If money was sent from your bank account or e-wallet to a scammer, the first few hours matter. In the Philippines, you usually do not “freeze the scammer’s account” by filing your own court case right away. The faster and more practical remedy is to report the disputed transaction to your bank or e-money issuer so it can trace the funds and request a temporary hold under the Anti-Financial Account Scamming Act, while you build the records needed for law enforcement, BSP escalation, and possible recovery.
What “freezing” a bank or e-wallet account really means
People often use “freeze” to mean different things. In Philippine practice, there are three separate remedies:
| What people call it | What it actually means | Who can initiate it | Usual purpose |
|---|---|---|---|
| Locking your own account | Disabling your online banking, card, or e-wallet access | You, through the app or customer service | Stop further unauthorized transactions |
| Temporary holding of disputed funds | Holding the money that was sent to a beneficiary account while banks/e-wallets verify the transaction | Bank, e-money issuer, or other BSP-supervised institution under AFASA rules | Stop scam proceeds from being withdrawn or moved again |
| Court freeze order | A Court of Appeals order freezing money or property linked to unlawful activity or money laundering | AMLC, through a petition before the Court of Appeals | Preserve assets for investigation, forfeiture, or prosecution |
For most online scam victims, the immediate target is the second one: temporary holding of disputed funds. This is the mechanism most directly connected to bank transfers, InstaPay/PESONet transfers, QR payments, and e-wallet transfers after an online scam.
Legal basis: the Anti-Financial Account Scamming Act
The main law is Republic Act No. 12010, or the Anti-Financial Account Scamming Act (AFASA), approved in 2024. AFASA covers financial accounts such as deposit accounts, transaction accounts, credit card accounts, and e-wallets under institutions supervised by the Bangko Sentral ng Pilipinas (BSP). (Lawphil)
AFASA punishes two common scam patterns:
- Money muling, where a person uses, lends, sells, rents, or allows the use of a financial account to receive, transfer, withdraw, or move scam proceeds.
- Social engineering, where a scammer deceives a person into giving sensitive identifying information, such as passwords, OTPs, account details, or e-wallet credentials, resulting in unauthorized access or control over the account. (Lawphil)
The most important provision for victims is Section 7. It allows institutions to temporarily hold funds subject of a disputed transaction for a BSP-prescribed period not exceeding 30 calendar days, unless extended by a court. A transaction may be treated as disputed if there are reasonable grounds to believe it is unusual, has no clear economic purpose, comes from an illegal or unknown source, or was facilitated through social engineering. (Lawphil)
BSP’s 2025 implementing rules further break this down into:
- an initial hold of up to 5 calendar days; and
- a possible extended hold of up to 25 additional calendar days, for a total of not more than 30 calendar days, unless a court extends it. (Bureau of the Treasury)
This is why victims are repeatedly told to file a report immediately. If the money has already been withdrawn in cash, converted, or moved through multiple accounts, the bank or e-wallet may still trace the chain, but actual recovery becomes much harder.
Step-by-step guide to freeze or hold funds after an online scam
1. Secure your own account first
Before chasing the scammer’s account, stop further loss from your own account.
Do these immediately:
- Change your online banking, e-wallet, email, and social media passwords.
- Log out all devices if the app or platform allows it.
- Disable or lock your card, online banking, or e-wallet if there is a “lock,” “freeze,” or “disable transfer” option.
- Call your bank or e-wallet’s official hotline only. Do not use numbers sent by the scammer.
- Tell the provider clearly: “My account may be compromised. Please restrict online access and prevent further outgoing transfers.”
This is different from freezing the recipient’s account. It protects your remaining funds.
2. Gather the transaction details before they disappear
Banks and e-wallets work faster when the report contains complete identifiers. Prepare:
| Information | Why it matters |
|---|---|
| Transaction reference number | Used to trace InstaPay, PESONet, QR, or wallet transfers |
| Date and exact time | Helps locate the transaction in logs |
| Amount sent | Used to identify the disputed funds |
| Source account or wallet | Shows where the money came from |
| Recipient bank/e-wallet name | Helps identify the receiving financial institution |
| Recipient account name, number, mobile number, or wallet ID | Needed for tracing and holding |
| Screenshots of chat, listing, profile, QR code, fake receipt, website, or SMS | Supports the fraud narrative |
| Police report, sworn complaint, or affidavit | Often needed to support extended holding |
Do not delete the conversation, even if it is embarrassing. Screenshot everything, including the scammer’s profile URL, username, mobile number, email address, payment instructions, and any promise of refund.
3. Report first to your own bank or e-wallet
Under BSP rules, the first-level recourse is the financial institution’s own Financial Consumer Protection Assistance Mechanism (FCPAM) or customer service channel. BSP’s current complaint guide says consumers should report first to the BSP-supervised institution before escalating to BSP-CAM.
Use the provider’s official fraud channel, app help center, hotline, or branch. The BSP also maintains a Directory of BSI Consumer Assistance Channels, updated as of March 10, 2026, for banks and other BSP-supervised institutions. (Bureau of the Treasury)
When reporting, be direct. Say:
“I am reporting a disputed transaction due to an online scam. Please initiate tracing and temporary holding of the disputed funds under RA 12010 and BSP Circular No. 1215, if funds are still available. Please give me a case reference number.”
Ask for these specifically:
- case reference number;
- confirmation that the report was received;
- whether an initial holding request was sent to the receiving financial institution;
- what documents are needed within the initial holding period;
- whether your own account access will be restricted for safety;
- when you can expect the next update.
Under BSP’s AFASA rules, once the originating financial institution receives a complaint or fraud finding, it verifies key details, prepares a disputed transaction report, preserves the source account when needed, and sends an initial holding request to receiving or subsequent receiving institutions if the funds moved outside its own system. (Bureau of the Treasury)
4. Submit a sworn complaint, affidavit, or police report within the initial hold period
This is a common bottleneck. Many victims report the scam quickly but fail to submit documents in time.
Under BSP’s AFASA rules, for extended holding, the source account owner should submit supporting documents such as a sworn complaint, affidavit, police report, or other supporting document within the initial holding period, unless the industry protocol provides otherwise. The document should explain the circumstances of the transaction and why the victim believes it is a disputed transaction. (Bureau of the Treasury)
A simple affidavit or sworn complaint should include:
- your full name, address, contact number, and valid ID details;
- your source account or e-wallet details;
- a chronological narration of what happened;
- the scammer’s name, username, account number, mobile number, or profile link, if known;
- the exact amount, date, time, and reference number of each transfer;
- screenshots or attachments;
- a statement that you did not intend to donate, gift, or freely transfer the money to the scammer;
- a request that the disputed funds be traced, held, and returned if verified as scam proceeds.
If you are abroad, prepare the same documents and ask the bank/e-wallet whether it accepts an electronically notarized affidavit, consularized document, apostilled document, or locally notarized foreign affidavit. Requirements vary because financial institutions have internal verification rules, especially when they must confirm that the complainant is the actual source account owner or an authorized representative.
5. File a cybercrime report with law enforcement
The bank/e-wallet process is for tracing and holding funds. A cybercrime complaint is for investigation, identity tracing, warrants, subpoenas, prosecution, and coordination with other agencies.
You may report to:
| Office | Practical role |
|---|---|
| PNP Anti-Cybercrime Group (PNP-ACG) | Cybercrime investigation, complaint intake, coordination with police units |
| NBI Cybercrime Division | Investigation of computer-related crimes and online fraud |
| CICC / National Anti-Scam Hotline 1326 | Central reporting and referral channel for scams and cyber fraud |
| DOJ Office of Cybercrime | Central authority and policy/legal coordination for cybercrime matters |
The NBI Citizen’s Charter for computer-crime assistance states that the general public may seek investigative assistance from the NBI Cybercrime Division, with preliminary interview, sworn statements, and collection of supporting documents as part of the process. (National Bureau of Investigation)
For urgent scam reporting, government sources identify 1326 as the National Anti-Scam Hotline / Inter-Agency Response Center hotline, and reports may also be made through the eGovPH eReport feature for scam-related complaints. (Dictionary)
When filing with law enforcement, bring or upload:
- valid government ID;
- proof of ownership of the source account or wallet;
- transaction receipts;
- screenshots of chats, posts, SMS, emails, websites, QR codes, and profiles;
- bank/e-wallet case reference number;
- affidavit or sworn narration;
- names and numbers of other victims, if any;
- the scammer’s known bank, e-wallet, mobile number, email, address, or social media handles.
6. Escalate to BSP if the bank or e-wallet does not act properly
If your bank or e-wallet does not respond, refuses to give a reference number, fails to explain the status, or mishandles the complaint, you may escalate to the BSP Consumer Assistance Mechanism.
BSP explains that its Consumer Assistance Mechanism is a second-level recourse for financial consumers after they have first reported to the BSP-supervised institution. New complaints may be filed through BSP Online Buddy (BOB), and if BOB is inaccessible, consumers may submit the CIR form and supporting documents by email.
When escalating to BSP, attach:
- your original complaint to the bank/e-wallet;
- the bank/e-wallet reference number;
- screenshots of follow-ups;
- transaction proof;
- affidavit or police report;
- explanation of what the institution failed to do.
BSP escalation is not the same as a criminal case. It is a regulatory consumer complaint. It is useful when the issue is the conduct of the bank/e-wallet, such as delay, lack of response, failure to follow its complaint process, or mishandling of disputed transaction procedures.
What happens after funds are temporarily held?
If the receiving bank or e-wallet successfully holds the funds, the money is credited in the beneficiary account but cannot be withdrawn during the holding period. BSP rules require the institutions to coordinate, trace the disputed transaction chain, verify information, communicate with account owners, and review supporting documents. (Bureau of the Treasury)
Possible outcomes include:
| Outcome | What it means |
|---|---|
| Funds are confirmed as scam-related | The holding institution may return the equivalent amount to the source account owner through the source institution |
| Beneficiary proves legitimacy | The hold may be lifted and funds released to the beneficiary |
| Funds were already withdrawn | The bank may document the withdrawal and provide tracing details, but recovery becomes harder |
| Funds moved to another institution | The originating institution may send holding requests down the transaction chain |
| A court order is obtained | Holding may be extended beyond AFASA’s administrative holding period |
BSP rules provide that after the initial or extended holding period lapses, or once the legitimacy of the transaction is confirmed, the institution should release the funds to the beneficiary unless there is a court extension, a written waiver, or the totality of information reasonably shows the funds are related to money muling, unlawful activity, illegal sources, social engineering, or similar grounds. (Bureau of the Treasury)
Importantly, AFASA also creates accountability for institutions. A BSP-supervised institution that fails to temporarily hold funds when required may be liable for loss or damage, including restitution. On the other hand, an institution that improperly holds funds beyond the allowable period may face administrative action. (Lawphil)
Court freeze orders and AMLC freeze orders are different
A private victim usually cannot walk into court and personally obtain an AMLC-style freeze order over the scammer’s bank account.
Under the Anti-Money Laundering Act, as amended, the Court of Appeals may issue a freeze order upon application by the Anti-Money Laundering Council (AMLC) and a finding of probable cause that the monetary instrument or property is related to unlawful activity. The Supreme Court has described AMLA freeze orders as extraordinary relief intended to preserve assets linked to unlawful activity. (Supreme Court E-Library)
In Manganip v. Republic of the Philippines, Powerlink.com Corp. v. Republic of the Philippines, and Codeworks.ph Inc. v. Republic of the Philippines, decided on May 20, 2025, the Supreme Court upheld the rule that AMLA freeze orders may cover related and materially linked accounts, but only with safeguards: the Court of Appeals must make an independent probable-cause finding, the freeze must be limited to the amount linked to the predicate offense, and the account holder may move to lift the freeze. (Supreme Court of the Philippines)
For an ordinary scam victim, this means:
- use the bank/e-wallet temporary holding process first;
- file with PNP-ACG, NBI, or CICC so investigators can pursue cybercrime and financial-tracing remedies;
- allow proper agencies to coordinate with BSP, AMLC, and prosecutors if the facts justify broader asset-freezing or money-laundering action.
Criminal laws that may apply to online scams
Online scams may involve several laws at the same time:
| Law | When it may apply |
|---|---|
| RA 12010, Anti-Financial Account Scamming Act | Money mule accounts, social engineering, selling or lending accounts |
| Revised Penal Code, Article 315 on estafa | Deceit or false pretenses caused the victim to part with money |
| RA 10175, Cybercrime Prevention Act of 2012 | The scam was committed through ICT, online platforms, electronic communications, or computer systems |
| RA 8484, Access Devices Regulation Act, as amended by RA 11449 | Credit card, debit card, account access device, online banking credential, or unauthorized access-device fraud |
| RA 9160, Anti-Money Laundering Act, as amended | Scam proceeds are laundered, layered, or moved through accounts or assets |
Article 315 of the Revised Penal Code punishes swindling or estafa, including fraud committed through false pretenses, fictitious names, imaginary transactions, or other similar deceits. (Lawphil)
Cybercrime procedures also matter because investigators may need electronic evidence, subscriber information, traffic data, device data, or platform records. The Supreme Court’s Rule on Cybercrime Warrants covers warrants and related orders involving preservation, disclosure, interception, search, seizure, examination, custody, and destruction of computer data under RA 10175.
Common mistakes that hurt recovery
Waiting until “tomorrow” to report
Scam funds often move quickly. Report even if you still feel unsure or embarrassed. You can submit additional documents later, but the first report creates the time stamp needed for tracing and possible initial holding.
Reporting only to Facebook, Telegram, WhatsApp, or the marketplace
Platform reports may help take down a profile, but they do not automatically hold bank or e-wallet funds. Report to your financial institution separately.
Saying “I authorized the transfer” without explaining the fraud
Many scams involve the victim personally sending money because of deception. Be accurate. Say:
- “I sent the money because I was deceived by a fake seller.”
- “I was induced by a fake investment page.”
- “I gave the OTP because the caller pretended to be from the bank.”
- “I was tricked into transferring funds to a money mule account.”
The legal point is not always whether you tapped “send.” The issue may be whether the transfer was caused by fraud, social engineering, or criminal deception.
Failing to submit an affidavit or police report within the initial period
The initial hold is short. BSP rules allow an initial hold of up to five calendar days, and supporting documents are important for extended holding. (Bureau of the Treasury)
Sending sensitive information to fake “recovery agents”
After a scam, victims are often targeted again by people claiming they can recover money for a fee. Do not give OTPs, passwords, card numbers, seed phrases, or remote access to anyone.
BSP’s complaint guide also warns consumers not to share PINs, passwords, account numbers, card numbers, passport details, or other sensitive identification information when submitting complaints.
Required documents, fees, and timelines
| Item | Usual requirement | Notes |
|---|---|---|
| Bank/e-wallet complaint | Free | File through official fraud hotline, app, branch, or FCPAM |
| BSP escalation | Free | Use BOB or CIR form after reporting to the institution first |
| NBI cybercrime assistance | No fee listed in the NBI Citizen’s Charter page for the complaint-assistance steps | Bring ID, sworn statement, evidence, and device if relevant |
| Affidavit or sworn complaint | Usually notarized if prepared outside the agency | Fees vary by notary; some law enforcement offices may assist with sworn statements |
| Police report or cybercrime complaint | Usually requires personal details and evidence | Ask for receiving copy, blotter entry, or complaint reference |
| Initial holding period | Up to 5 calendar days | Time-sensitive |
| Extended holding period | Up to 25 additional calendar days | Requires reasonable grounds and supporting documents |
| Total AFASA temporary holding | Up to 30 calendar days unless extended by court | Court order needed beyond AFASA administrative period |
| Coordinated verification if funds were held | Within the 30-calendar-day holding period unless court-extended | Banks/e-wallets coordinate and verify the transaction chain |
| Coordinated verification if no funds were held | Generally within 30 calendar days; may reach 60 calendar days for meritorious reasons under BSP rules | Useful for investigation even if recovery is unlikely |
Special situations
The scammer used GCash, Maya, ShopeePay, GrabPay, or another e-wallet
E-wallets are covered if they are BSP-supervised payment or financial service providers. AFASA expressly includes e-wallets in the definition of financial accounts. (Lawphil)
Report both ways:
- to your own source institution; and
- to the receiving e-wallet, if its official fraud channel allows direct reports from non-customers.
Still ask your own bank or e-wallet to initiate tracing because the formal chain usually starts with the source institution.
The money was sent through InstaPay or PESONet
Give the exact reference number and receiving institution. InstaPay transfers are fast, so delay is risky. The receiving account may already be emptied by the time the complaint is processed.
The scammer is abroad
Report anyway if your account is maintained with a Philippine institution, the receiving account is Philippine-based, or any element occurred in the Philippines. AFASA provides jurisdiction where any element was committed in the Philippines, where Philippine-based systems or infrastructure were used, where damage was caused to a person in the Philippines, or where the financial account is maintained with an institution operating in the Philippines. (Lawphil)
You are an OFW or foreigner outside the Philippines
You can still report to your Philippine bank/e-wallet using official online channels. For affidavits, expect additional identity checks. If a Philippine agency or bank requires a sworn document executed abroad, it may ask for notarization, consular acknowledgment, or apostille depending on where it was signed and how the document will be used.
The bank says it cannot disclose the recipient’s information because of privacy
Do not be surprised. Banks and e-wallets are cautious about disclosing personal data directly to private complainants. However, AFASA allows coordinated verification among covered institutions, and certain secrecy and data privacy restrictions do not apply during the coordinated verification process or BSP investigation within the scope of the law. (Lawphil)
In practice, you may receive limited information, such as whether funds were held, withdrawn, or transferred onward, rather than the full identity documents of the account holder. Law enforcement and BSP channels are used for deeper inquiry.
The bank refuses to return the money because you “voluntarily transferred” it
That is common in fake seller, fake investment, romance scam, and impersonation cases. The bank may argue that the transaction passed authentication. But under AFASA, the institution’s duties and possible restitution may still be examined if there was failure to employ adequate risk management systems or failure to exercise the required degree of diligence. AFASA also states that conviction is not a prerequisite to restitution in that context. (Lawphil)
This is why your complaint should focus on the full facts: deception, transaction pattern, mule account, speed of reporting, and whether the bank/e-wallet acted promptly.
Frequently Asked Questions
Can I personally freeze the scammer’s bank account in the Philippines?
Usually, no. A private victim normally starts by reporting to the bank or e-wallet so it can initiate temporary holding of disputed funds under AFASA. Court freeze orders under AMLA are sought by AMLC before the Court of Appeals, not directly by ordinary private complainants.
How fast should I report an online scam to my bank or e-wallet?
Immediately. The practical window may be measured in minutes or hours because scam proceeds can be withdrawn or transferred through several accounts quickly. Under BSP rules, the initial holding period is short, so early reporting and quick submission of documents matter.
What should I say to the bank or e-wallet?
Say: “I am reporting a disputed transaction caused by an online scam. Please trace the funds and initiate temporary holding under RA 12010 and BSP rules if the funds are still available. Please give me a case reference number.”
Do I need a police report before the bank freezes the funds?
Not always for the first report. AFASA rules allow complaint-initiated holding through the institution’s 24/7 fraud reporting channel. However, a sworn complaint, affidavit, police report, or similar supporting document is often important to support extended holding beyond the initial period.
How long can the bank or e-wallet hold the disputed funds?
Under AFASA and BSP rules, the temporary holding period is generally up to 30 calendar days, consisting of an initial hold of up to 5 calendar days and a possible extension of up to 25 calendar days. A further extension requires a court of competent jurisdiction.
Will I automatically get my money back if the account is frozen?
No. Holding funds is not the same as final recovery. The institutions still verify whether the transaction is truly disputed, whether the beneficiary can prove legitimacy, whether the money came from social engineering or illegal sources, and whether the funds are still intact.
What if the money was already withdrawn?
Report anyway. The bank or e-wallet may still document the transaction chain, identify receiving or subsequent receiving institutions, and provide information through proper channels. Recovery is harder, but the records may support a criminal complaint, BSP complaint, AMLC referral, or civil claim.
Can I file a small claims case to recover scam money?
Possibly, if you know the defendant’s identity and address and your claim is purely for payment or reimbursement of money within the small claims threshold. The Supreme Court has increased the small claims threshold to ₱1,000,000, exclusive of interest and costs. (Supreme Court of the Philippines) But many online scam cases are difficult for small claims because the scammer’s true identity or address is unknown, or because criminal investigation is needed first.
Is a barangay blotter enough?
A barangay blotter may help show that you reported the incident, but banks and cybercrime investigators often prefer a police report, cybercrime complaint, sworn statement, or affidavit with complete transaction details. For online scams, PNP-ACG, NBI Cybercrime Division, CICC, and your financial institution are usually more relevant than the barangay.
Can the bank tell me the scammer’s full name and address?
Not always. Financial institutions are careful with privacy and bank secrecy rules. Under AFASA, information-sharing can occur for coordinated verification, BSP investigation, and law enforcement purposes, but that does not mean the victim automatically receives all personal data of the recipient.
Key Takeaways
- Report the scam to your own bank or e-wallet immediately and ask for temporary holding of disputed funds under RA 12010 / AFASA.
- The initial hold may last only up to 5 calendar days, so submit an affidavit, sworn complaint, police report, or supporting documents quickly.
- AFASA allows a total temporary holding period of up to 30 calendar days, unless extended by court.
- A bank/e-wallet temporary hold is different from an AMLC Court of Appeals freeze order.
- File reports with PNP-ACG, NBI Cybercrime Division, CICC 1326, or other proper cybercrime channels to support investigation and possible prosecution.
- Escalate to BSP-CAM / BOB if the bank or e-wallet mishandles your complaint after you first reported to the institution.
- Screenshots are helpful, but transaction reference numbers, dates, amounts, account details, and sworn narration are often what move the case forward.
- Recovery is most realistic when the report is fast, the funds are still traceable, and the victim submits complete documents within the required period.