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The trade file: how traders can secure permitted trade

· Helfen statt Blockieren editorial team

Many refusals happen because a bank cannot tell quickly that a deal is permitted. Our proposal: a short file per deal, always built the same way, that makes checking easy, and a shared procedure for the cases where things still get stuck. A working draft for discussion.

The problem in two sentences

The European Banking Authority considers unwarranted de-risking a sign of poor risk management: banks refuse whole groups instead of assessing the individual customer. In the 2026 DIHK survey, 42 percent of the companies that see home-made hurdles name problems in processing their foreign business.

Both have one side in common: whoever has to check needs documents, quickly and in a form they recognise. That is where the proposal starts. It replaces no obligation and no licence; it makes existing obligations visible.

Five sheets per deal

The trade file: five sheets per deal

Each sheet answers a question that the bank, customs or an authority would otherwise ask.

1Goodstariff code, origin,control list check2Partnername, address,owners, screeningwith date3Country, useembargo? end use,Art. 12g clausewhere required4Paymentroute, currency,complete paymentreference5Evidencelicence, or whynone is needed1Goodstariff code, origin,control list check2Partnername, address,owners, screeningwith date3Country, useembargo? end use,Art. 12g clausewhere required4Paymentroute, currency,complete paymentreference5Evidencelicence, or whynone is needed

Sketch: Helfen statt Blockieren. A proposal, not legal advice.

The file is not a new official form but an order for documents that a careful trader has or should have anyway. Its value lies in uniformity: if many traders use the same sequence, banks learn to read it quickly.

A rule without exception

The payment reference is complete and true. The file is meant to make permitted deals recognisable, not to make prohibited ones invisible. It does not help, and is not meant to help, with listed persons or prohibited goods.

Talk before paying

The best time for the file is before the first payment to a new country or a new customer: a short message to the bank with the five sheets. The 2023 EBA guidelines require a bank to assess the risk of the individual customer before refusing. The file gives it the material to do so.

When it still gets stuck

When it still gets stuck

A fixed procedure instead of waiting. Red: where it usually ends without a file.

1Reasonsask in writingfor the reasonSilencerefusal withoutreason, the dealis lost2Supplysend the missingsheet of the file3Expertsask the Helpdesk,Bundesbank, BAFA,chamber4Remediesconsumers: BaFin(s. 48 ZKG);firms: other bank5Reportpass the caseanonymously to theassociation1Reasonsask in writingfor the reasonSilencerefusal withoutreason, the dealis lost2Supplysend the missingsheet of the file3Expertsask the Helpdesk,Bundesbank, BAFA,chamber4Remediesconsumers: BaFin(s. 48 ZKG);firms: other bank5Reportpass the caseanonymously to theassociation

Sketch: Helfen statt Blockieren, based on EBA (2022 and 2023), the German Payment Accounts Act, Deutsche Bundesbank and the European Commission.

Consumers have a legal remedy: anyone legally resident in the EU is entitled to a basic account and can turn to BaFin if refused. Companies have no such entitlement. For them the path runs through talks, expert bodies and switching banks. Where a US law listed in the annex of the Blocking Statute affects a deal, the European Commission must be informed within 30 days (more on this).

Turning single cases into figures

In 2022 the EBA recommended that supervisors engage more with banks and affected customers. That requires figures. Today every trader tells their case alone. Our proposal: associations such as the chambers of commerce, the wholesale and foreign trade federation BGA or the retail federation HDE collect cases anonymously using a common grid and present a summary once a year. “Helfen statt Blockieren” provides the grid and offers to develop it further with associations.

Proposed anonymous case report
FieldContent
Date and country of the dealcountry only, no partner name
Type of goodschapter of the tariff code
Type of obstaclepayment refused, delayed, account closed, goods stopped
Whereown bank, correspondent bank, payee’s bank, customs
Reason givenverbatim, if in writing
Was there a prohibition?yes, no, unclear, with source
Outcomeresolved after how many days, or lost

Limits of the proposal

  • The file guarantees nothing. The bank still decides whom it keeps as a customer.
  • It takes time, most of all for the first deal. For follow-up deals usually only single sheets change.
  • It does little against the effect of foreign laws on banks. That is a task for policy, not for the trader.
  • The anonymous case report needs sponsors that do not exist yet. Until then it is an offer.

Feedback on this draft is welcome: info@aciel-martinez-poll.com. The path of a payment in detail is explained in “Why a permitted payment gets stuck”.

This piece is information, not legal advice. It reflects the author’s view. “Helfen statt Blockieren” is non-partisan.

Sources

All online sources accessed on 3 November 2026.

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