Your neobank might be based in a country you've never visited — and that's exactly where your complaint needs to go if direct contact with the company gets you nowhere.
Why Automated Freezes Are So Hard to Escalate
A common and genuinely frustrating pattern with European neobanks and fintechs: an internal security or AML algorithm flags an account and freezes it, but the front-line customer support team — often chat-only, sometimes without a direct phone line — has no visibility into the actual review and can't provide a timeline or explanation. This isn't necessarily bad faith; it often reflects how compliance workflows are genuinely structured at digital-first banks, where the compliance team operates separately from customer-facing support and doesn't communicate directly with customers during an open review.
The Passporting Complication: Who Actually Regulates Your Neobank
This is the detail that trips people up most: under the EU's single-market passporting framework, a fintech authorized in one member state can operate across the entire EU using that one authorization, under "home country control" — meaning the regulator with actual supervisory authority is the one in the company's home member state, not necessarily the regulator in the country where you personally live or bank.
A German user of a fintech licensed in Lithuania, for example, generally needs to direct a formal regulatory complaint to the Lithuanian authority (or the specific home-country regulator the firm is actually licensed under), not to BaFin — BaFin's role in that scenario is typically limited to cooperating with the home regulator, not directly supervising the firm's conduct. Before filing anywhere, confirm your specific provider's home member state and authorizing regulator — this information is generally required to be disclosed in the firm's terms of service or on its website.
Escalation Path
- Written complaint to the fintech directly, addressed to its compliance department specifically rather than general support, requesting the specific reason for the restriction and an expected resolution timeframe.
- If unresolved, complain to the firm's home-country financial regulator — identify this correctly first, since filing with the wrong country's regulator will simply be redirected or ignored.
- Consider your national financial ombudsman as an alternative or parallel route, particularly for individual dispute resolution rather than broader regulatory enforcement.
Your balance itself remains your property throughout this process — a freeze or extended review is not the same as forfeiture, though the practical difficulty is the same regardless: getting a clear timeline and actual resolution.
What This Means for You
Before assuming your own country's central bank or regulator is the right complaint destination, confirm where your specific fintech is actually authorized — this single step avoids weeks of a complaint sitting with an agency that has no jurisdiction over the firm. Generate a formal written request to the compliance team as your first step, and keep a dated record of every communication.
Related Kibbo Tools
- Exchange Account Freeze/Lockout Response Letter →
- Frozen Account Response Checklist →
- Crypto Regulators (Directory) →
Sources
- European Banking Authority — passporting and home/host supervision framework. eba.europa.eu