In short. A Swiss bank account can be frozen for four reasons. The bank is checking where the money comes from, anti-money laundering law requires it to block the assets, the Public Prosecutor has ordered a seizure, or a foreign state has asked Switzerland for mutual legal assistance. The last three come with short deadlines, counted in days. The first step is to ask the bank, in writing, on what basis the account is blocked, and then to gather the documents that explain where the funds come from.
Your card is declined. Online banking still shows the balance, but no transfer goes through. On the phone, the relationship manager mentions “compliance” and will say nothing more.
The shortest deadline, ten days to appeal against a seizure, may start running as soon as you hear of the measure from your bank, without any letter from the authority. Hence the need to sort things out straight away.
First steps
On the same day, write to the bank. Ask on what basis the account is blocked and, if there is one, for a copy of the authority’s decision. Note what you are told on the phone, with date and time. Do not rush to move money out of your other accounts and do not ask a relative to receive payments for you, which reads very badly in a file.
Within forty-eight hours, put together a source-of-funds file. Statements for the last two years, contracts and invoices explaining significant incoming payments, payslips and tax assessments, deeds of sale of a property or a company. For crypto-assets, platform statements, wallet addresses and the tax returns that list them. For a company, the annual accounts and the main customer contracts. These are also the documents a lawyer will ask for at the first meeting.
In every case, keep one written version of the facts, the same for the bank, the prosecutor and, where relevant, the mutual assistance authority.
Where does the freeze come from?
Four situations, to be recognized from what you can observe. This is guidance, not certainty, and it does not replace reading the letters you have received.
The bank is asking about the source of the funds
This is the bank’s own compliance review. No legal deadline runs, but your answer is decisive. Reply in writing, once, with supporting documents.
The account is frozen overnight, with no question and no explanation
The Money Laundering Reporting Office (MROS) may have forwarded the file to a criminal authority, or a seizure may already have been ordered. The statutory freeze lasts five working days at most and may be followed by a seizure. Ask in writing whether an authority’s decision exists.
The bank mentions an order of the Public Prosecutor, or you receive one
This is a criminal seizure. An appeal must be filed within ten days of notification, or of the day you learned of the measure. Obtain the order and its reasons.
The bank tells you about a request from a foreign state
This is international mutual legal assistance. Depending on the Swiss decision concerned, the appeal deadline is ten or thirty days from its written communication. Elect a domicile in Switzerland and ask for the file.
If one of the last three situations matches yours, a first meeting makes it possible to check quickly which decision exists and which deadline is running. Two more ordinary situations are outside the scope of this article, an attachment ordered by the debt enforcement office and a simple lock of online banking access.
When the bank acts on its own
A transfer from abroad, a deposit from a crypto platform, an amount out of line with what the bank knows about you, and a list of questions arrives. The bank has no choice. It must clarify the background and purpose of any transaction that appears unusual, unless its legality is obvious (Art. 6 para. 2 AMLA).
What clients tend to underestimate is the weight of their answer. If the clarifications do not dispel the suspicion, the bank must report to the Money Laundering Reporting Office Switzerland, the MROS (Art. 9 AMLA). Implausible explanations by the client are, incidentally, among the indicators of money laundering listed in FINMA’s regulations. In other words, your answer to the bank often decides what happens next. A vague, partial or purely oral answer can tip a file that had nothing criminal about it.
Two more rules. The bank may not tell you that it has reported to the MROS (Art. 10a AMLA), so an evasive answer is already information. And a report does not, by itself, freeze the account. While the MROS analyzes it, the bank keeps executing your instructions, in a traceable form for significant amounts (Art. 9a AMLA). A complete freeze without any authority’s decision therefore rests, in principle, on the contract (general terms, update of the client file) rather than on anti-money laundering law.
If the bank maintains the freeze without a reason, a written complaint and then the Swiss Banking Ombudsman remain available.
When the MROS forwards the file
The bank’s report is not enough to trigger the statutory freeze. The MROS must have forwarded the file to a criminal prosecution authority and notified the bank (Art. 10 para. 1 AMLA). The bank then blocks the assets linked to the report until that authority decides, for five working days at most (Art. 10 para. 2 AMLA).
This period cannot be extended, as the Commentaire romand on the AMLA makes clear. It does not guarantee release either. If the prosecutor wants to keep the funds, a seizure order is issued, and you move to the next situation. These few days are therefore for assembling the source-of-funds file and instructing a lawyer, so as to react as soon as the order is made.
Another scenario. If the MROS does not forward the file within 40 working days of the report, the bank may terminate the relationship (Art. 9b AMLA). Significant amounts then leave only in a traceable form. Opening an account in your own name with another bank right away lets you request a transfer rather than a withdrawal.
When the Public Prosecutor has ordered a seizure
A seizure is ordered by a written order with brief reasons (Art. 263 para. 2 CrimPC). It is very often served on the bank alone, with a prohibition on telling you. In a case decided in Geneva in January 2025, that prohibition, backed by the threat of Art. 292 SCC, ran for three renewable months (ACPR/19/2025 of January 8, 2025).
The appeal deadline is ten days (Art. 396 para. 1 CrimPC). Criminal procedure has no court holidays, and the appeal does not suspend the seizure. Where the order was served only on the bank, the deadline runs from the day you learn of the measure (ACPR/19/2025, consid. 1.2.2).
One point almost always comes as a surprise. A seizure can hit clean money. The Criminal Procedure Code allows assets to be seized to cover procedural costs and fines, or a compensatory claim of the State (Art. 263 para. 1 let. b and e CrimPC), and neither purpose requires a link with the offense. A seizure to cover costs may, however, only target the accused’s assets, taking into account their income and family, and never assets exempt from attachment (Art. 268 CrimPC). Proving the lawful origin of the funds therefore remains essential, without always being enough.
What to do, in this order.
- Ask the Public Prosecutor in writing for the order and its reasons. An order silent on the offenses was held to have been cured on appeal, because the account holder had not asked for the reasons (ACPR/19/2025, consid. 2.2 and 2.3).
- Ask for access to the file.
- Appeal within ten days if the order is open to challenge.
- Apply for the seizure to be lifted, with supporting documents. A seizure is lifted when its ground disappears (Art. 267 para. 1 CrimPC). Only the legal holder of the account may apply, not the beneficial owner or the shareholder. For a company account, the company itself must act.
- Apply for a partial release for rent, salaries, taxes or defense costs. Such requests are often decided on a simple letter.
- Challenge the amount rather than the suspicion. The sum seized must remain proportionate to the proceeds of the offense (Federal Supreme Court 7B_879/2025 of January 30, 2026, consid. 2.2.3), an argument that often stands a better chance than contesting the suspicion itself.
Then there is duration. No statute sets a limit, and time rarely works for an account holder who waits. In 2025, the Federal Supreme Court upheld a seizure ordered in 2015, in a case with twenty-seven complainants, noting that the appellants had not pressed the prosecutor during the periods of inactivity they complained of (Federal Supreme Court 7B_1455/2024 of April 30, 2025, consid. 4.3.2 and 4.3.3). At the end of 2025, the Geneva Criminal Appeals Chamber maintained a CHF 100,000 seizure against an accused living abroad, even though a dismissal had been announced (ACPR/1052/2025 of December 12, 2025). The accused had let an earlier order maintaining the seizure become final. Two habits follow, pressing the prosecutor during every quiet period and appealing every order that maintains the seizure.
When a foreign state requests mutual legal assistance
A foreign authority is investigating and asks Switzerland for bank documents, sometimes for the account to be frozen. The Swiss authority executes the request without re-running the foreign investigation, which narrows the arguments on the merits but leaves procedural rights intact.
The bank is entitled to inform you of the request, unless the authority has expressly prohibited it (Art. 80n IMAC). That first notice matters, because a person who steps in late can no longer challenge a closing decision that has become final.
If you live abroad, the authority will serve its decisions on you only if you have elected a domicile in Switzerland (Art. 80m IMAC), in practice with a lawyer. That is the first step.
Persons entitled may then inspect the file and take part in the proceedings (Art. 80b IMAC). This is the stage at which the scope of what will be sent abroad is discussed. Simplified execution, sometimes proposed, saves time, but consent is irrevocable (Art. 80c IMAC). It should never be given without seeing the documents.
Deadlines depend on the Swiss decision concerned and run from its written communication. Ten days against a seizure ordered during the proceedings, which can be challenged separately only if it causes immediate and irreparable harm. Thirty days against the closing decision ordering transmission abroad, an appeal that suspends the transmission (Art. 80e, 80k and 80l IMAC). Beyond that, the Federal Supreme Court only hears particularly important cases, within ten days (Art. 84 and 100 para. 2 let. b FSCA).
For foreign counsel, the Swiss proceedings do not decide the foreign case and are best run hand in hand with the client’s lawyer in the requesting state. What helps most on the Swiss side is a copy of the foreign request if available, the charges, the stage of the foreign proceedings, and instructions early enough to elect a Swiss domicile and meet the ten and thirty day deadlines.
Deadlines at a glance
- Five working days at most for the statutory freeze, from the MROS notice to the bank (Art. 10 para. 2 AMLA).
- Ten days to appeal against a seizure order, from notification, or from the day you learned of it if it was served only on the bank (Art. 396 para. 1 CrimPC).
- Ten days to appeal against a seizure ordered in mutual assistance, from written communication of the decision (Art. 80k IMAC).
- Thirty days to appeal against the closing decision in mutual assistance, from its written communication (Art. 80k IMAC).
- Ten days to bring a mutual assistance case before the Federal Supreme Court (Art. 100 para. 2 let. b FSCA).
- Forty working days after the report to the MROS, without any forwarding on its part, the bank may terminate the relationship (Art. 9b para. 1 AMLA).
Each deadline applies only to the decision it concerns. If in doubt about the nature of a letter, go by the shortest.
Frequently asked questions
Can the bank freeze my account without telling me why?
It may not tell you that it has reported to the MROS (Art. 10a AMLA). It may, however, tell you that an authority’s decision exists, unless that authority has prohibited it. A freeze without any decision rests in principle on the contract, and that is the ground on which it can be challenged.
How long can an account remain seized?
There is no maximum duration. The seizure must remain proportionate, which means the investigation must move forward. Yet in 2025 the Federal Supreme Court upheld a seizure ordered ten years earlier, because the account holders had not pressed the prosecutor.
Can I pay my rent, salaries or lawyer from a seized account?
A partial release can be requested from the Public Prosecutor, with a budget and supporting documents. Such requests are often decided on a simple letter.
I live abroad. Will I be informed of a mutual assistance request concerning my Swiss account?
The bank may inform you of the request, unless expressly prohibited (Art. 80n IMAC). The Swiss authority will serve its decisions on you only if you have elected a domicile in Switzerland (Art. 80m IMAC).
I have done nothing wrong. Do I still need to act?
Yes. Lawful assets can be seized to cover costs or a compensatory claim, and appeal deadlines run in every case.
My bank is ending the relationship. What happens to my assets?
If the MROS has not forwarded the file within 40 working days, the bank may terminate the relationship (Art. 9b AMLA). Significant amounts then leave in a traceable form, in practice by transfer to an account in your name.
Legal basis and case law
Anti-money laundering: Art. 6 para. 2, 9 para. 1 and 1quinquies, 9a, 9b, 10 and 10a of the Anti-Money Laundering Act (AMLA). Seizure: Art. 89 para. 2, 263, 267, 268, 387 and 396 of the Criminal Procedure Code (CrimPC). Mutual assistance: Art. 80b, 80c, 80e, 80k, 80l, 80m and 80n of the Federal Act on International Mutual Assistance in Criminal Matters (IMAC), Art. 84 and 100 para. 2 let. b of the Federal Supreme Court Act (FSCA).
Case law: ACPR/19/2025 of January 8, 2025 (seizure served on the bank alone, appeal deadline, reasons), ACPR/1052/2025 of December 12, 2025 (seizure to cover costs maintained), Federal Supreme Court 7B_879/2025 of January 30, 2026 (amount seized), Federal Supreme Court 7B_1455/2024 of April 30, 2025 (duration of the seizure). Commentary: Commentaire romand, AMLA, on Art. 9 and 10.
On this type of case
When the freeze stems from criminal proceedings, see our page criminal defense lawyer in Geneva.
If the frozen funds come from a fraud of which you are the victim, see our page fraud and asset recovery lawyer in Geneva.
These matters are decided in the first days, between the bank, the prosecutor and sometimes a foreign authority. A first meeting identifies where the freeze comes from, which deadlines are running and what can usefully be done, on the basis of the documents listed above. It does not prejudge the outcome. Sentinel Legal handles white-collar criminal proceedings, seizures and international mutual assistance, in English and French. See also Money mule in Switzerland and Summoned to a hearing. To discuss a situation: +41 22 512 76 00 or via the contact form.