Frozen, restricted or closed: which one you have
People say "frozen" for at least 5 different things, and each is released a different way. Work out which you face before you call: confirming a card payment does nothing for a closure notice.
| What you see | Usual trigger | What releases it |
|---|---|---|
| Card declined or app locked | A login or payment from a new country | Confirming your identity, often in the app |
| Account restricted until you send documents | A periodic review, a returned letter or an unanswered recertification | The documents asked for, by the deadline |
| A letter giving a closing date | The bank no longer serves your country, or is ending the relationship | Usually nothing: move the money and complain if the reason is wrong |
| Account blocked at once, no reason given | A reported suspicion, a sanctions match or checks the bank cannot complete | The bank's own review, which it may not discuss |
| Funds held under an order | A court, a creditor or a tax authority | Paying or challenging the order |
Why banks freeze or close accounts after you move abroad
A bank must know who you are, where you live and why money moves through your account, and that duty continues after the account opens. EU anti-money-laundering law requires ongoing monitoring of every customer relationship, including scrutiny of transactions and keeping documents, data and information up to date (Directive (EU) 2015/849, Article 13). A move abroad puts most of that file out of date at once.
Closed because you live abroad: the account's residence terms
Many accounts are sold only to residents of the bank's own country or of a list of markets. Even the EU's basic payment account, which a bank cannot refuse to a legal EU resident only because they live in another member state (Your Europe), can be ended once the holder is no longer legally resident in the Union, or after more than 24 consecutive months without a transaction (Directive 2014/92/EU, Article 19). A checking account in your old country can survive a move, but only if its terms and the bank's license cover residents of your new one.
KYC checks the bank can no longer complete
EU anti-money-laundering law also makes banks repeat their checks on existing customers at appropriate times and whenever a customer's relevant circumstances change, and a bank that cannot complete them must not carry out transactions and must end the relationship (Directive (EU) 2015/849, Article 14). Letters returned from an old address, a phone number that no longer answers and a proof of address the bank cannot verify all stall that review.
Fraud systems react first. A login or card payment from a new country can lock the app until you confirm it was you, and a run of those blocks can tell the bank its picture of you is out of date.
Your CRS self-certification no longer matches
A bank in a country that exchanges data under the Common Reporting Standard normally holds a signed statement of where you are tax resident, taken when you opened the account; older accounts may rely on your address on file instead (OECD CRS commentary on Section IV, paragraph 2, and Section III, paragraph 13). A change in circumstances ends its validity on the date the bank knows or has reason to know of it. The bank may keep treating you as before for up to 90 days, and if it gets neither a new statement nor confirmation of the old one in that time, it must treat you as resident in both your old and your new country (OECD CRS commentary on Section IV, paragraphs 13 to 15).
The standard does not itself order a bank to close the account: the OECD notes that reasonable efforts to collect a missing tax number do not necessarily require closing, blocking or transferring it (OECD CRS commentary on Section I, paragraph 28). Banks restrict anyway, because a form that conflicts with their own records is a due diligence failure.
US citizens: FATCA and US indicia
Banks outside the US must report accounts held by US persons to the IRS under FATCA, directly or through their own country's tax authority (IRS FATCA page), so they search their files for signs of US status such as a US birthplace, address or phone number. The Government Accountability Office found that foreign banks closed some US persons' accounts or denied them new ones after FATCA was enacted, because of the costs and risks of the reporting (GAO-19-180).
Sanctions and high-risk countries
Banks screen every customer and payment against sanctions lists, and a match can block an account at once, without notice. Countries with weak money laundering controls draw extra questions rather than a block. In statements of June 19, 2026 the FATF called for countermeasures against North Korea and Iran and enhanced due diligence for Myanmar, and listed 22 jurisdictions under increased monitoring, among them Bulgaria, Monaco, Kenya and Vietnam (FINTRAC notice of July 15, 2026).
For a country on the EU's own high-risk list, which as of October 2026 includes Kenya, Monaco and Vietnam (European Commission), EU banks must collect more on you and on the source of your funds and wealth, ask the reasons for your transactions, get senior management approval to keep the relationship and monitor it more closely (Directive (EU) 2015/849, Article 18a). For other countries that credible assessments find lack effective controls, an EU bank must still count that as a higher-risk factor when it rates you (Article 18(3) and Annex III of the same directive). Living in a listed country is legal, but expect those questions on transfers in or out.
Letting review letters go to an address you have left
Review and recertification requests go to the address and phone number on file. If those still point to your parents' house or an apartment you gave up, the deadline passes unread, and the first you hear of it is a declined card in another country.
KYC for expats: what the bank asks for after a move
KYC, short for know your customer, is the name banks give these checks. After a move, expect most of the list below, and expect the bank to compare the answers: a foreign address that does not match the country on your tax form is what turns a routine review into a restriction.
Documents a bank asks for after you move abroad
- Your passport, and the residence permit or visa for your new country if you hold one.
- Proof of your new address: a recent lease, utility bill or local bank statement in your name.
- A new CRS self-certification naming every country where you are tax resident and your tax number in each.
- A tax residence certificate from your new country, if the bank doubts the form.
- Your occupation, your employer or main clients, and the payments you expect into the account.
- For a large deposit, the paper trail: a contract, invoices, a sale agreement or tax returns.
Send exactly what is asked, by the deadline, and keep copies. If you claim no tax residence anywhere, be ready to explain it, because an address on file is itself a reason for the bank to doubt that answer (OECD CRS commentary on Section IV, paragraph 25bis).
How to keep your account from being frozen when you move
Most of the freezes on this page start with a file the bank can no longer trust. Keep it accurate and most of them never happen.
- Ask before you go: in writing, whether the bank serves residents of your new country, and treat a vague answer as a no.
- Update the address and phone number with proof: as soon as you sign a lease, not when the bank asks.
- Recertify your tax residence: a new self-certification inside the 90 days keeps you from being treated as resident in 2 countries.
- Keep the number that receives security codes: a lost SIM locks you out of the app, and a locked app cannot answer a review.
- Use the account: a basic EU account can be closed after more than 24 months without a transaction.
- Hold a second account at an unrelated bank: the best bank for a digital nomad is usually one that serves the country you live in, and a backup keeps you paid during a review.
Moving from Germany to Portugal with a German account
Holds up
Lena asks her German bank 6 weeks before moving to Lisbon whether it keeps customers resident in Portugal. It does. She sends her Lisbon lease the week she signs it and certifies Portugal with her Portuguese tax number, and the review closes within days.
Breaks
Lena moves without asking. Her bank does not keep customers resident in Portugal, so her first address update brings a closing notice, and she has 2 months to open a Portuguese account and move her salary and every direct debit to it.
Moving the money to a bank in one of the non CRS countries fixes none of this. The problem is a file that no longer matches your life, and the new bank asks the same questions on day 1.
How to fix a frozen bank account abroad
Unfreezing an account from abroad
- Ask whether the account is under fraud review, restricted pending documents or being closed, and by what date.
- Get the request in writing: which documents, in what form, by which date and through which channel.
- Send exactly that, with a short note giving your move date, new address and new country of tax residence.
- If the account is closing, move the balance before the closing date to an account in your own name.
- If the reason is wrong or nobody answers, file a formal complaint and keep the reference number.
How much notice a bank must give before closing your account
In the EU a bank may end an open-ended payment account contract with at least 2 months' notice if the contract allows it (Directive (EU) 2015/2366, Article 55). The UK tightened its rules on April 28, 2026: for contracts made on or after that date the provider must give at least 90 days' notice, with reasons specific enough for you to understand why (Payment Services Regulations 2017, regulation 51B).
Minimum notice before a bank closes a payment account
| Account | Minimum notice | Reasons in writing |
|---|---|---|
| EU payment account | 2 months, if the contract allows termination | Not required by the directive |
| EU basic account closed for non-residence, inactivity or a second account | 2 months | Yes, with how to complain |
| EU basic account closed for illegal use or false information | None, effective immediately | The notice must say how to complain |
| UK account opened on or after April 28, 2026 | 90 days | Yes, specific enough to understand why |
| UK account opened before April 28, 2026 | 2 months, if the contract allows termination | Not required (regulation 51A) |
The UK's notice requirement does not apply in a short list of cases, among them a bank that cannot complete the customer due diligence the Money Laundering Regulations require, suspects a serious crime, must close the account under immigration law, or is directed to by the FCA, the Treasury or the Secretary of State (regulation 51C). An incomplete KYC file is the first exception on that list.
When the bank will not say why
A bank that has reported a suspicion is not allowed to tell you: EU law bars banks and their staff from disclosing to the customer that information has been or will be reported, or that a money laundering analysis is under way (Directive (EU) 2015/849, Article 39). Silence does not prove a report, but it explains why staff often cannot answer. Ask in writing which documents would let the bank finish its review.
Complaints: the ombudsman and the regulator
In the UK, a business has up to 8 weeks to answer most complaints, but 15 business days for complaints about payment services, such as a payment account closure, or up to 35 business days if the delay is beyond its control (FCA Handbook, DISP 1.6.2A R). You then have 6 months from its final response to take the case to the Financial Ombudsman Service, which costs you nothing (Financial Ombudsman Service).
In the EU, a notice closing a basic account must tell you how to complain and which competent authority and dispute resolution body to contact (Directive 2014/92/EU, Article 19). In the US, the Consumer Financial Protection Bureau takes complaints about checking and savings accounts, and most companies respond within 15 days (CFPB).
Getting your money back from a closed account
Closing the account does not cancel your claim to the balance. Give the bank an account in your own name, ideally in the same currency, and confirm the transfer in writing. If the closure follows checks the bank could not complete, expect it to want those documents before it releases the money.
When the frozen account belongs to your company
A company account goes through the same review when its owner moves, because the bank's due diligence covers the company's beneficial owner as well as the company itself (Directive (EU) 2015/849, Article 13). If the company is a passive entity under CRS, the bank also reports the people who control it to their own countries of residence (OECD CRS text), so the owner's new country belongs on the company's form as well as on their own.
Before an owner moves, check that the company's bank accepts owners resident in the new country: business bank accounts for non-residents each set their own list, and a move outside it can close the company account even though the company has not moved.
David's note
I answer every bank letter the week it arrives. A restriction that takes a week to clear with a lease and a tax number in hand can take months once the bank has stopped trusting the file, and by then you are explaining yourself from another time zone.
