Dealing with Bank Account Freezing: Appeals and Lawyer's Role

21 April 2026

When a bank account is frozen, knowing the reason for the freeze is not enough; what matters more is knowing how to confront it legally. What does the account holder do vis-à-vis the bank? How does one file a grievance against the decision? What is the lawyer's role? What becomes of the funds during the freeze? And what are the penalties for mishandling it? In what follows we explain all of that, grounded in the text of Federal Decree-Law No. (10) of 2025 and its Executive Regulation issued by Cabinet Resolution No. (134) of 2025.

Confronting a Bank Account Freeze: The Grievance, the Lawyer's Role, and the Fate of Your Funds Under UAE Law

First: The Steps to Take Vis-à-Vis the Bank

The first practical step is to identify the authority that ordered the freeze, its basis, its duration, and its type (the halting of an operation, a freeze by the Unit, or a freeze by the Public Prosecution), because the path of response differs accordingly. It is also important to document all correspondence with the bank in writing.

The Bank Notifies You and Requests Proof of a Legitimate Source

Article (51) of the Executive Regulation obliged the institution at which the funds were frozen to notify their owner of the freezing order and its source, and to require them to provide the documents necessary to establish the soundness of the transaction and the legitimacy of the source of the funds, then to refer them to the Unit. This notice is the first opportunity for defense — it allows the account holder to submit documents establishing the legitimacy of their funds from the very outset of the procedure.

⚠ The Limits of the Bank's Disclosure

Despite notifying you of the freezing order and its source, the bank remains reticent about the details of the inquiry; Article (24) of the Decree-Law made information relating to suspicious transactions confidential, and Article (19) of the Regulation prohibits the bank from disclosing to the customer that it has reported, or is about to report, suspicious operations, or that there is an investigation concerning them. The bank's adherence is compliance with the command of the law.

Second: The Grievance — The Primary Legal Route to Confront the Freeze

Here lies the essential safeguard that the law guaranteed. Article (6) of the Decree-Law permitted every interested party to file a grievance against the Public Prosecution's decisions of seizure or freezing, against decisions that would prevent dealing in the funds, or against the extension of the freeze issued by decision of the Public Prosecutor. The grievance is adjudicated by the competent criminal court within whose jurisdiction the Public Prosecution that issued the decision is located. The following are the steps of this route as drawn by the law:

1The grievance is filed by a report submitted to the competent court.

2The president of the court sets a hearing to consider the grievance, of which the grievant is notified.

3The Public Prosecution submits a memorandum with its opinion on the grievance.

4The court decides the grievance within a period not exceeding fourteen working days from the date of its submission.

⚠ The Decision on the Grievance Is Not Subject to Appeal

Article (6) provided that the decision on the grievance is not subject to appeal. If the grievance is rejected, a new grievance may not be submitted except after the lapse of every three months from the date of rejection, unless a serious ground arises before that period elapses. The grievance must therefore be prepared with the utmost care the first time.

Third: The Lawyer's Role in Confronting the Freeze

The lawyer's value centers on precisely identifying the ordering authority, its basis, and its duration; preparing the grievance report and submitting it before the competent criminal court on time, attending its hearings and responding to the Prosecution's memorandum; establishing the legitimacy of the source of funds to rebut the suspicion; and tracking the time limits and applying to have the freeze lifted upon their lapse without extension. Their role extends to representing companies; Article (4) of the Decree-Law provided that a legal person is criminally liable if one of the crimes is deliberately committed in its name or on its account, without prejudice to the personal liability of its perpetrator.

Managing the Frozen Funds and the Cap on Management Fees

Article (53) of the Regulation permitted the Prosecution or the court to assign the accused, the owner of the funds, or whomever it deems appropriate to manage the frozen funds, and disposal or sale before judgment may be authorized if their deterioration is feared. If the assignee is a third party, the management fees are assessed by a decision approved by the Public Prosecutor, either as a lump sum or as a percentage not exceeding ten percent of the value of the funds under management.

The Lawyer's Exemption from Reporting Within the Scope of Professional Secrecy

Article (18) of the Regulation exempted lawyers, notaries, independent legal professionals, and independent legal auditors from the duty to report suspicious transactions, if they obtained the information in the course of assessing the client's legal position, defending or representing them, or providing a legal opinion, or in other circumstances in which they are subject to professional secrecy. This safeguards the relationship between a client and their lawyer.

Fourth: The Fate of Frozen Funds and the Prohibition on Disposing of Them

Article (54) of the Regulation addressed the fate of the funds during the freeze with important provisions. It obliged institutions to transfer the frozen funds to deposit accounts bearing interest or profit at the prevailing market rate, and deemed the interest and profits accruing from them an integral part of the criminal property in the event a judgment of confiscation is issued. Most important for the account holder is that, upon the revocation of the freezing decision by the competent authorities, the frozen funds are returned with their interest and profits added to them. The Regulation also prohibited institutions from disposing of the seized or frozen funds in any way — even to settle prior obligations — except by permission of the Public Prosecution or the competent court, after coordination with the supervisory authority.

Funds Returned with Their Profits Upon Revocation

Freezing does not deprive you of ownership of your funds or their returns; they are transferred to a productive deposit and returned to you in full, together with their interest and profits, whenever the freezing decision is revoked, in accordance with Article (54) of the Executive Regulation.

Fifth: Liability and Penalties for Violating the Freezing Order

Mishandling a freeze may turn a manageable situation into an independent crime. Article (29) of the Decree-Law penalized anyone who, deliberately or through gross negligence, breached any order issued by a competent authority for seizure, freezing, or other precautionary measures, and aggravated the penalty if this resulted in the impossibility of seizing the proceeds, their loss, or the loss of their value. Indeed, Article (6) of the Decree and Article (52) of the Regulation provided that any contract or disposition whose purpose is to affect the ability of the competent authorities to seize, freeze, recover, or confiscate is void by force of law — without prejudice to the rights of bona fide third parties. Attempting to move frozen funds is therefore a legally dangerous course.

Protection of the Good-Faith Reporter and Proactive Cooperation

In return, Article (37) of the Decree-Law provided that no criminal, civil, or administrative liability attaches to anyone who provided the required information in good faith. Article (26) also permitted the court to mitigate or grant exemption from the penalty for any of the perpetrators who took the initiative to give the authorities information that led to uncovering the crime or its perpetrators, or to seizing the criminal property.

Sixth: Practical Tips for Individuals and Companies

Identify the Basis, Authority, and Duration

Know the ordering authority, the type of freeze, and its duration, because the path of response differs between a freeze by the Unit, the Prosecution, and the lists.

Do Not Attempt to Move the Funds

Any disposition whose purpose is to evade the freeze is void by force of law and may expose you to an independent penalty.

Take the Initiative to File a Grievance Within the Period

The grievance before the competent criminal court is your primary route, decided within 14 working days, so engage a lawyer to prepare it precisely.

Submit Source Documents to the Bank

The bank is obliged to notify you of the source of the freeze and to request documents proving the legitimacy of the funds; take the initiative to submit them to support your position early.

Your Funds Remain Productive and Are Returned with Profits

Frozen funds are transferred to an interest- or profit-bearing deposit and returned to you with their returns upon revocation of the freeze.

For Companies: Review Your Obligations

Review your due diligence measures and compliance policies, for a legal person is criminally liable for what is committed in its name or on its account.

Frequently Asked Questions

How do I file a grievance against the freezing decision?

The law permitted every interested party to file a grievance against the Public Prosecution's decisions of seizure or freezing before the competent criminal court. The grievance is filed by a report submitted to the court; its president sets a hearing of which the grievant is notified, the Prosecution submits a memorandum with its opinion, and the court then decides within a period not exceeding fourteen working days from the date of submission.

What if my grievance is rejected?

The decision on the grievance is not subject to appeal. If it is rejected, a new grievance may not be submitted except after the lapse of every three months from the date of rejection, unless a serious ground arises before that period elapses. The grievance must therefore be prepared with the utmost care the first time.

Will the bank tell me the reason for the freeze and ask me for documents?

Yes. Article (51) of the Regulation obliged the institution to notify the owner of the funds of the freezing order and its source, and to require the documents necessary to establish the soundness of the transaction and the legitimacy of the source of the funds, then to refer them to the Unit. The bank, however, remains reticent about the details of the inquiry, since information relating to suspicious transactions is confidential and it is prohibited from disclosing the existence of a report or investigation.

What happens to my funds during the freeze, and are they returned with their profits?

Frozen funds are transferred to deposit accounts bearing interest or profit at the prevailing market rate, so you do not lose ownership of them or of their returns. Upon revocation of the freezing decision by the competent authorities, the funds are returned to you in full with their interest and profits added, in accordance with Article (54) of the Regulation.

Who manages the frozen funds, and how much are the management fees?

Article (53) of the Regulation permitted the Prosecution or the court to assign the accused, the owner of the funds, or whomever it deems appropriate to manage the frozen funds. If the assignee is a third party, their fees are assessed by a decision approved by the Public Prosecutor, either as a lump sum or as a percentage not exceeding ten percent of the value of the funds under management.

What happens if I try to withdraw the frozen funds?

Any contract or disposition whose purpose is to affect the authorities' ability to seize, freeze, recover, or confiscate is void by force of law. Article (29) of the Decree also penalized anyone who deliberately or through gross negligence breached the freezing order, and aggravated the penalty if this resulted in the impossibility of seizing the proceeds, their loss, or the loss of their value.

Does taking the initiative to cooperate with the authorities improve my position?

Yes. Article (26) permitted the court to mitigate or grant exemption from the penalty for any of the perpetrators who took the initiative to give the authorities information that led to uncovering the crime or its perpetrators, or to seizing the criminal property. Likewise, no liability attaches to anyone who provided the required information in good faith.

Will my lawyer attend with me in confronting the freeze?

Yes. The lawyer handles identifying the ordering authority, its basis, and its duration; preparing the grievance report and submitting it before the competent criminal court on time, attending its hearings and responding to the Prosecution's memorandum; establishing the legitimacy of the source of funds; and tracking the time limits and applying to have the freeze lifted. The lawyer is also exempt from the duty to report within the scope of professional secrecy, safeguarding the relationship between a client and their lawyer.

Legal References

Federal Decree-Law No. (10) of 2025 on combating money laundering, the financing of terrorism, and the financing of the proliferation of weapons, issued on 30 September 2025 (repealing Decree-Law No. 20 of 2018).
Cabinet Resolution No. (134) of 2025 on the Executive Regulation of Federal Decree-Law No. (10) of 2025, issued on 29 October 2025.

⚖ SPECIALIZED LEGAL CONSULTATION

Do you need to confront a decision freezing your account?

The team at AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS is ready to prepare your grievance and follow your legal position through to the return of your funds.

✓Preparing and submitting the grievance report before the competent criminal court on time, and following its hearings.

✓Establishing the legitimacy of the source of funds to rebut the suspicion and protect your legal position.

✓Following the fate of the frozen funds and applying for their return with their returns upon revocation.

✓Representing individuals and companies, protecting the rights of bona fide third parties, and tracking the legal time limits.

Contact AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS to book your legal consultation today.

Disclaimer: This blog was prepared by AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS for general legal-awareness purposes only. It does not constitute legal advice or a legal opinion on any specific matter, and it does not create an attorney-client relationship. Rulings differ according to the circumstances of each case, and it is advisable to obtain specialized legal consultation before taking any action.

This English text is a translation. In the event of any discrepancy, the Arabic version shall be the authoritative reference.