An account stops working. Sometimes there is a letter; often there is only a declined transaction and a branch manager who cannot say why.

The first task is always the same: establish who froze it and under what power, because the route out is entirely different in each case, and applying to the wrong forum wastes the weeks that matter.

Who can freeze what

The bank itself, under its own AML monitoring and account terms — where activity is unusual, documentation is outstanding, or a name matches a screening list. Often the account is not "frozen" by anyone external at all; the bank has restricted it.

The FIA, in the course of an investigation, typically where funds are said to be the proceeds of an offence — commonly online fraud, where a victim's money passed through the account.

The State Bank framework and AML machinery, including where a suspicious transaction report has been made.

NAB, in corruption matters, with powers over property and accounts.

FBR, recovering tax demands by attachment of bank accounts and other property.

The courts, by attachment before judgment or in execution of a decree, at the instance of a private litigant.

Sanctions and proscription listings under the anti-terrorism framework and the United Nations Security Council resolutions, applied by financial institutions through screening. Name-match cases — where an ordinary customer shares a name with a listed person — are common and are resolved by identification evidence rather than litigation.

Customs and other authorities over specific goods and securities.

Step one: find out which

Ask the bank, in writing, for the reason and the authority. Banks are frequently reluctant, but a written request creates a record and often produces an answer.

The answer determines everything. Applying to a court to release an account that FBR has attached for an unpaid demand, or negotiating with the bank over a freeze imposed by an investigating agency, achieves nothing but delay.

Route out: bank-imposed restriction

Usually the easiest to resolve, and the most common.

Provide what the bank actually needs: updated KYC, source of funds documentation, invoices and contracts supporting the transactions, and an explanation of the pattern that flagged. Do this in writing, with documents attached, addressed to the compliance function rather than only the branch.

If the bank does not resolve it, escalate through its grievance process and then to the Banking Mohtasib, which is free and effective for service failures.

Do not simply open an account elsewhere and continue. The pattern is visible, and it makes the next enquiry worse. See a frozen bank account and AML compliance for smaller businesses.

Route out: investigating agency

Where an agency has caused the freeze, the position is more serious and time matters.

  • Establish the case — which complaint, which provisions, and whether you are a suspect or a downstream account holder
  • Provide a documented source of funds and the commercial explanation for the transactions in question
  • Where funds genuinely arrived from a fraud victim without your knowledge — the classic P2P crypto or online sale scenario — say so early and evidence the underlying trade. See cryptocurrency and digital assets
  • Apply to the relevant forum for release, and press for the freeze to be confined to the disputed amount rather than the whole balance. That narrowing is often achievable and keeps a business alive
  • Deal with any criminal exposure in parallel, including pre-arrest bail where the risk warrants it

See an FIA notice and how the agency works, reporting online fraud and cybercrime and bail after arrest.

Route out: money laundering proceedings

Where the freeze is connected to proceedings under the anti-money-laundering framework, attachment and confiscation of property have their own statutory process — notice, adjudication, and an appeal route.

This is a specialist area and the deadlines are unforgiving. See money laundering references and defence and benami transactions.

Route out: tax attachment

FBR recovery by attachment follows an assessment or a demand, and the answer is usually to attack the underlying position rather than the attachment.

Practically: check whether the demand was validly served, whether an appeal is pending, and whether a stay has been or can be obtained. Recovery is frequently pursued while an appeal is undecided, and a stay application is the immediate priority.

See FBR audit notices, withholding tax obligations and customs valuation and duty demands.

Route out: court attachment by a private party

Where a litigant has obtained attachment before judgment or in execution:

  • Challenge whether the grounds were made out — attachment before judgment requires more than an assertion that the defendant might dispose of assets
  • Offer alternative security so the business can continue
  • Where the attached property belongs to someone else, that person files an objection application
  • Where the decree or order was obtained ex parte without proper service, apply to set it aside — and note the short deadline

See stay orders and injunctions, recovering money owed and limitation and the deadlines that end claims.

While the freeze is in place

Practical survival matters:

  • Apply for release of specific amounts for salaries, statutory dues and essential operations. This is frequently granted and rarely asked for
  • Keep paying employees if at all possible — employee claims add a second front
  • Tell banks and lenders before they find out; a defaulted facility compounds the problem. See defending a bank recovery suit
  • Do not move assets around. Transfers made after a freeze, or in anticipation of one, are examined and can create fresh allegations

For overseas Pakistanis

Accounts of non-residents are frozen with some regularity — dormancy, incomplete documentation, remittances that do not match the declared profile, or a name match on a screening list.

Most of these resolve with documentation and can be handled from abroad through counsel here under a power of attorney. What does not work is ignoring it until the next visit. See powers of attorney from abroad and overseas Pakistanis investing in Pakistan.

How the firm can help

We establish quickly who has frozen what and under which power, prepare source of funds documentation that satisfies compliance functions, apply for release or for narrowing of a freeze to a disputed amount, defend the underlying proceedings — criminal, AML, tax or civil — and obtain interim relief so a business can keep operating.

See banking and finance, or contact the firm with whatever the bank has told you in writing.