Bank Account Freezes & AML Holds

Frozen Accounts, Payment Holds, Enhanced Due Diligence & Bank Compliance Reviews

Banks and payment providers may restrict accounts or suspend transactions while conducting AML, KYC, source-of-funds, fraud, sanctions, or other compliance reviews.

Friling Law assists businesses and individuals in understanding the basis for a compliance restriction and developing an organized legal and documentary response.

We assist with:

• Bank account restrictions and freezes
• AML compliance holds
• International payment holds
• Enhanced due diligence reviews
• KYC remediation
• Source-of-funds requests
• Source-of-wealth documentation
• Beneficial ownership questions
• Transaction explanations
• Bank compliance questionnaires
• Requests for supporting contracts and invoices
• Account closure and de-risking matters
• Distinguishing AML holds from OFAC blocking actions

Where appropriate, we can assist in presenting the commercial purpose, parties, ownership, source of funds, transaction history, and supporting documentation in a coherent compliance package.

AML & Financial Crime

Anti-Money Laundering, Financial Crime Compliance, Investigations & Enforcement

Friling Law advises U.S. and international businesses, financial institutions, fintech companies, payment providers, money services businesses, digital asset companies, investors, and individuals on U.S. anti-money laundering and financial crime laws.

Our practice combines AML/BSA compliance, FinCEN regulatory matters, KYC and beneficial ownership due diligence, financial investigations, cross-border payments, banking compliance, and OFAC sanctions. We assist clients in developing preventive compliance frameworks, responding to financial institutions and regulators, investigating potentially problematic transactions, remediating compliance deficiencies, and defending against regulatory and enforcement actions.

For international clients, we place particular emphasis on matters involving cross-border financial flows, U.S. dollar transactions, correspondent banking, high-risk jurisdictions, complex ownership structures, and the intersection between AML and U.S. economic sanctions.