Checks in progress
A payment may be held while the bank clarifies the parties, purpose or source of funds. Ask what can be provided and the reference for the request.
BANKING ISSUES · PRACTICAL GUIDANCE
Account blocked, transfer held or banking relationship terminated?
When a bank asks questions, the impact on your business can be immediate. Understand the situation, prepare accurate information and manage the dialogue professionally.
Explore real-world scenarios Describe the request you receivedFIRST, IDENTIFY THE ISSUE
A restriction is not always a legal freeze
Start with the bank’s actual message: which service is affected, what is being requested and by when? A delay alone does not reveal its cause.
Refusal or relationship closure
A refusal may reflect legal requirements or the bank’s commercial and risk policies. Identify the stated reason, notice and available complaint route.
Legal freeze or sanctions restriction
A binding legal measure has its own scope and procedures. A complete document pack cannot by itself lift it; legal advice may be needed.
Banks must understand their customers and monitor activity on a risk-sensitive basis. Higher-risk factors may call for enhanced checks; a sector or foreign connection alone does not prove wrongdoing. Technical or fraud-prevention checks may also explain a delay.
RECOGNISE YOUR SITUATION
Four sectors, different reasons for a bank to ask questions
These are illustrative situations, not actual client engagements or findings of suspicious conduct.
Gold dealers
A dealer making frequent precious-metal purchases and deposits faces restrictions on their account.
Why the bank may intervene
Discuss this situation The bank may review traceability, cash use and consistency of transactions.
Useful informationTransaction records, commercial documents and an explanation of funds flows.
Accountants and clients
A client receives a request for information or an account opening refusal.
Why the bank may intervene
Discuss this situation The bank may assess ownership, beneficial owners and expected activity.
Useful informationCorporate documents, contracts and business-model explanations.
Fresh-produce import/export
A business making frequent cross-border payments has a supplier transfer held.
Why the bank may intervene
Discuss this situation The bank may assess counterparties, high-risk jurisdictions, goods and economic purpose.
Useful informationInvoices, orders, shipping documents, contracts and supplier information.
Real estate
A payment linked to a property transaction is held for further checks.
Why the bank may intervene
Discuss this situation The bank may examine source of funds, parties and transaction structure.
Useful informationContracts, information on parties and relevant source-of-funds evidence.
THE CRITICAL MOMENT
The bank asks for an explanation. How do you respond?
Incomplete, inconsistent or unsupported information can leave legitimate questions unresolved. A clear reconstruction should explain what happened, why and what evidence supports it.
Understand the request
Reconstruct facts and documents
Prepare a coherent response
POSSIBLE OUTCOMES
What can happen next?
Transaction proceeds after checks
Further information or restrictions
Payment refused
Banking relationship terminated
Where legal thresholds are met, the bank may have a duty to file a suspicious transaction report with the competent authority. This is a separate, confidential process: a missing document does not automatically cause a report, and the bank may be prohibited from disclosing one. Legal freezes and sanctions restrictions are also distinct.
SPECIALIST SUPPORT
Protect business continuity through a well-prepared response
I help businesses and professional advisers understand requests, reconstruct transactions, identify missing evidence and prepare clear communications with intermediaries, within the agreed mandate.
Output to agree: a summary of the bank’s requests, missing information, a documented reconstruction and a response outline.
Describe your banking issue No guarantee of account reopening, payment execution or changes to the bank’s decision. Do not send confidential documents in your first enquiry.Rules depend on the jurisdiction
Italy applies Legislative Decree 231/2007 and UIF rules; Malta applies the PMLFTR and FIAU Implementing Procedures. Reporting goes to the UIF in Italy and the FIAU in Malta. The grounds, restrictions and available remedies must be assessed for the intermediary and measure concerned. This page does not establish a right to a business account or a payment-execution deadline.
Official references and scope
- Italy — Legislative Decree 231/2007, Articles 18–19, 24–25, 35, 39 and 42
- UIF — Instructions of 18 December 2025, Part I, Section IX.A: reporting and abstention
- Malta — FIAU Implementing Procedures Part I, April 2026: CDD and reporting
- EBA — risk management and access to financial services; no general guarantee of access
The EU AML Regulation 2024/1624 generally applies from 10 July 2027; it is not presented here as the current national framework.