A Blocked Account - Three Different Reasons, Three Different Routes and One Question to the Bank
A blocked account looks the same whatever the cause - the card does not work, transfers do not go through, the salary does not arrive - but there are three possible reasons: the National Bureau of Enforcement acting on a court or notary's enforceable document, the Revenue Service acting on tax arrears, or the bank itself under anti-money-laundering rules. Each has its own law, its own timeline and its own route, and the first step is always the same: ask the bank in writing who blocked the account and on what basis.
This page covers all three scenarios and, separately, the most painful case: a held incoming transfer, where the money sits at the bank, is not credited to the client and the bank asks for source of funds documents. It also covers the specifics of foreign clients and company accounts, account closure and refusal of service, the order of escalation from the bank to the National Bank, and claiming damages where the block turns out to be unjustified. Tax disputes and general enforcement rules have their own pages.
Four Grounds and What Is Done in Each
Banks often decline to explain the reason on "confidentiality" grounds - but a client is entitled to know which order or which internal procedure the restriction rests on.
Unblocking the Account - From the First Question to a Damages Claim
Establishing the ground in writing
A written question to the bank: who blocked the account (the Bureau, the Revenue Service, a court or the bank), on the basis of which document, for what amount and for how long. The bank must reply to a customer's written approach within the set period - and that reply determines which route the case takes.
Reviewing the relevant authority's file
At the Bureau - the case file, a breakdown of the sum, the statutory caps on deductions; at the Revenue Service - the basis and dates of the assessment; at court - the order and its scope. The lawyer checks whether the amount and scope match the act: often every account is blocked where one would have sufficed.
Releasing protected sums
In enforcement the law protects the subsistence minimum and certain social payments (pension, benefits, maintenance); deductions from wages are capped. The lawyer asks the Bureau for a recalculation and the release of protected sums - often the fastest result available.
The source of funds package in an AML case
In one go and in full: the contract, invoice, acceptance reports, identification of the payer, the history of earlier payments, tax returns, the chain of origin of the funds (a sale, salary, dividend, loan). The lawyer aims at one "final" answer rather than delivery in instalments, which stretches the check out for months.
Escalating the complaint
A written complaint to the bank with a deadline; where there is no reply or a refusal - to the National Bank's consumer protection directorate. In parallel, where the money is urgently needed, an alternative channel (another bank, a different routing) - because winning a complaint takes months while the business needs the transfer this week.
Claiming damages
Loss caused by funds blocked without justification: a collapsed deal, penalties on other obligations, contractual fines, exchange rate losses. The lawyer documents the loss from the day of the block - with letters, counterparties' claims and cancelled contracts.
The Money Is at the Bank but Not in the Account - What Is Happening and What to Do
The most common and most painful scenario: a transfer from abroad or from a local counterparty gets "stuck" at the bank - it is not credited to the client, not returned to the sender, and the bank asks for documents. Legally this is not a block but a check on the transfer, which the law requires the bank to carry out; but the practical result is the same - the money is out of reach and no deadline is written down anywhere.
The lawyer's work here has two parts. The first is a document package that answers the check once and for all: what the relationship with the sender is (the contract), what the money is for (invoice, acceptance report), who the sender is (registration documents, beneficial owner), where their money comes from and why the transaction is ordinary for your business (the history of earlier payments, tax returns). Supplying documents piecemeal is the most common mistake: each new document restarts the check.
The second is recording the deadlines and using the lawful levers: a written approach stating a deadline, a question as to which rule the funds are being held under, and a reminder that a bank holding funds without justification is liable for the loss. If the money is still not credited and no reasoning arrives - a complaint to the National Bank and, for a large sum, court. In parallel the lawyer considers a fallback route with the sender - returning the funds and re-sending them through another bank is often faster than winning the dispute.
What a Blocked Account Case Rests On
- Right to information
- A client is entitled to know who blocked the account and on the basis of which document; the bank must reply to a written approach within the set period. "Confidentiality" is no ground for refusing an answer where the block rests on an enforcement or tax act.
- Protected sums
- In enforcement the law protects the subsistence minimum and certain social payments; deductions from wages are capped. These caps do not always operate automatically - especially where there are several enforcement files - and a recalculation must be requested separately.
- Scope of a freeze
- A freeze is imposed for a specific amount; blocking more than that, or restricting every account where one would suffice, is challengeable and grounds a claim for damages.
- AML check
- A bank must examine an unusual transaction and may request documents from the client; that power is not unlimited - the check must end within a reasonable time and be reasoned, and holding funds without justification creates liability for loss.
- Refusal of service
- Refusing to open an account or closing one is the bank's right but not an arbitrary one: the refusal must be reasoned in writing and is challengeable before the National Bank; blanket refusals without criteria raise a separate question of discrimination.
- Damages
- Loss caused by funds blocked without justification - a collapsed deal, a fine, penalties, exchange rate loss - is recoverable from the bank; the claim must be documented from the day of the block.
What to Prepare for an AML Check - in One Go and in Full
- The contract with the sender or counterparty, signed, with annexes and payment terms.
- The invoice or acceptance report for the specific transaction, matching the amount and the payment reference.
- Identification of the sender: registration documents, beneficial owner information, a description of their business.
- The chain of origin of funds on your side: income documents, a property sale, dividends, a loan agreement, an inheritance.
- The history of earlier payments with the same counterparty - so that the transaction does not look "unusual".
- Tax returns or certificates showing that the income is declared and the transaction is part of your ordinary business.
Three Blocked Account Cases
A pension swept up by enforcement
After the Bureau blocked the account, a pensioner had the entire balance deducted, including her pension and social benefit. The lawyer: reviewed the enforcement file, applied to the Bureau to release the protected sums citing the statute, and obtained a recalculation; in parallel the debt was recalculated under the caps. The protected money was returned and the monthly deduction was reduced to the lawful cap.
A foreigner's incoming transfer held for two months
A foreign IT specialist had a transfer from a European client held by the bank, which requested documents piecemeal. The lawyer: a single package (contract, invoices, the client's registration, the history of earlier payments, sole entrepreneur tax returns), a written approach stating the deadline and the legal basis, and notice of a complaint to the National Bank. The funds were credited within five working days; subsequent transfers went through without problems.
A company account the bank closed
A trading company was notified that its account would be closed within two weeks, without reasons. The lawyer: a written demand for reasons and an extension, a complaint to the National Bank and, in parallel, opening an account at another bank with a full document package (beneficiaries, counterparties, turnover structure). The new account was opened in five days and the old bank extended its deadline until the migration was complete - the business never stopped.
Questions About Blocked Accounts
The bank will not tell me the reason. What rights do I have?
You are entitled to ask the bank in writing who blocked the account and on what basis, and to receive an answer within the set period. If the block rests on an act of the Enforcement Bureau or the Revenue Service, the bank must say so - after which the case moves to that authority. If no answer comes or it is generic, that is itself a ground for a complaint to the National Bank.
My salary and pension are paid into that account. Will they be taken too?
In enforcement the law protects the subsistence minimum and certain social payments, and deductions from wages are capped - but in practice that protection does not always operate automatically, especially where several enforcement files target one person. The lawyer applies to the Bureau to release the protected sums and recalculate; the money is often returned.
The bank has held my funds and asks for documents piecemeal. Why?
Because every answer raises a new question, and the check stretches out for months that way. The right tactic is a single package: contract, invoice, acceptance report, identification of the sender, chain of origin and the history of earlier transactions all at once, with the legal basis and a deadline stated. The lawyer builds the package to be "final" and records the deadlines for a damages claim in parallel.
I am a foreigner and the bank refused to open an account. Is that challengeable?
Refusing service is the bank's right, but it must be reasoned in writing and is challengeable before the National Bank. In practice two routes run in parallel: the complaint (which produces a systemic result) and an application to another bank with a better-prepared package - a description of your activity, your source of income and your ties to Georgia (residence, property, a company). A refusal often reflects one bank's policy rather than your status.
A transfer failed and my deal collapsed. Can I claim damages from the bank?
If the block or the hold was unjustified - yes: the bank is liable for the loss caused to the client. The claim must be documented: the contract that collapsed, the counterparty's claim or penalty, penalties on other obligations, the exchange rate difference, correspondence with the bank with dates. That is why the lawyer starts the damages file on the first day of the block, not after it is lifted.
Lawyers for Blocked Account Cases
In a blocked account case speed depends on the completeness of the documents - one package in one go, not delivery in instalments. Within 15 minutes the coordinator connects you with a lawyer who works regularly with banks, the National Bank and the Enforcement Bureau.
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Call: 568 330 318Is Your Account Blocked or a Transfer Left Hanging?
At a free consultation the lawyer establishes who blocked it and on what basis, which documents to submit in one go and how quickly the funds can be released. The coordinator rings you in 15 minutes, in English or Russian if you need it.