The report examines a difficult question in crypto-asset compliance: how to distinguish a lawful refusal of financial services from an unjustified restriction imposed on a customer whose legal status raises additional concerns. “Disputed status” may encompass very different situations, including a sanctions name match, foreign criminal proceedings, an INTERPOL notice, PEP status, an asylum procedure, a corporate dispute, questions about the source of funds, or inaccurate information in a commercial database. The report’s central argument is that these circumstances should not be collapsed into a single category of “high risk”; each requires its own legal classification and evidential assessment.

Particular attention is given to the limits of MiCA. While MiCA imposes obligations on authorised crypto-asset service providers concerning organisation, client treatment, safeguarding and complaints, it does not create an unconditional entitlement to crypto services. MiCA also operates alongside AML/CFT requirements, sanctions regimes, transfer-information rules and the GDPR. The analysis covers sanctions screening, restrictions affecting Russian nationals and residence-based exemptions, documents relating to international protection, INTERPOL data, source-of-funds verification, self-hosted addresses, blockchain analytics and automated risk assessment.

The practical sections set out a structured approach to reviewing restrictions. The provider and service must first be identified, followed by the actual reason for the restriction. A mandatory legal prohibition must then be distinguished from manageable risk, evidential uncertainty or corporate policy. Customer evidence should be assessed against the specific issue it is intended to resolve, and significant new information should lead to a meaningful review. The report also addresses the lawful return of assets after termination, correction of inaccurate data, genuine human involvement in automated decision-making and the selection of the appropriate complaint or supervisory route.

ARGA’s position combines effective sanctions and AML/CFT compliance with individual assessment and meaningful correction of errors. Financial access does not create a right to demand a prohibited transaction, but a complex customer profile should not automatically be treated as evidence that assets are unlawfully derived. The resulting model is designed to distinguish mandatory restrictions from errors, evidential gaps, unmanageable risks and commercial decisions, while providing a defined process for reviewing each of them.