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Banking and source of funds

The rules behind your bank's questions, and the records that answer them.

Education onlyUK and USChecked 1 Nov 2026

Last checked 1 November 2026. Banks set their own policies within the law. What a particular bank asks for, or whether it will deal with crypto firms, is up to that bank. If anything here conflicts with the linked source, the source wins.

A company that buys or sells bitcoin moves money between its bank and an exchange or broker. Banks are required to know their customers, and may ask where money came from. This page sets out the rules behind those questions and the records that help answer them.

United KingdomGo to United States

UK: why the bank asks

Under regulation 28 of the Money Laundering Regulations 2017, banks and other regulated firms must carry out customer due diligence on a company, including identifying its beneficial owners. UK cryptoasset exchanges and custodians must be registered with the FCA for anti money laundering purposes. The FCA says that registration is for money laundering supervision, and that consumers do not get Financial Ombudsman Service or FSCS protection from it.

Source: legislation.gov.uk: Money Laundering Regulations 2017, regulation 28: customer due diligence for companies, FCA: Cryptoassets: AML and CTF regime (registration, no FSCS or Ombudsman cover).

Before sending money, check the firm on the FCA register. Some banks restrict payments to crypto firms; UK Finance described banks' approach in a letter to an all party parliamentary group in October 2026. For a provider and banking review ahead of the new UK regime, see UK crypto regime from October 2027.

Source: FCA: Financial Services Register: check a firm, UK Finance: Letter to the APPG on Crypto and Digital Assets on access to banking, 5 October 2026 (PDF).

US: why the bank asks

Under 31 CFR 1010.230, banks must identify and verify the beneficial owners of legal entity customers when an account is opened. In 2025, the OCC, the FDIC and the Federal Reserve each issued statements on banks' crypto related activities, and the FDIC said its banks no longer need prior approval for permissible crypto related activities.

Source: eCFR: 31 CFR 1010.230: beneficial ownership requirements for legal entity customers, OCC: Interpretive Letter 1183 on bank crypto activities, 7 March 2025, FDIC: FIL-7-2025: process for banks to engage in crypto related activities, 28 March 2025, Federal Reserve Board: Withdrawal of guidance on crypto asset and dollar token activities, 24 April 2025.

Both countries

A source of funds pack

A short, tidy file answers most questions quickly. It also helps when selling bitcoin back to the bank account. Include how the purchase was funded, whether from retained profits, a share issue or a director or shareholder loan. See funding a company bitcoin purchase.

RecordWhy it helps
Board minute and treasury policyShows the purchase was approved and is within limits.
How the purchase was fundedThe bank trail for retained profits, share allotment records, or the director or shareholder loan account.
Bank statements for each payment to the exchangeLinks company money to each purchase.
Exchange statements and trade confirmationsShows what was bought, when and at what price.
Withdrawal records with transaction IDsLinks the exchange to the company's own multisig wallet.
Wallet export or watch-only viewShows the bitcoin stayed in company control until sold.
Sale confirmation and the return transferLinks the sale back to the company bank account.

Our judgement, not a rule: telling the bank in advance about a planned purchase or sale, with the minute, can avoid a payment being held for checks. Whether to do so is for the company to decide.

Read next

Sources

Primary sources only. Each link was checked on 1 November 2026. Rules change, so confirm the current version with your adviser.

  1. legislation.gov.ukMoney Laundering Regulations 2017, regulation 28: customer due diligence for companies
  2. FCACryptoassets: AML and CTF regime (registration, no FSCS or Ombudsman cover)
  3. FCAFinancial Services Register: check a firm
  4. UK FinanceLetter to the APPG on Crypto and Digital Assets on access to banking, 5 October 2026 (PDF)
  5. eCFR31 CFR 1010.230: beneficial ownership requirements for legal entity customers
  6. OCCInterpretive Letter 1183 on bank crypto activities, 7 March 2025
  7. FDICFIL-7-2025: process for banks to engage in crypto related activities, 28 March 2025
  8. Federal Reserve BoardWithdrawal of guidance on crypto asset and dollar token activities, 24 April 2025
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Education, not advice.

This is general information and education only. It is not financial, investment, tax, accounting, legal or regulatory advice, and it is not a recommendation to buy, sell or hold bitcoin or any other asset. It does not take account of your circumstances or those of your company. You must obtain your own official professional advice to confirm this information is correct before acting on it.

Rules change. This information is correct to our understanding at the last-reviewed date, but it may be incomplete or out of date, and official sources take precedence. Bitcoin is volatile. A company that buys it could lose some or all of the money it puts in.

Using this site does not create an adviser or client relationship. IoT Financial is not authorised or regulated by the Financial Conduct Authority (FCA) and is not registered with the US Securities and Exchange Commission (SEC) as an investment adviser. Read the full disclaimer.