a bank kérdéseket tesz fel a kriptovaluta-használatról a vállalatomon belül, hogyan válaszoljak

Crypto question is part of customer due diligence, not scope 3

The bank asks this as part of customer due diligence under the Anti-Money Laundering and Countering the Financing of Terrorism Act (Wwft), not as a sustainability question. For banks, cryptocurrency is standard on the list of enhanced risk indicators, so the question recurs at every periodic review, regardless of sector. Answer factually: does the undertaking 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? These 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 follows up with questions about the origin of the funds used and about the wallet or platform details; this connects to the broader question about a vállalkozás vagyonának eredete, which often appears in the same questionnaire. Keep an internal record of which accounts and platforms are used — this is the same kind of documentation as for the banks where the undertaking maintains accounts, and the bank may ask for an overview of these if the answer to the crypto question is yes.

Where this follows from: customer due diligence Wwft

The obligation for ongoing customer due diligence is set out in the Wwft; this law requires the bank to continue monitoring the business relationship and to ask additional questions in the event of unusual or high-risk transactions — including crypto — and to conduct further investigation if necessary. This is an obligation of the bank itself, not a request that the undertaking must prove something that is not asked for; the answer remains factual and limited to what actually takes place within the undertaking.