This article explains, in Philippine context, why bank and e-money accounts get frozen, who can order a freeze, what your rights are, and practical, step-by-step ways to unfreeze funds. It is legal information—not individualized legal advice.

1) What “freezing” actually means

Freeze / hold / debit block. A bank stops outgoing transactions on an account (withdrawals, transfers, payments). Incoming credits may still post unless the order says otherwise.
Garnishment / levy. Funds are restrained and turned over to a government creditor per writ/warrant.
Account closure. Separate from a freeze; the bank terminates the relationship (often after AML flags).
Scope. Orders can name specific accounts, a customer (all accounts with that bank), or “any and all accounts” system-wide when the order is served broadly (e.g., by a revenue district or sheriff).

2) Who can cause a freeze (and the usual legal bases)

The precise document that reached the bank determines both the procedure to challenge and the timeline to unfreeze.

Court of Appeals (CA) Freeze Orders under the AMLA
- Law. Anti-Money Laundering Act (as amended, including R.A. 10167, R.A. 10365, R.A. 10927).
- Trigger. Petition by the Anti-Money Laundering Council (AMLC) showing probable cause that the account is related to unlawful activity or money laundering.
- Nature. Ex parte (without notifying you initially), effective immediately for a limited period (commonly 20 days) and extendable by the CA after hearing.
- Effect. Bank must freeze identified property/accounts; breach exposes the bank to penalties.
Anti-Terrorism and Targeted Financial Sanctions
- Laws/regs. Anti-Terrorism Act (ATA) and related UNSC sanctions implementation.
- Trigger. Designation/listing of a person/entity; AMLC may issue a freeze without prior court approval (time-bound and subject to judicial confirmation/extension).
- Effect. Immediate and very strict freeze; humanitarian exemptions are possible but must be applied for.
BIR Warrants of Garnishment (WOG) / Levy (Tax Collection)
- Law. National Internal Revenue Code (NIRC) and rules on distraint and levy.
- Trigger. Assessment becomes final/executory or delinquency occurs; the BIR serves a WOG on the bank.
- Effect. Bank must hold the taxpayer’s funds up to the amount stated and remit to BIR; banks seldom lift without BIR clearance or court relief.
Civil Cases: Writ of Preliminary Attachment / Injunction
- Law. Rules of Court.
- Trigger. A private litigant secures a court writ (often with a bond) to secure a claim.
- Effect. Sheriff serves writ; bank holds funds subject to the writ. Lifting usually requires court order, counter-bond, or case resolution.
Criminal Cases: Search, Seizure, Asset Preservation
- Law. Rules of Criminal Procedure; special penal laws (e.g., anti-graft, cybercrime).
- Trigger. Prosecutors/law enforcers obtain a court order targeting suspected proceeds/instrumentalities.
- Effect. Bank complies strictly until order expires or is quashed.
Regulatory / KYC Reasons (Bank-Initiated Freeze)
- Law/regs. Bangko Sentral ng Pilipinas (BSP) AML/CFT rules (KYC, ongoing monitoring), e-money rules, and bank contractual terms.
- Triggers (examples).
  - Identity mismatch or KYC deficiencies (expired ID, unverified address).
  - Unusual or suspicious activity (e.g., rapid in/out flows, mule-like patterns).
  - Chargeback/fraud complaints for card or wallet rails.
  - Dormancy plus risk flags; or sanctions hits during screening.
- Effect. Bank may place a temporary hold while it performs Enhanced Due Diligence (EDD). These are often lifted internally once requirements are satisfied.
Other government agencies
- E.g., PCGG (ill-gotten wealth), COA/LGUs (public funds), courts in family cases (support, community property). Each uses its own writ/order; bank follows the face of the process.

3) Common scenarios, symptoms, and first clues

App says “restricted,” teller says “by order of ___.” Ask for the exact legal instrument (freeze order, writ number, WOG, AMLC letter) and date of service.
Only one bank is affected vs many. Multi-bank impact often means AMLC/ATA/BIR action; single-bank hold may be a KYC/contract issue.
Only outward debits blocked. Suggests bank-initiated AML/KYC hold or CA freeze (credits may still post).
Funds suddenly remitted to a government account. Typically BIR garnishment or satisfaction of a writ.

4) Your rights (and limits)

Notice and access to documents. You are entitled to know the basis of the restraint. For AMLA/ATA, initial non-disclosure to you is allowed, but once served and especially after extension, you may access the petition/order for purposes of challenge.
Due process. You can petition the issuing authority (CA/court/agency) to lift/modify; for KYC holds, you can escalate within the bank and to the BSP Consumer Assistance Mechanism (CAM).
Data privacy. Banks lawfully share your data with regulators/law enforcement for compliance; this is an exception to bank secrecy.
Humanitarian/operational carve-outs. In ATA/AMLA contexts, limited releases for necessities (e.g., medical, payroll) can be requested—but only via the issuing authority’s process, not by branch discretion.
Time limits. Freeze orders are time-bound (subject to extension). Bank-initiated holds should be no longer than necessary to complete due diligence.

5) How to unfreeze: playbooks by situation

Always get the document that triggered the freeze. Everything flows from it. If the front-line staff can’t provide a copy, ask them to identify: (a) issuing authority, (b) reference number, (c) date/time of service, and (d) exact wording of the restraint.

A) AMLC / CA Freeze Order (AMLA)

Objective: Lift or narrow the freeze; or release specific amounts. Steps:

Secure copies of the CA freeze order and AMLC petition (from the CA or your counsel).
Map the assets covered (account numbers, amounts, related accounts).
Prepare evidence showing lawful source/use of funds (payslips, contracts, invoices, tax filings, gift deeds, loan docs, remittance slips).
File with the CA:
- Opposition to the AMLC petition or motion to lift/modify (e.g., carve-out for living expenses, payroll, or to exclude an account demonstrably unrelated).
- Observe the return/hearing date and any extension proceedings.
If the freeze lapses without extension, request bank release citing the expiry (banks need written proof—CA or AMLC notice—or the order’s own sunset clause).

Timelines: Initial orders are short (commonly ~20 days) but extensions can run much longer while a related forfeiture case is pursued.

B) Anti-Terrorism / Sanctions Freeze

Objective: Delisting or specific license for limited use. Steps:

Confirm whether the basis is ATA designation or UN list implementation.
Apply for humanitarian exemptions or specific licenses as allowed by rules; these are narrow and evidence-driven.
Pursue delisting or judicial review where available.
Banks cannot override—only the competent authority can.

C) BIR Warrant of Garnishment (Tax)

Objective: Lift garnishment or reduce scope/amount. Steps:

Get the WOG copy and the final assessment it stems from.
Determine if the assessment is final (lapsed protest/appeal) or still contestable.
Paths:
- Abatement/compromise or installment under BIR rules → obtain BIR lifting/partial lifting letter.
- Appeal (CTA/courts) with injunctive relief → present court TRO/Status Quo Ante Order to the bank.
- Payment → secure BIR release and present to bank.

Note: Banks remit upon demand. Once remitted, getting money back requires BIR/court action, not bank discretion.

D) Court Writ (Attachment/Injunction) in a Civil/Criminal Case

Objective: Dissolve or modify the writ. Steps:

Obtain the writ, bond details, and case docket.
File a motion to discharge the attachment (e.g., improper issuance, lack of cause) or post a counter-bond equal to the claim plus costs.
If you win or settle, present the court order lifting the writ to the bank.

E) Bank-Initiated AML/KYC Hold

Objective: Satisfy due diligence and get an internal release. Steps:

Ask the bank for the specific deficiency or trigger (e.g., expired ID, source-of-funds check, transaction review).
Submit: valid government ID(s), proof of address, source-of-funds/source-of-wealth documents (employment certificate, payslips, contracts, BIR 2316/1701, DTI/SEC papers, invoices/ORs, loan agreements, remittance receipts).
If flagged for possible mule/fraud, add: chat/email trails, marketplace order records, complaint resolutions, police blotter if scammed.
Request written confirmation of lifting once cleared.
Escalate unresolved cases to the bank’s central complaints unit and, if needed, file with BSP Consumer Assistance. Keep case numbers.

Typical timeframes: From same-day (simple ID update) to a few weeks (EDD with document validation).

6) Evidence that helps (checklist)

Government IDs (primary + secondary), proof of address (bill, barangay cert).
Employment/engagement: contract, COE, payslips; business: DTI/SEC, mayor’s permit, invoices/OR, bank statements.
Tax: BIR 2316/2307/1701/1702, COR (1905/2303).
Source of funds: remittance receipts, loan agreements and disbursement proofs, deed of donation/sale, insurance proceeds, settlement agreements.
For marketplace/crypto: platform statements, wallet tx hashes, exchange KYC/withdrawal records, order/fulfillment screenshots.
For fraud/scam: demand letters, police blotter, NBI report, chargeback correspondence.

7) Special situations

Joint accounts. A freeze on one holder can immobilize the entire joint account if covered by the order. Each co-owner may seek partial lifting for their verifiable share.
Payroll and corporate accounts. Ask for carve-outs to meet statutory wage obligations; provide payroll registers and SSS/PhilHealth/Pag-IBIG proofs.
E-money and fintech wallets. Same AML/KYC duties as banks. Holds are common for large first-time inflows or P2P resale activity.
Foreign remittances. Sudden high-value inflows from higher-risk corridors trigger EDD; pre-position remitter details and purpose of funds.
Dormant accounts. Dormancy + attempted reactivation without updated KYC can lead to a hold until you visit and update records.
Estate/death. Accounts of a deceased person are not “frozen” by AML but are locked pending estate settlement. Heirs need extrajudicial or court processes and BIR estate tax clearance for release.

8) How long do freezes last?

AMLA/ATA. Initially short, but courts may extend while forfeiture/designation issues are pending.
BIR WOG. Until satisfied, lifted by BIR, or enjoined by a court.
Court writs. Until dissolved/modified or upon judgment.
Bank-initiated holds. Should lift as soon as KYC/EDD is completed and risk is mitigated.

9) Practical dos and don’ts

Get the document (or at least the exact reference) that caused the freeze.
Centralize all communication via email and ask for ticket numbers.
Over-document lawful sources and transaction purpose.
Use calm timelines in your submissions (who/what/when/why/how).
If urgent needs exist (medicine, payroll), ask for partial release or carve-outs where the regime allows.

Don’t

Structure transactions to evade thresholds (that worsens AML suspicion).
Move activity to new accounts to “escape” scrutiny (may expand the freeze).
Threaten staff; they cannot override legal orders.
Ignore tax assessments or court dates—these are what keep freezes alive.

10) How lawyers typically frame a lifting request (outline)

Caption (case no./freeze order ref).
Relief sought (lift/modify; limited humanitarian release; exclusion of specific account).
Statement of facts (timeline, amounts, account list).
Grounds (lack of nexus to unlawful activity; due process; overbreadth; hardship proportionality; supporting statutes/case law).
Evidence (annexes: IDs, contracts, tax, bank records).
Prayer (specific amounts/accounts; time-bound relief).
Verification & attachments (authority, service proof).

11) Getting help and escalation map

Start: Bank branch → bank head office complaints → BSP Consumer Assistance (for bank-initiated holds or poor handling).
For legal orders: Go to the issuing authority (CA/court/BIR/AMLC).
For suspected scams or mule accusations: PNP-ACG / NBI-CCD blotter to document your position, then submit to bank.

12) Short templates

Request for Basis / Copy of Order (to bank)

Subject: Request for Copy/Details of Freeze or Hold on Account [Acct No. ****1234] Dear [Bank], I was informed that my account is on hold/freeze. Please provide (a) the legal basis and issuing authority, (b) reference number, (c) date/time served on the bank, and (d) scope of the restraint. I also request your requirements and expected timeline for review. Sincerely, [Name], [TIN], [Contact]

Source-of-Funds Package (cover note)

Please find attached IDs, proof of address, and documents evidencing the lawful sources and intended use of the funds in [account]. I respectfully request lifting of the internal AML/KYC hold at the soonest.

13) Quick decision tree

Do you have a reference/writ number?
- Yes → Identify the issuing authority and follow the relevant playbook.
- No → Ask bank for basis; if “KYC/AML review,” go to the bank-initiated hold steps.
Is it tax-related?
- Yes → Work on BIR compromise/abatement or court relief; bank can’t lift on its own.
Are humanitarian needs urgent?
- Yes → Request targeted carve-out (AMLA/ATA contexts) with supporting proof.

14) Key takeaways

Everything depends on the exact legal basis—get the document.
Three main families: AMLA/ATA freezes, tax garnishments, and court writs.
Bank-initiated holds often lift once you complete KYC/EDD and substantiate sources.
Speed comes from documentation. Prepare a clean, chronological evidence pack.
Only the authority that caused the freeze can fully lift it (or a court that can enjoin it).

If your funds are significant or the order is from AMLC/BIR/courts, consult counsel immediately to choose the right forum (motion vs. petition, administrative vs. judicial) and preserve deadlines.