Bank Account Restrictions: What Can Clients Do When Their Funds Remain Frozen?

Anti-money laundering and financial crime controls are an essential part of the modern financial system. Financial institutions are required to monitor transactions and may restrict accounts where legitimate compliance concerns arise. But what happens when a review continues for weeks or months while the client remains unable to access their own funds?

This is an increasingly important issue in Lithuania's financial services market. According to the Financial Crime Investigation Service (FNTT), more than 102,000 suspicious transaction reports were received in Lithuania in 2025, almost 25% more than the previous year.

Our experience with Revolut

Our firm deals with account restrictions and frozen funds on a daily basis. We regularly represent individuals and businesses whose accounts with Revolut remain restricted for prolonged periods. Clients often cooperate fully with requests for information and provide the requested documents, yet receive only generic responses referring to an ongoing “security review” or “compliance check”, without a clear explanation of the reasons for the restriction, its legal basis or when their funds will be released.

For businesses, such restrictions can have serious consequences, preventing them from paying employees, suppliers, taxes and other obligations and potentially causing significant losses.

What can clients do?

AML obligations do not necessarily give financial institutions unlimited discretion to restrict access to funds indefinitely. The legal basis, duration, necessity and proportionality of a restriction should be assessed in each case, including whether any competent authority is involved.

Our lawyers assist clients in challenging prolonged restrictions imposed by Revolut and other financial institutions, including through formal legal demands, complaints to supervisory authorities and court proceedings. 

If your funds have been restricted for an extended period without a clear explanation or apparent legal basis, we can assess your situation and advise on the available remedies. Contact us at info@sulijapartners.com

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