the bank itself, not a request that the enterprise prove something that is not asked for; the answer remains factual and limited to what actually occurs within the enterprise.
What this is based on
- Trade Register Act 2007 — the data recorded for each company
- Act on the prevention of money laundering and the financing of terrorism — client due diligence
- Directive (EU) 2022/2464 (CSRD)
The regulation itself is on EUR-Lex. We refer for each claim; you do not have to take our word for it.
What you concretely need to do
The implementation of each obligation, with the deadlines involved and the templates for recording it, is included in the subscription.
View the subscription First the free quick-scanThis is not legal advice. This page provides general information on the regulations this platform covers. We do not know your situation. If in doubt about your own case, consult a lawyer or the competent supervisory authority.
Written with AI based on the sources above, checked by a human on 2026-09-05. Is something incorrect? Let us know — corrections receive priority.