When compliance becomes a tool of repression.

For most people, debanking is a policy debate. For her, it arrived one morning in 2018.

"It started with letters from banks with no explanation, or with 'compliance reasons.' Sometimes not even a letter, just a transfer that did not go through."

Her organization's banking contracts were terminated one after another. The last Belgian account went, she says, over humanitarian fundraising for Ukraine, because a compliance system flagged Ukraine as a grey zone. There was no court decision, no accusation she could answer, and no one to appeal to.

Day to day, that meant the team could not be paid, grants donors had already approved could not be received, and an office could not be rented.

"Instead of human rights work, we spend our time writing to banks, regulators and lawyers. Partners step back because being associated with us becomes a compliance risk for them too."

Debanking is only the moment

She is precise about why the ordinary word is not enough.

"Debanking is the moment when your account is closed. Transnational financial repression is the whole machine behind it."

An authoritarian government, she explains, can use Western rules and institutions against its opponents abroad: international anti money laundering standards, INTERPOL tools, legal assistance requests between states, the Schengen Information System. Banks, payment platforms and regulators in Europe and the US then do the work for the regime, often without knowing it.

And it reaches further than activists. Banks, real estate agencies and other businesses screen every client against compliance databases, increasingly scored by AI systems that nobody inside the bank can explain. A smear campaign feeds those databases, and the output becomes a risk score.

"Winning in court does not fix the score, and the cost of producing the input is now close to zero: AI written articles, sponsored opinion pieces, anonymous websites."

The regime does not need to break into the system. It only needs to feed it.

When the rules are turned around

One of her talks is titled "When Compliance Becomes a Tool of Repression," and she makes the case from her own experience.

In 2022, a criminal complaint was filed against her and the Open Dialogue Foundation in Belgium, and under the pretext of suspicious financial activity it sought her passport, travel records, border crossings, hotel bills and bank movements. The Belgian investigating judge refused, finding the requests were designed to collect the maximum amount of personal data for purposes other than establishing the truth. The prosecution was declared inadmissible in 2024, confirmed on appeal in 2025, and costs were awarded against the complainants.

"The customer due diligence rules written to catch corrupt officials were invoked by corrupt officials against the person who exposed them."

The asymmetry is what she wants people to see. When a request comes from an authoritarian state, it gets executed. When a European court orders that state's agents to pay, nothing is enforced.

"The system is built to comply with and trust state requests. Until it includes a presumption of abuse for requests from perpetrator states, verification before accounts are frozen, and limits on data sharing, the compliance officer is the last link in a chain that starts somewhere else."

The bank of last resort

The industry mostly defends Bitcoin as an investment. She defends it as infrastructure for people who have been cut off.

"It makes possible the one thing every debanked person needs first: to receive money, hold it and send it without asking for permission."

When Russia launched its full scale invasion of Ukraine in February 2022, major payment platforms suspended her organization's accounts along with many other Ukrainian volunteer accounts, and banks could neither send nor receive payments to Ukraine for months. Using Bitcoin and stablecoins, her team delivered humanitarian aid on the second day of the invasion, and has since provided Ukrainian refugees and the military with support worth over €9 million.

Through the coalition she founded, she has documented human rights leaders from Russia, Belarus, Kazakhstan, Afghanistan and Venezuela who rely on it the same way: to pay a lawyer, feed a family or deliver medicine when every other channel is closed.

A self hosted wallet has no compliance department.

Her concern is where regulation is heading. Rules that classify privacy tools as a money laundering risk push every transaction back through an exchange, where every problem she describes returns.

A standard, not yet a remedy

In June and July 2026, the European Parliament, the Parliamentary Assembly of the Council of Europe and the OSCE Parliamentary Assembly adopted texts recognizing transnational financial repression as a distinct threat. For the first time, donors, business people, lawyers and diaspora communities were named as victims, and regulators were told that compliance can be misused as a tool of repression.

"The OSCE Parliamentary Assembly also called for neutral language towards privacy tools. That language did not exist a year ago."

She is equally clear about what has not changed.

"Nobody who lost accounts got them back. There is no complaint mechanism, no compensation, no supervisor responsible when a bank acts on a foreign request. With the resolutions we achieved the standard, but we still need to do the work to enforce it."

Do not wait to be invited

For a woman with expertise in this area who has not yet put herself forward:

"Do not wait to be invited. Nobody had answers when our accounts were closed: not lawyers, not regulators, not banks. We had to find them ourselves. Most of what I know about these rules I learned because I had no choice."

"Your story and specific experience are worth more than the general opinion that might question and dismiss you at the beginning. If the subject you know is being decided without you, the decision will be worse."

Lyudmyla Kozlovska speaks on transnational financial repression: the abuse of anti money laundering and counter terrorist financing rules, INTERPOL, mutual legal assistance treaties and cybersecurity frameworks by authoritarian regimes to debank, surveil and silence their critics abroad. The people on the receiving end include human rights defenders, journalists and donors, as well as serving and former officials of EU and NATO member states.

She takes on reform of those frameworks, the privacy of communication and payment including the EU's Chat Control proposal, and the case for Bitcoin and stablecoins as financial infrastructure for people shut out of the banking system. She argues it from what her own organization has lived through, from its debanking in Belgium to delivering over €9 million in humanitarian aid to Ukraine while banks and payment platforms were suspended.

Lyudmyla Kozlovska is in the Crypto Women Collective Speaker Index. The index is open and free to use, and anyone can contact her directly.

Connect with Lyudmyla on LinkedIn.