Frozen Accounts and Crypto in the UAE: Who Froze It and How to Challenge It
A frozen account is rarely explained at the moment it happens. The bank or the exchange says only that funds are blocked and asks for documents. Yet the first question decides everything that follows: who ordered the freeze, under what power, and for how long. Three different regimes are at work in the UAE, each with its own timing and its own route of challenge, and the wrong assumption at the start usually costs the only window the law provides.
The law that now applies
The governing instrument is Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing, which repealed and replaced Decree-Law No. 20 of 2018 and came into force on 14 October 2025. Its executive regulations, Cabinet Resolution No. 134 of 2025, replaced Cabinet Resolution No. 10 of 2019 with effect from 14 December 2025. The new framework expands predicate offences, introduces standalone proliferation-financing offences and covers digital systems and virtual assets expressly. Anything written about UAE freezing practice before late 2025 has to be read against the new text, and the transitional position for matters opened under the previous law is itself a question that has to be checked file by file.
Scenario one: an administrative freeze by the FIU
The head of the Financial Intelligence Unit may act without any prior notice to the client. A suspicious transaction can be suspended for up to ten working days on the basis of the Unit analysis of suspicious transaction reports or of information received from local or foreign counterparts. Funds held with financial institutions, with designated non-financial businesses and professions such as lawyers, auditors, real estate brokers and precious-metal dealers, or with virtual asset service providers, can be frozen for up to thirty days, with extension by the Attorney General or a delegate. Under the executive regulations the Unit notifies the institution and the Attorney General; the institution in turn notifies the account holder and asks for documents proving the lawful origin of the funds. That request is not a formality — it is the first submission on the record.
Scenario two: seizure by the Public Prosecution or the court
In a criminal investigation the Public Prosecution and the competent court may, again without prior notice to the owner, identify, trace, value, seize or freeze suspected criminal property or assets equivalent to its value, prohibit its management or disposal, and impose a travel ban lasting until the investigation or trial ends. The general procedural regime for precautionary measures over suspect property under the Criminal Procedure Law applies in parallel. One provision deserves particular attention: any transaction whose purpose is to move assets beyond the reach of seizure or confiscation is void by operation of law where the parties knew or should have known of that purpose, with the rights of bona fide third parties preserved. Attempts to restructure ownership after a freeze therefore tend to produce a second problem rather than a solution.
Crypto: custodial and self-custody are not the same problem
The statutory definition of funds covers electronic, digital and crypto assets, and virtual asset service providers licensed in the UAE sit inside the same freezing regime as banks: an order reaches the platform and the balance stops moving. Assets held in self-custody are a different technical position, because there is no intermediary to serve, but that is not a safe harbour — dealings in anonymising instruments and mixers are themselves criminalised under the 2025 Law, and the equivalent-value mechanism allows the prosecution to reach other assets of the same person instead. In practice the realistic route for a client whose exchange balance is blocked is documentary rather than technical: establishing the origin of the holdings, the chain of acquisitions and the compliance history of the platform relationship.
The challenge, and the window it runs in
The freeze and seizure decisions are challenged by a written grievance (تظلم) available to every interested person, not only to a suspect: a spouse, a company whose account is blocked, or a buyer whose property is caught by the order may all bring it. It is filed with the criminal court in the district of the prosecution that issued the decision, or with the court competent for the substantive case, and it may be directed at the seizure, at the prohibition on disposal, or at an extension granted by the Attorney General. The court must decide within fourteen working days of filing, and its decision is final and not subject to appeal. Where the grievance is rejected, a fresh one cannot be filed for three months unless new and serious grounds appear. Confiscation itself is a criminal penalty and follows the ordinary appellate and cassation route together with the judgment.
When the order comes from abroad
A significant share of freezes in the UAE originate in a foreign request. The 2025 Law obliges the competent judicial authorities, on the request of a foreign court, to identify, trace, value, seize, freeze or confiscate assets or their equivalent value, and expressly permits execution of a foreign order for provisional measures or confiscation without a domestic investigation where the order was issued by a competent foreign court. Co-operation may not be refused on the ground that the offence is fiscal, financial or customs-related, that banking or professional secrecy applies save for legitimate legal privilege, or that the act is classified differently in UAE law. The practical consequence is blunt: a client with assets in the UAE should assume that a properly channelled request from a partner jurisdiction will be executed, and should build the defence on the merits of the underlying case and on bona fide third-party rights rather than on formal objections.
The first days, in order
Do not argue with the bank or the exchange: they are executing an order and cannot lift it. Establish which authority issued it — the Financial Intelligence Unit, the Public Prosecution or a court — through a formal enquiry, because the answer determines both the deadline and the forum. Assemble the source-of-funds and source-of-wealth file properly the first time: contracts, bank statements, tax filings, sale agreements, inheritance documents. Keep to the grievance window rather than waiting for the investigation to develop. Check the position of connected persons and structures, since the equivalent-value and third-party mechanisms reach spouses, nominees and offshore vehicles. And avoid any disposal intended to protect the assets — that route is void by law and can create a separate offence.
How we work on these matters
We act for account holders, companies and third parties whose assets are caught by an order. The work begins by identifying the issuing authority and the legal basis, then assembling the source-of-funds record to the standard the file requires, then filing the grievance within the statutory window and appearing on it. Where the freeze sits alongside a criminal investigation, a travel ban or a foreign request, those tracks are run together, because the submissions made in one become the record in the others. Matters are handled in Russian, English and Arabic. This material states federal legislation as at September 2026, after the entry into force of the 2025 Law and its executive regulations, and is general information rather than advice on a particular matter; practice under the new provisions is still forming, and the position in a specific file should be checked before any step is taken.
Where we handle matters like this
Financial Crime, Crypto & Asset Recovery
Account blocking, AML checks, requests for source of funds. We formulate a position that resolves the regulator's questions rather than creating new ones.
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Defence in criminal proceedings in the UAE: fraud, breach of trust, embezzlement, cybercrimes. We enter the case at any stage — from the first interrogation to appeal.
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