Why Accounts Get Blocked — Two Different Mechanisms
When a bank holds your operations and the account is effectively blocked, the first task is to know exactly which mechanism is at work, because your steps follow from that. The first and most regulated mechanism is an instruction of the head of the Financial Monitoring Service of Georgia to suspend a transaction — a written order that obliges the bank to suspend the preparation, conclusion or performance of the transaction. The second mechanism is the bank's internal control: the law obliges the accountable person — the bank — to submit a report to the Financial Monitoring Service on a suspicious transaction, or on its preparation or attempt, on the very day a substantiated suspicion arises, and it is against the background of such an assessment that banks often restrict operations on their own. A third boundary must also be kept in mind: a blocking is not a seizure. The seizure of an account is a different enforcement-law mechanism governed by other rules; what we deal with here is the anti-money-laundering law.