115-FZ and P2P USDT: why banks block cards after crypto trades
A plain-language explanation of why banks block cards after P2P USDT exchange, how 115-FZ and 161-FZ work, and what to do before and after a block.
A scenario familiar to thousands of freelancers and P2P traders in the CIS: you receive USDT for work, exchange it via P2P for rubles — and a day or two later the bank blocks your card, demanding "proof of source of funds." Let's walk through the causes and how to protect yourself.
What is 115-FZ in plain language
115-FZ ("On combating money laundering") is a Russian federal law requiring banks to monitor client transactions for suspicious patterns. The bank doesn't need to prove money laundering — it only needs to suspect, and may freeze operations pending clarification.
The key point: the bank is accountable to the Central Bank for not allowing suspicious transactions. So it errs on the side of caution and blocks preventively, especially for typical P2P patterns.
115-FZ is not a verdict. A block is a suspicion, not an accusation. In most cases the card can be unblocked by providing source-of-funds documentation.
Why P2P USDT becomes a target
Banks flag several "red flags" typical of P2P USDT exchange:
- Many small transactions from different individuals within a short window (typical P2P churn pattern).
- Off-hours transactions (nights, weekends).
- Transfers from "drop" accounts (multiple card accounts, recent registration).
- Amounts just below reporting thresholds (199,000 ₽ instead of 200,000 ₽ — threshold evasion).
Rosfinmonitoring algorithms flag these patterns automatically. Since June 1, 2025, Rosfinmonitoring may suspend operations for 10 days under 115-FZ — a new provision.
The scale of the problem
Russia is the largest crypto market in Europe: $376B/year in on-chain volume. The P2P segment is a major part — banks know this well.
What is 161-FZ and how does it differ
More about 161-FZ
161-FZ ("On the national payment system") is a separate law that banks often apply alongside 115-FZ. While 115-FZ requires you to justify the source of funds, 161-FZ lets the bank refuse service without explaining reasons — only notifying the client.
In practice: first a 115-FZ block (with a document request), then, if the bank is unsatisfied, contract termination under 161-FZ. Different legal grounds, but often used together.
How to protect yourself BEFORE a block
1. Check the counterparty before the trade
The core AML rule: incoming funds must not be "dirty." If you receive rubles from a wallet linked to drug trafficking or a scam, the block is inevitable — even if you knew nothing.
Before a large trade, check the counterparty's crypto address via an AML checker. VerifAML screens 20 chains (including Tron/USDT — the primary P2P asset) across many sources — sanctions lists, reputational databases, EVM address labels and others, and the database keeps expanding.
2. Don't split transactions
Transactions of 95,000 ₽ instead of 200,000 ₽ are a clear signal to the bank. Splitting is explicitly mentioned in Rosfinmonitoring guidelines as a typical laundering indicator.
3. Document the source
Save P2P chats, order screenshots, freelancer contracts. When the bank requests — you must respond within a short window (usually 7 days).
What to do AFTER a block
- Don't panic and don't close the card yourself. Request the bank's written grounds for the block.
- Gather documents proving source of funds: exchange statements, P2P platform records, client contracts.
- Submit the response via online banking (115-FZ forms). In writing, not by phone.
- If refused — file a complaint with the Central Bank via the online reception. This often works.
- If closed under 161-FZ — you have the right to transfer the balance to another bank within 7 days.
VerifAML won't fix a block retroactively. But regular screening of incoming P2P payments reduces the chance of receiving "dirty" rubles from a flagged wallet. One 30-second AML check saves weeks of disputes.
Related materials
- How to check USDT on Tron before a P2P trade — step-by-step guide
- What is risk score 0–100% and how to read the report
- Garantex: what it is and why it's sanctioned
VerifAML is an informational service. This article is not legal advice. For specific legal situations, consult a lawyer.