A frozen company account is not an accident but an order with an origin: a court, the tax authority, investigators, or the bank itself under anti-money-laundering controls. The fastest route to unfreezing is not a complaint call — it is identifying exactly who ordered the freeze and on what basis.
Four common lawful sources of a freeze
The first source is a court’s interim emergency measure under Articles 111 and 114 of the Civil Procedure Code 92/2015/QH13, when a counterparty sues and seeks security for enforcement. The second is tax enforcement under the Tax Administration Law 108/2025/QH15: debiting the account or freezing it where tax debts are overdue. The third is an investigative agency’s request in a criminal case touching transactions through the account. The fourth is the bank’s own freeze under the Anti-Money-Laundering Law 14/2022/QH15 and the account agreement where transactions look suspicious or customer identification has lapsed — with Decree 52/2024/ND-CP on non-cash payments as the general frame for closing and freezing payment accounts.
Unfreezing follows whoever issued the order
Each freeze can only be lifted through the mechanism that created it: a court freeze needs a decision cancelling the interim measure or substituting other security; tax enforcement needs payment in full or an approved instalment or deferral decision; an investigative freeze needs the agency’s written release; and a bank’s internal hold usually needs only refreshed identification files, transaction explanations and updated company information. The most expensive mistake is suing the bank while the order came from a state body — in those cases the bank merely executes and has no power to self-release.
First moves inside 48 hours
- Require the bank to state the freeze basis in writing: decision number, issuing authority, scope and duration — notification is the account holder’s right.
- Mirror-freeze upcoming payment obligations and proactively inform major counterparties to prevent cascading contract breaches.
- Open a lawful backup payment channel through another company account while resolving the freeze; never route company money through personal accounts to evade it.
Frequently Asked Questions
Why was the account frozen?
Usually one of four bases: a court interim emergency measure, tax enforcement over overdue debts, an investigative agency’s request, or the bank’s own hold under anti-money-laundering controls and the account agreement within the Decree 52/2024/ND-CP frame.
How is it unfrozen?
By resolving the matter with the authority that ordered it: ask the court to cancel the measure or accept substitute security, pay the tax or obtain an instalment decision, obtain the investigators’ written release, or complete identification and transaction explanations for the bank.
Should we sue the bank?
Only where the bank froze on its own without legal or contractual basis and caused loss. Where the freeze follows a state order, the bank is merely the executor — suing it does not lift the freeze.
Can we switch banks?
Other accounts can carry flows that are not frozen, but court and tax freeze orders are commonly served across banks and the underlying debt still has to be settled; changing banks does not erase the freeze basis.
This article has been quality-reviewed by the FLAW AI Legal Council