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bank asks a question about cryptocurrency activities of our company what do they mean

Cryptocurrency question is part of customer due diligence, not sustainability

The bank asks this as part of customer due diligence under the Act on the prevention of money laundering and terrorist financing (Wwft). For banks, cryptocurrencies are a heightened-risk indicator: anonymity, cross-border flows and limited visibility of the counterparty mean that the bank specifically asks about this, separate from the rest of customer due diligence. The bank is not making a judgment about crypto as such, but seeking to establish whether your company deals with it and, if so, in what form: ownership as an investment object, receipt of crypto as payment from customers, or trading/exchange as a business activity. Each form leads to different follow-up questions and sometimes different supporting documents.

Recognize the pattern: this question usually appears in the same section as the questions about origin of the company's assets and about the bank relationships that the enterprise maintains — the bank is trying to get a complete picture of cash flows here, not just crypto. If your company has no crypto activities, "no" with a brief explanation is usually sufficient; the risk lies in answering "no" too quickly when there has actually been occasional invoicing or investment in crypto. So check internally with finance and whoever prepares the balance sheet before you confirm this, because this is one of the few answers where an incorrect "no" counts more heavily than a "yes" with explanation.

Where this comes from: customer due diligence under the Wwft

The obligation to conduct customer due diligence derives from the Wwft, which requires banks to take a risk-based approach: the more unusual or opaque the cash flow, the deeper the investigation. Cryptocurrencies fall in practice under the category of heightened risk, comparable to the reason why banks also ask further questions about politically exposed persons within the UBO structure. This is separate from the Trade Register Act 2007, which only regulates the recorded business data, and separate from the CSRD Directive, which concerns sustainability reporting — the crypto question therefore always comes through the Wwft channel, even if it appears in a combined questionnaire.

What this is based on

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.

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This 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.