What the service includes
An account freeze stops a business here and now: salaries, payments to suppliers and taxes cannot go through. The causes vary, from a formally unfiled return to a bank’s suspicion of questionable transactions under Federal Law No. 115-FZ, and what needs to be done depends on the cause.
We establish the exact ground for the freeze, prepare the necessary documents or explanations and get the restrictions lifted, including through an appeal if the bank or the tax authority refuses to unblock the account after the formal causes have been remedied.
A further difficulty is that lifting the freeze at one bank does not guarantee that the company will stay off the Bank of Russia’s database of questionable transactions, in which case problems arise with other banks. So alongside unblocking the specific account, we check whether there are grounds for including the company on such a list and, where necessary, seek its removal. This is especially important for businesses with several settlement accounts at different banks.
What the service includes:
Who it is for
The situations clients most often bring to us on this topic.
How we work
A fixed fee and a clear plan of action, agreed before work begins. The timeframes below are indicative and depend on the complexity of the case.
Diagnosing the cause
We establish the exact ground for the freeze: a tax authority decision or the bank’s internal compliance. Timeframe: 1 day.
Preparing documents
We prepare returns, explanations or a package of documents confirming that the transactions are genuine. Timeframe: 1-3 days.
Dealing with the bank or the FTS
We submit the documents and get the freeze lifted within the statutory deadlines. Timeframe: 1-15 days.
Appeal if refused
If the bank or the tax authority unjustifiably refuses to unblock the account, we appeal that decision. Timeframe: 1-3 months if refused.
What you will need at the start
We confirm the exact list for your situation at the consultation. This is a guide so that you arrive at the first meeting prepared.
Key figures
Experience in this practice area specifically, not in practice as a whole.
Common mistakes
Expecting the account to unblock itself. The company sends the requested documents once and then simply waits, assuming that the bank will lift the restrictions automatically. Prolonged silence often leads to the account being closed altogether and the company being put on a list of unreliable clients.
A formal reply to the bank’s request. The company answers the bank’s request to explain transactions briefly and without supporting documents. The bank takes this as confirmation of its suspicions and tightens the restrictions instead of lifting them.
Trying to open an account at another bank. Instead of removing the cause of the freeze, the company tries to open an account at another bank, not realising that information about heightened risk is passed between banks through Rosfinmonitoring and the Central Bank, and the new account is frozen on the same grounds.
What you get
An unblocked settlement account. The company can make payments again: salaries, taxes and settlements with suppliers.
A clear reason for the freeze. The business has a clear explanation of what triggered the restrictions and what needs to change so that it does not happen again.
A document package for the bank. Explanations and supporting documents that resolve the questions of the financial monitoring department are prepared.
A clean reputation in the banks’ databases. The company does not remain on the information lists of questionable transactions that make dealing with other banks harder.
Related
Frequently asked questions
How quickly can an account be unblocked?+
If a formal ground is removed, from a few days; if the decision has to be challenged, from several weeks to months.
Can a bank freeze an account without a decision from the tax authority?+
Yes. Banks apply compliance procedures on their own under Federal Law No. 115-FZ when they suspect questionable transactions. This is a separate ground, unrelated to the FTS.
What should I do if the bank demands an explanation of every transaction for the past six months?+
This is standard practice under enhanced compliance control. We help prepare the explanations so that they actually resolve the bank’s questions.
Can I open an account at another bank while this one is blocked?+
Formally yes, but where there are systemic suspicions about the business, this may lead to a refusal from the other bank as well. We look at the situation as a whole, not just at a single point.
How long does inclusion of a company in the Bank of Russia’s high-risk list last, and is it possible to get off it?+
Formally it is open-ended, but the law provides a procedure for removal from such a list through an interdepartmental commission or the court. The earlier that procedure is started, the lower the likelihood that the restrictions will spread to other banks.
Can the bank be made to pay costs if the account freeze is held by a court to be unjustified?+
Yes. If the freeze is successfully challenged in court, the company is entitled to claim its court costs and, in some cases, the losses caused by the suspension of operations on the account.