Compliance reviews, AML holds, and OFAC screenings can freeze your fiat and crypto balances for weeks. Use this playbook to document legitimate source-of-funds, push for timelines, and escalate when a review drags on.
Common Freeze Triggers
Trigger
Exchange Action
Resolution Window
Large inbound transfer from new wallet
Hold pending source-of-funds interview
3-14 days if documents provided
Rapid in-and-out transfers
Flagged for layering/mixing risk
7-30 days, sometimes permanent closure
Link to sanctioned address
Freeze or block until OFAC guidance
Indefinite unless license granted
Chargeback or scam victim report
Hold fiat balances pending investigation
Varies; often 30-60 days
KYC mismatch or expired ID
Account locked until documents updated
24-72 hours once ID verified
Why demand letters matter
Escalate beyond front-line support to legal/compliance teams.
Document cooperation and show that funds are legitimate.
Create record for regulators if the freeze violates policies.
Realistic expectations
OFAC or law-enforcement holds cannot be overridden by a demand letter.
Compliance teams can release funds once risk questions are answered.
Letters can secure partial withdrawals or timelines when reviews drag on.
Do not ask the exchange to violate AML obligations. Focus on transparency, documentation, and timelines instead of demanding immediate release without review.
Regulatory & Contract Framework
AML / BSA
U.S. exchanges operate as money services businesses under the Bank Secrecy Act. They must monitor transactions, file Suspicious Activity Reports (SARs), and sometimes hold funds while reviews occur.
FinCEN guidance on convertible virtual currency lists red flags such as mixers, darknet markets, and rapid movement through new accounts.
Sanctions (OFAC)
If funds are linked to sanctioned persons or jurisdictions, exchanges must block the property and report to OFAC within ten business days. Releases require OFAC authorization.
Demand letters can still request clarity: Is this a blocking obligation or an internal risk hold?
Exchange Agreements
User agreements reserve broad rights to suspend or close accounts. Highlight conflicting sections that promise timely communication or withdrawal rights.
Most agreements require arbitration. Demand letters preserve the record and can lead to negotiated releases before arbitration is filed.
Consumer protection overlay: Regulators scrutinize fintechs that freeze funds for months without explanation. Pointing to state UDAP standards and CFPB/FTC expectations on communication often moves compliance teams.
Documentation Checklist
Account History
Account opening date, KYC level, jurisdiction.
Past volume, average balances, trading pairs used.
Prior compliance reviews or tickets.
Source of Funds
Bank statements showing fiat deposits.
On-chain explorers linking deposits to regulated exchanges.
Invoices, payroll statements, or sale agreements for larger inflows.
Communication Trail
Support ticket numbers, email threads, chatbot transcripts.
Requests for documents and proof of your responses.
Any statements that funds would be released by a certain date.
Partner Bank Considerations
If fiat balances sit with a partner bank, note the bank's identity. Some disputes fall under banking regulators or the CFPB.
Gather account and routing numbers, statements, and any FDIC references the exchange used in marketing.
Letter Strategy
Tone & Objectives
Emphasize cooperation: "I am providing the following documents and request an updated review timeline."
Ask whether the freeze stems from sanctions, SAR obligations, or internal policy.
Request partial releases if certain assets are clearly unrelated to the flagged activity.
Document hardship (payroll, tax payments) without accusing the exchange of wrongdoing.
Key Sections
Background: Account age, verification level, transaction history.
Freeze timeline: Dates of deposits, restriction notices, and support contacts.
Compliance acknowledgment: Recognize AML/BSA duties while requesting clarity.
Specific requests: Determination letter, release timeline, partial withdrawals, escalation contact.
Escalation notice: Potential arbitration, regulator complaints, or legal claims for breach of contract/unfair practices if no response.
Law-enforcement holds: If the exchange states that law enforcement requested the freeze, ask for contact information and case number. They may only release funds when authorities permit it.
Sample Crypto Freeze Demand Letter
[Date]
Compliance Department
[Exchange Name]
Re: Account #[ID] / Frozen balances totaling $[Amount]
I am counsel for [Customer], an account holder since [Year] who completed Level [KYC] verification. On [Date] you restricted trading, withdrawals, and fiat transfers, citing "compliance review" ticket #[Ticket]. Our client promptly supplied requested documents on [Dates] (government ID, bank statements, purchase agreements) but has received no timeline for release.
Our review of the account shows:
• Deposits originated from [Bank/Exchange], a regulated financial institution.
• On-chain analysis confirms funds came from wallets controlled by [Customer], not mixers or sanctioned addresses.
• No law-enforcement notice or subpoena has been provided.
My client respects your obligations under the Bank Secrecy Act, FinCEN guidance, and OFAC regulations. This letter requests clarification on whether the freeze is a sanctions block, SAR-related hold, or discretionary account closure, and asks that you release or allow staged withdrawals of funds not subject to a blocking requirement.
Unless you identify a legal prohibition, please within seven (7) days:
1. Provide a written explanation referencing the applicable section of the User Agreement and compliance policy;
2. Confirm whether any portion of the funds are held due to an OFAC block or law-enforcement directive;
3. Schedule a release of eligible fiat and crypto balances or provide a concrete timeline for review completion.
If no response is received, I will pursue remedies for breach of contract and unfair practices, and elevate the matter to the relevant financial regulators. Contact owner@terms.law to coordinate. My client remains ready to supply any additional documentation you require.
Sincerely,
Sergei Tokmakov
Attorney for [Customer]
Yes, but keep it factual: identify the agency with jurisdiction (state banking department, CFPB for partner banks, or state AG for unfair practices) without threatening criminal charges.
Most exchange agreements disclaim consequential damages. Focus on releasing funds; damages claims are difficult unless you can prove breach of specific contractual promises.
Attorney Services & Contact
Frozen Exchange Account Advocacy
I represent traders, startups, and funds dealing with prolonged crypto exchange freezes, fiat holds, and compliance reviews.
Email owner@terms.law or use Calendly for a paid strategy session.