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Funds frozen by financial intelligence units in the EU and the UK

Updated: November 2026
 
An account at a European bank has been blocked, a payment does not go through, and the bank gives no reason or refers to a ban on disclosure. Behind this there is usually a decision of a financial intelligence unit or a prosecutor rather than of the bank itself. Time limits, the deciding body and the way to challenge the decision depend on the country, so the first step is to establish who froze the funds and on what grounds.
 
How it works in Europe
Every EU member state and the United Kingdom has a financial intelligence unit. It receives suspicious transaction reports from banks, analyses them and passes materials to law enforcement. A financial intelligence unit usually does not investigate, but it can temporarily prohibit a bank from executing a client’s transactions. A longer freeze normally requires a decision of a prosecutor or a court.
 
At present, these rules differ from country to country. The new Directive (EU) 2024/1640 is meant to bring them closer: EU member states must apply it by 10 July 2027. It expressly empowers financial intelligence units to suspend transactions for up to 10 working days and to restrict access to an account for up to 5 working days. National law may set longer periods if it provides safeguards for the owner of the funds.
 
Latvia
The Latvian Financial Intelligence Unit (Finanšu izlūkošanas dienests) first freezes funds temporarily, then may extend the freeze for a set period and pass the materials to law enforcement. If the source of the funds is not confirmed, they may be confiscated in criminal proceedings. The appeal procedure in Latvia has changed: complaints used to be heard by the prosecutor’s office, and the procedure has since been revised. The time limit and the body to appeal to must therefore be checked as at the date of the decision. The time limit is short.
 
Luxembourg
The Luxembourg financial intelligence unit (Cellule de renseignement financier) instructs the bank not to execute the client’s transactions. The law sets no time limit for such an instruction, and the unit can withdraw it at any time. The bank may not inform the client of the instruction without the unit’s consent. The instruction can be lifted through the court: a person with an interest in the funds files a request with the Chambre du Conseil of the Luxembourg District Court, and the unit must file a written justification with the court.
 
Poland
In Poland, the financial intelligence unit is the General Inspector of Financial Information (Generalny Inspektor Informacji Finansowej). It can require a bank to suspend a transaction or block an account for up to 96 hours and notifies the prosecutor. The prosecutor can extend the block by order for up to six months, and then for up to another six months. If no securing order is made in criminal proceedings within that time, the block lapses.
 
Cyprus
In Cyprus, bank reports are received and analysed by the Unit for Combating Money Laundering (MOKAS). It does not investigate and passes information to the police. A longer freeze of funds and property in Cyprus usually requires a court order, made on the application of MOKAS or the police, including at the request of foreign states. Such an order is challenged in court.
 
United Kingdom
The United Kingdom uses a different mechanism. A bank that suspects money laundering reports it to the National Crime Agency and asks for consent to proceed with the transaction. Until consent is given, the transaction is not executed. If consent is refused, a 31-day moratorium begins, which the court may extend, but by no more than 186 days in total. Law enforcement may then apply to the court for an account freezing order. The owner of the funds may oppose an extension of the moratorium and ask the court to vary or set aside the order.
 
Other EU countries
Similar mechanisms apply in other EU member states, but the bodies, time limits and appeal procedures differ from country to country. In every matter, we therefore first establish which company holds the account and where it is licensed, who made the decision, on what grounds, and whether the time limit for a challenge has expired.
 
What decides the outcome
Whichever country froze the funds, the bank, the financial intelligence unit and the court assess one thing: whether the owner can document where the money came from and what the transaction was for.
 
What matters is:
  • a complete and consistent set of documents: contracts, bank statements, financial statements and tax returns, documents on the source of wealth;
  • an explanation that matches the information previously given to the bank;
  • translation of documents into English or the language of the country and, where needed, an apostille;
  • meeting the time limits, which are short in some countries.
From the firm’s practice
We have handled a large volume of work with the financial intelligence units of Latvia and Luxembourg concerning client funds held in banks in liquidation: preparing explanations of the source of funds, supporting clients through creditor compliance reviews, and challenging freezing decisions.
 
Our services
  • identifying the body that froze the funds, the grounds and the time limit for a challenge;
  • preparing explanations and documents on the source of funds for the bank and the financial intelligence unit;
  • pre-trial challenges and correspondence with the bank, the financial intelligence unit and the prosecutor;
  • court challenges together with local counsel in Latvia, Luxembourg, Poland, Cyprus, the United Kingdom and other countries;
  • representing creditors in the liquidation of foreign banks.