What should a UAE company do if its bank account is frozen or closed?

Preserve the bank notice, identify exactly what has been restricted and submit one coherent evidence pack through the bank’s official channel. At the same time, protect payroll, tax, customer and supplier obligations without routing around a bank restriction, sanctions control or authority order. A restriction, a bank-initiated closure and a legal freeze are different incidents and require different responses.

The UAE Central Bank’s current customer-due-diligence framework requires licensed financial institutions to understand and monitor customers on a risk-sensitive basis. Its Source of Funds and Source of Wealth guidance explains that evidence requirements increase with risk. That does not mean every restriction is a KYC problem, and it does not entitle a customer to the bank’s confidential controls or analysis.

Establish what actually happened

Record the wording, date, channel and scope of the bank’s communication. Distinguish:

Do not describe the incident as a “Central Bank freeze” unless the bank or competent authority has actually said so. Screenshots and call-centre summaries should be preserved, but the written notice and account terms carry more evidential weight.

First 24-hour evidence pack

Build a dated file containing:

1. bank notice and all reference numbers;
2. trade licence, constitutional documents and current ownership/UBO records;
3. authorised-signatory and manager evidence;
4. tax registrations and recent filings relevant to the activity;
5. contracts, invoices, shipping or delivery evidence for questioned payments;
6. source-of-funds and source-of-wealth evidence where requested;
7. explanation of unusual counterparties, countries, values or transaction patterns;
8. current website, business model and expected-flow description;
9. earlier KYC submissions and the bank’s acknowledgements;
10. a chronology of every contact with the bank.

Answer the bank’s questions directly. A large unsorted data dump can conceal the connection between a payment and its commercial basis. Use a cover note that maps each question to the relevant attachment.

Check corporate-record mismatches

Compare the bank profile with the company’s current licence, activity, address, owners, managers, signatories, tax data and expected flows. Common mismatches are diagnostic prompts, not assumed reasons for the restriction:

• an expired or amended licence not reflected in bank records;
• a new owner, manager or signatory;
• activity or geography that differs from onboarding information;
• payments inconsistent with the described product;
• unexplained related-party or personal-account transfers;
• missing evidence for initial capital or a material transaction.

If a record is wrong, correct it through the competent authority and explain the sequence. Do not backdate or manufacture supporting material.

Protect operations lawfully

List payroll, tax, rent, insurance, customer refunds and critical suppliers by deadline. Notify decision-makers and obtain advice before changing payment instructions. Alternative banking or collection arrangements must be legitimate, documented and consistent with contracts, tax, AML and sanctions obligations.

Do not split, disguise or reroute transactions to avoid a restriction. Do not ask customers to pay an employee or shareholder personally merely because the corporate account is unavailable.

Escalate through the bank first

Use the bank’s formal complaint or escalation channel and request written confirmation of receipt. State the remedy sought: clarification of required evidence, access to statements, review of a restriction, treatment of incoming payments, or instructions for transferring a closing balance.

Keep the operational request separate from allegations. If the bank gives a response, assess whether it resolves the practical issue and whether another legal or regulatory route is available.

Sanadak is available only within its scope

Sanadak’s current eligibility page covers natural persons, sole proprietors and small-to-medium enterprises that first complained to the licensed financial institution and then waited 15 calendar days without a written response or received an unsatisfactory response. Other conditions apply.

The same page says a complaint may be rejected where it materially concerns the institution’s risk management, internal pricing or AML policies and practices. Sanadak is therefore not a universal appeal against every corporate-account closure or compliance decision.

For evidence remediation and a new bank-readiness strategy, use UAE corporate bank-account support.