P2P exchange is buying or selling cryptocurrency “person to person”: the buyer pays you to a card, and you release the tokens on the platform. A bank usually does not see the cryptocurrency itself: it sees incoming transfers from strangers and compares them with what it knows about you. That is why cards are sometimes restricted and transactions stopped. Below: what the law and the NBU allow banks to do, why P2P attracts attention, and what you can lawfully do if your card has been blocked. As of 19 October 2026.
Important. This material is for information only; it is not legal advice and not an instruction on how to “get around” monitoring. Banks are obliged to carry it out. There is only one reliable path: use your own details openly and have documents that explain the source of funds. For the legal basics in more detail, see the material How to Withdraw Crypto to a Ukrainian Bank Card.
What a Bank Can Do
| Bank action | Basis | What to know |
|---|---|---|
| Refuse a transaction | Article 44 of the Law of Ukraine “On Payment Services” No. 1591-IX | Only on lawful grounds. The bank must immediately state the reason with reference to the provisions and is liable for damage if it refused without grounds |
| Suspend a suspicious transaction | Article 23 of Law No. 361-IX | The bank has the right to suspend a suspicious transaction, and where a criminal offense is suspected it is obliged to. A suspension for two business days takes place without prior notice to the client; after that, the specially authorized body may extend it to seven business days |
| Request documents and restrict service | Part 7, Article 11 of Law No. 361-IX; the bank’s public terms (example: PrivatBank, clause 1.1.7.2) | The client must provide documents for due diligence. If they are not provided, PrivatBank’s terms provide for suspending or restricting service until they are received |
| Set limits | NBU Regulation No. 65, clause 68; the banks’ Memorandum | Banks apply limits and other tools that restrict the service. Under the Memorandum, limits are set for clients without documented income |
| Close an account | Article 15 of Law No. 361-IX | The bank must refuse a transaction or terminate the relationship if the client has not provided the required documents, poses an unacceptably high risk or has submitted false information |
Why P2P in Particular Draws a Bank’s Attention
Drops. In a material of 1 April 2025, the NBU writes about an abnormal surge in transfers between individuals’ accounts in 2024 and about the problem of “drops.” The NBU did not extend the regulatory limit of UAH 150,000 per month on outgoing P2P transfers, but banks signed a Memorandum on the Transparency of the Payment Services Market. Its signatories undertook not to set limits on transactions of clients with confirmed sources of income (salaried employees, volunteers) and to set them for clients without documented income, including on IBAN transfers.
A similar outward appearance. The NBU describes a drop as a person who receives money from another person into their own account, transfers it on or withdraws cash (NBU “Harazd”). From the bank’s side, selling cryptocurrency can look similar: funds arrive from various strangers, then go to an exchange or elsewhere. This is our explanation, not the NBU’s position, but it shows why a bank asks for explanations.
Behavior that does not fit the profile. A bank must compare transactions with what it knows about the client, their activity and risk, and, if necessary, establish the source of funds (Regulation No. 65). Under NBU Resolution No. 110 of 5 September 2023, banks must respond when a client exceeds the declared volume of transactions and to unusual activity on the account; this does not apply to individuals who regularly carry out transactions in reasonable amounts and volumes (NBU announcement). We did not find the separate words “P2P” or “cryptocurrency” in Law No. 361-IX, Regulation No. 65 or the Law “On Payment Services” (a text search on 19 October 2026).
A payment from a third party. The Binance P2P rules require the buyer to pay from an account in their own verified name and prohibit payments to a third-party account. If money came from someone else’s card, you risk receiving funds that the bank links to a fraud scheme. The NBU writes that an account used to transfer such funds is blocked. For the schemes, see the materials Cryptocurrency Fraud: 10 Schemes and Bank Card Fraud: 10 Schemes.
What to Do If Your Card Has Been Blocked or Restricted
- Find out exactly what happened. Is it a refusal of a single transaction, a suspension, a restriction of the card or of the account? Read the message in the app, call the number on the back of the card or write to the bank’s chat. Under Article 44 of the Law on Payment Services, when a bank refuses to accept a payment instruction, it must state the reason with reference to the provisions. But if financial monitoring is involved, the law prohibits the bank from informing the client about passing information to the specially authorized body (Part 10, Article 16 of Law No. 361-IX), so you may not hear the details.
- Submit documents that explain where the funds came from. Usually these are exchange statements (deposits, orders, withdrawals), the history of P2P orders, receipts, and proof of the income from which the cryptocurrency was bought. The bank decides for itself what is sufficient, so ask in writing for the list of documents and the deadline for submission.
- Respond on time and in writing. A bank’s public terms (PrivatBank’s, for example) provide for suspending service until documents are received: the longer you stay silent, the longer the restriction lasts.
- Do not hand your card and details to other people. In its recommendations to cardholders, the NBU reminds that a payment card should not be given to other persons, even relatives.
- If the bank does not respond or drags its feet, send it an official complaint, and then file a complaint with the NBU on the “Citizens’ Appeals” page: type “Complaint,” topic “Blocking of an account/individual transactions.” The NBU promises a response within 30 calendar days, and in some cases 45.
- Distinguish who made the decision. According to NBU clarifications, an attachment of funds in an account is imposed by a state or private enforcement officer, and then the bank must block debit transactions. The specially authorized body may suspend debit transactions for up to seven business days. In such cases the bank cannot lift the restriction itself: contact the body that made the decision.
How to Reduce Risks by Lawful Means
- Use only your own cards and details. Accept payment only from an account in the counterparty’s name, as the Binance P2P rules require.
- Keep the history: exchange statements and P2P orders will help explain the source of funds.
- Do not give the bank false information: under Article 15 of Law No. 361-IX this is grounds for refusal or for terminating the relationship.
- Do not mix personal money, sole proprietor (FOP) funds and crypto transactions in one account without explanations.
- Do not agree to “help” with transfers for a reward: according to an NBU material, such persons bear criminal liability for complicity (Article 209 of the Criminal Code, 3 to 12 years of imprisonment).
Risk. There is no single “safe amount”: under Article 21 of Law No. 361-IX, a transaction of any amount can be suspicious. Threshold transactions start from UAH 400,000 where there are additional features (Article 20). So do not rely on other people’s advice about “safe” limits: check the terms against the official pages and your agreement with the bank.
Frequently Asked Questions
Is P2P cryptocurrency exchange banned in Ukraine?
There is no separate law on this: the law on virtual assets No. 2074-IX had not come into force as of 19 October 2026. We did not find the words “P2P” or “cryptocurrency” in Law No. 361-IX, Regulation No. 65 or the Law on Payment Services. At the same time, a bank is obliged to carry out monitoring and may ask for documents.
How long does a block last?
It depends on the reason. Under Article 23 of Law No. 361-IX, a bank may suspend a transaction for two business days, after which the specially authorized body may extend it to seven business days. A restriction caused by documents not being provided lasts until the bank receives what it needs. An attachment lasts until the decision of the enforcement officer or the court.
Is the bank required to explain the reason?
If a bank refuses to accept a payment instruction, it must immediately state the reason with reference to the provisions (Article 44 of the Law on Payment Services). If the matter is financial monitoring, the law prohibits informing the client about passing information to the specially authorized body.
Can an account be closed?
Yes, if the client has not provided documents for due diligence, poses an unacceptably high risk or has submitted false information (Article 15 of Law No. 361-IX). The decision depends on the specific situation and the bank’s terms.
Where can I complain if the bank blocks my card without explanation?
First write to the bank, then you can file a complaint with the NBU through the “Citizens’ Appeals” form: type “Complaint,” topic “Blocking of an account/individual transactions.” The NBU promises a response within 30 calendar days, sometimes 45.
