Legal Help for a Frozen Business Bank Account

What does this service cover?

When a company account is frozen, the problem is rarely one payment. It is payroll, suppliers, and whether the business can keep running. This service deals with the business side of a freeze, not the general guidance written for individuals.

It starts by finding out which authority froze the account, because the right response depends entirely on that.

Who froze the account?

An AMLA freeze under Section 50(1) is ordered by the Public Prosecutor when it suspects the money comes from crime ^[f1]. A police freeze under CPC Section 116D can be made by a Sergeant or above, straight away and without a court order ^[f4].

A bank compliance hold is different: it is the bank’s own internal review, and sometimes it can be settled without a lawyer at all.

Directors may be told very little when the freeze happens. So a lawyer’s first job is to work out which of these applies.

Can you release money for business expenses?

Section 44A lets an affected account holder apply in writing to the enforcement agency to change a freeze order and release money for reasonable living or business expenses ^[f2]. For a company, that can include payroll, rent and the payments that keep the business alive while the main matter is settled.

The application must show what the money is for and why the expense is reasonable. Preparing it properly matters more than filing it fast.

How do you keep the business running meanwhile?

A frozen account does not pause the company’s other duties. Directors still need to keep statutory filings up to date and tell staff and suppliers what is happening, even if they can only share a little.

Where possible, use the company’s other accounts that are not affected for essential payments. This buys time while the variation application or the investigation moves forward.

How long can a freeze last?

A section 44 freeze lasts up to 90 days unless you are charged. A section 50 order or seizure lapses after 18 months if no charge is brought in that time ^[f3]. The Court of Appeal applied the then 12-month limit in Lim Hui Jin v CIMB Bank Bhd & Ors [2018] ^[f6]. The limit has been 18 months since 1 March 2026.

Police freezes under CPC Section 116D lapse after 18 months without a prosecution. They are varied through a Sessions Court, not the enforcement agency. That is one reason to identify the type of freeze early.

What if the bank cannot fix it?

Bank Negara Malaysia’s BNMLINK line, 1-300-88-5465, is the official channel for banking complaints the bank has not resolved ^[f5].

But if your freeze is a police or AMLA order, not a bank decision, complaining through the bank will not move it. The bank is following an outside order that it cannot lift on its own.

What can this service not promise?

No lawyer can promise that a variation application will succeed, how much will be released, or how soon the money will be available. Each freeze is judged on its own facts. What you get is a properly prepared application and clear advice on what the business can reasonably do while the freeze lasts.

How do you get started?

Start with a consultation covering which bank froze the account, when it happened and which payments are stuck. From there, a lawyer can advise whether a written Section 44A application to the enforcement agency fits and which documents the business should prepare.

Sources

1. Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AMLA), Sections 44A, 50(1), 52A
2. Criminal Procedure Code (Amendment) Act 2024, Section 116D
3. Bank Negara Malaysia, BNMLINK complaints channel
4. Lim Hui Jin v CIMB Bank Bhd & Ors [2018], Court of Appeal