01
Source of Funds
The origin of the funds had to be demonstrated, not only described.
Medici Expert Cases
From Frozen Funds to Release: Rebuilding a Bank Compliance Case
The client had legitimate funds and proper accounting. The bank still froze the account. We rebuilt the compliance case around what the bank needed to verify, and the funds were released.
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Case
at a Glance
Situation:
Funds frozen following a bank compliance review
Challenge:
A legitimate source of funds, supported by documents that did not let the bank close its review
Scope:
- Transaction review
- Source of funds
- Compliance documentation
- Direct communication with the bank
Outcome:
- Funds released
- New banking relationship established
Context
The client could explain the funds. The bank needed to verify them.
The client ran a real business, kept proper accounts and held documents behind every incoming payment.
After a compliance review, the bank restricted the account. The client answered the questions, more than once. Each answer added documents, but not a picture the compliance officer could follow and sign off.
A compliance officer cannot release funds on a reasonable impression. They need an evidence trail they can defend to an auditor later. Medici was brought in to find what was missing from that trail and rebuild the case around it.
The Challenge
A bank asks where the money came from. It also asks whether everything else supports that answer.
01
Transaction History
The movement of money had to match the client's explanation and actual business activity.
01
Documentation
The accounting was sound, but it was not organised around the questions compliance was asking.
01
Previous Communication
Every earlier reply was already part of the bank's file. The rebuilt case had to stay consistent with all of it.
01
The challenge
The evidence existed. It did not yet form one consistent case.
From Freeze to Release
01
Reconstruct the Case
We reviewed the compliance request, earlier correspondence, transaction history and documents to identify what had triggered the bank's concern.
02
Identify the Gaps
We established what the bank still needed to verify, and where documents were missing or in the wrong format.
03
Rebuild the Evidence
Source of funds, transactions, business activity and accounting records were connected into one evidence package.
04
Address the Bank's Requirements
We structured the response around the bank's specific questions and supported the client through follow-up rounds.
05
Resolve the Case
The bank completed its review and released the funds.
What Made the Case Difficult
Compliance was not looking for one document. It was looking for consistency
01
Source of Funds
Where did the money originate?
01
Transaction History
Does the actual movement of funds support that explanation?
01
Business Activity
Do the transactions make sense for what the client does?
01
Supporting Evidence
Can each step be checked against statements, agreements, invoices and accounts?
Medici Approach
We started with what the bank still needed to prove.
01
We worked backwards from the compliance concern.
The bank's questions determined which evidence was relevant and what had to be demonstrated.
02
We connected documents to transactions.
Source of funds, accounting and the actual movement of money had to support the same explanation.
03
We rebuilt the compliance package.
Existing material was restructured and supplemented to answer the bank directly.
04
We stayed involved until resolution.
Follow-up questions are a normal part of the process. We handled them until the review was closed.
05
We only build cases around verifiable facts
There is a clear limit to this work. We only build a case around facts that can be legitimately supported. If a transaction history cannot be reconciled with a lawful, verifiable source of funds, we say so.
Having legitimate funds is only part of the equation. Compliance needs to be able to verify the story behind them — through the transactions, documents and actual business activity. The strongest cases are the ones where all three tell the same story.
The Outcome
The bank completed the review. The funds were released.
01
Funds Released
The client regained access to the funds once the bank's requirements were addressed.
02
A Consistent Evidence Trail
Transactions, business activity and documents now form one verifiable record, ready for the next bank or partner review.
03
New Banking Relationship
We also supported the client in opening a new account. It was opened in 4 days.*
*Timelines and outcomes depend on the circumstances of each case and the decision of the relevant bank, exchange or financial institution.
04
Funds Recovered. Banking Restored. Operations Continued.
The client did not only receive a better response to compliance. They regained control of the funds and had banking in place to continue operating.
Facing a Similar Review?
A freeze does not automatically mean the funds are the problem. Before responding again, three questions matter.
01
What exactly is compliance trying to verify?
Additional documents will not help if they do not address the actual concern.
01
Can the full movement of funds be explained and evidenced?
Your explanation should match the transactions, agreements, statements and accounts.
01
Does everything tell the same story?
Compliance compares what you say with what the records show. Any gap reads as risk.
Facing a Similar Compliance Review?
If a bank or exchange has frozen your funds or requested additional evidence, send us the request and a short description of what happened. We will review the case, identify what still needs to be demonstrated, and tell you whether there is a legitimate path forward.
Discuss Your Case