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Unblocking an account with a bank or payment system

Updated: November 2026
 
An account has been blocked, an incoming payment has not been credited, and the bank or payment system says nothing beyond a standard reply from customer support. The cause is most often a financial monitoring review. Funds can be unblocked by establishing what stage the review has reached and giving the compliance team the specific explanations and documents it expects. In harder cases, a complaint to the regulator or a court claim is needed.
 
Why accounts are blocked
Banks and payment systems must review their clients’ transactions under anti-money laundering rules. In Ukraine, these are set by the Law of Ukraine “On Prevention and Counteraction to Legalisation (Laundering) of the Proceeds of Crime, Financing of Terrorism and Financing of Proliferation of Weapons of Mass Destruction” (in Ukrainian). The EU and the United Kingdom have their own rules built on the same standards.
 
Accounts are most often blocked because of:
  • an incoming payment of an amount unusual for the client;
  • a payment from a new counterparty or a high-risk country;
  • an incomplete or inconsistent reply to a source of funds request;
  • outdated client data that was not updated on request;
  • a match between the name of the client or counterparty and a sanctions list.
Ukraine
In a Ukrainian bank, a block usually starts with a request about the source of funds. How to reply is described in Bank request about the source of funds: how to reply (in Ukrainian).
 
If the account stays blocked after the reply, you need to establish who restricted the transactions and on what grounds.
 
There are three possible situations:
  • The bank has stopped the transaction and reported it to the State Financial Monitoring Service. The suspension is limited in time: even where there is a reasoned suspicion, it cannot exceed 30 working days in total. If that period has expired and there is no court seizure order, the bank must resume the transactions.
  • The bank has refused to serve the client or closed the account. Such a refusal must rest on grounds set out in the law. It can be challenged by a written complaint to the bank, a complaint to the National Bank of Ukraine as the regulator, or a court claim.
  • The funds have been seized in criminal proceedings. The matter is then no longer for the bank to decide: it is the investigating judge’s order under the Criminal Procedure Code of Ukraine (in Ukrainian) that must be challenged.
Payment systems and banks in the EU and the United Kingdom
Many payment systems used by Ukrainian clients hold a licence in one EU member state and use it to serve clients across the European Economic Area. Some have a separate company for clients in the United Kingdom. So first establish which company holds the account and who its regulator is. This is stated in the agreement or terms of service, and it determines where to complain.
 
A block in a payment system usually works like this. The compliance team stops an incoming payment or the whole account and asks for documents through the app or by email. The reply comes from compliance, not customer support, and often without reasons.
 
So it is important to:
  • reply in writing and keep all correspondence;
  • send all documents in one reply rather than in parts. Each new request delays the review;
  • explain the transaction in full: who the payer is, why the funds were paid, and where the payer’s money came from;
  • attach English translations of any documents drawn up in Ukrainian.
If compliance does not reply or refuses, the next step is a formal complaint to the company itself. In EU member states, a payment institution usually has to answer a complaint within 15 business days, and the period may be extended in exceptional cases. If the answer is unsatisfactory, a consumer may apply to the out-of-court dispute resolution body in the country where the company is licensed, most often the central bank or a financial ombudsman. Such review is usually free of charge, and the right to go to court remains.
 
In the United Kingdom, the firm must give a final response to the complaint. The client then has six months to refer it to the Financial Ombudsman Service, which handles complaints from individuals, micro-enterprises and small businesses.
 
From the firm’s practice
The firm helped clients unblock 200 000.00 EUR in the Revolut payment system and unblock funds in the Paysera payment system. In both cases, the payment system blocked an incoming payment and asked for an explanation of the source of funds. We prepared the explanation and the set of documents, handled the correspondence with the compliance team, and the funds were released without going to court.
 
Our services
  • establishing the reason for and the basis of the account block;
  • preparing explanations and documents on the source of funds for the bank or payment system;
  • correspondence with the compliance team, including in English;
  • complaints to the bank, the National Bank of Ukraine and foreign regulators;
  • claims against banks for unjustified account blocks or refusal of service;
  • challenging seizure of funds in criminal proceedings.