miért kérdez rá a bank, hogy végzek-e kriptó tevékenységet

A bank checks crypto activity as a money laundering risk

The bank asks this because cryptocurrencies represent an increased-risk-indicator for it within the client due diligence that is mandatory under the Anti-Money Laundering and Terrorist Financing Act (Wwft). If a business itself trades in crypto, receives payments in crypto, or holds crypto for third parties, the bank must factor this into the customer's risk classification. This often leads to a separate question in the questionnaire, separate from the ordinary questions about a vállalkozás vagyonának eredete.

What matters is the distinction between three situations: the business itself trades in crypto as part of its operations, the business accepts crypto as a payment method from customers, or there is no crypto activity whatsoever. For each of these situations, a different answer is correct — entering "no" because it is not a core activity, while invoicing in crypto does occur occasionally, is incomplete. If the business has no documentation or policy on crypto because the subject never came up, then "no, not applicable" is the factually correct answer — not something that needs to be supplemented with an explanation that does not exist. Evidence that the bank may request in this regard is a crypto policy, an overview of wallet addresses, or a statement from the exchange platforms used; without such a document in the file, the system cannot suggest a "yes" here.

Origin from the Wwft, not from the CSRD

This question comes from the client due diligence of the Wwft, not from sustainability reporting under the CSRD (Directive 2022/2464) — these two are sometimes accidentally mixed in questionnaires, but the crypto question belongs to the former. It usually stands apart from questions about a vállalkozás végső tulajdonosai, even if the bank places them in the same section.