Blocked bank transfer in Spain: what to do

If the bank has held a transfer you are sending or receiving, it most often needs to check where the money comes from or what it is for. Law 10/2010 prevents it from executing transactions if it cannot apply due diligence (Art. 7(3)). We tell you what the bank is asking for, prepare the documents and, if it does not respond, file a complaint.

Transfer on hold? We’ll tell you what to do

Tell us the amount, the date, whether you are sending or receiving it and what the bank has told you, and we will guide you.

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First step
Ask in writing what is missing
Customer service deadline for payments
15 business days
After customer service
Bank of Spain
Spanish law
Law 10/2010, Art. 7(3)

From a held transfer to money you can use

The first thing is to find out which bank is holding the transfer and what it is missing. Then, to give it exactly that, all at once.

LocatePhase 1

Where it is stuck

With the receipt and the reference, we find out whether it is being held by your bank, the other party’s bank or an intermediary.

The detail that changes everything.
ReasonPhase 2

Why it has stopped

We determine whether it is a source-of-funds review, a problem with the payment order details, a match with a sanctions list or a garnishment.

Each cause has its own path.
EvidencePhase 3

The documents

We gather proof of the source and the purpose of the transfer: contracts, invoices, deeds, pay stubs or bank statements.

A complete chain.
ResponsePhase 4

A dossier for the bank

We send the documents in order, with a clear explanation of the transaction, and keep proof of delivery.

Everything at once.
ComplaintPhase 5

If the bank does not respond

We prepare the complaint to the bank’s customer service department and then to the Bank of Spain.

Through the proper channels.
AccountPhase 6

If your account is closed

If the bank decides to end the relationship, we help you recover the balance and prepare to open an account with another institution.

Without losing the money.

Why the bank holds a transfer

The cause determines the path: a source-of-funds review is not resolved the same way as a garnishment.

Source

The bank does not know where the money comes from

A large amount, or one that differs from your usual transactions, requires the bank to ask where it comes from.

Purpose

It does not know what the transfer is for

A payment to a new recipient or to another country may lead the bank to ask for the contract or the invoice.

Lists

The name matches a sanctions list

If the payer or the payee matches a sanctioned person, the bank has to check this before executing the transfer.

Garnishment

There is a garnishment on the account

If the block comes from the Tax Agency, Social Security or a court, the way forward is through the body that ordered it.

A held transfer, by the numbers

Figures from Law 10/2010, Regulation (EU) 2023/1113 and the rules on bank complaints.

Law 10/2010, Art. 7(3) No transaction

The bank does not execute transactions if it cannot apply due diligence, and it bears no liability for this unless there is unjust enrichment.

Law 10/2010, Art. 19 Duty to refrain

Where there are signs of money laundering, the bank refrains from executing the transaction and reports it to SEPBLAC.

Law 10/2010, Art. 24 Confidentiality

The bank cannot tell you whether it has reported the transaction to SEPBLAC.

Regulation (EU) 2023/1113 Data

The transfer must carry the payer’s name, account and address, and the payee’s name and account.

Royal Decree-law 19/2018, Art. 69 15 business days

Deadline for the customer service department to respond to a complaint about payment services.

Law 44/2002, Art. 30 1 month

General deadline for the customer service department to respond; after that, the Bank of Spain.

Has the bank been holding your transfer for days?

We tell you what the bank is missing and how to submit it so that it releases the transfer.

Blocked bank transfer: common questions

Why has the bank blocked my transfer?

Most often, the bank needs to check where the money comes from or what it is for before executing it. Law 10/2010 requires the bank to review transactions, including the source of funds (Art. 6), and prevents it from executing them if it cannot apply due diligence (Art. 7(3)). It may also hold the transfer if information is missing from the payment order or if the name matches a sanctions list.

What documents can I be asked for?

Those that explain the transaction: the contract or invoice that justifies the payment, and proof of the source of the money (pay stubs, deeds, inheritances, sales, bank statements). If the transfer comes from abroad, also the receipts for the transfer and for the currency exchange.

How long can the bank hold the transfer?

Law 10/2010 does not set a deadline for the bank to review the documents: the block lasts until it can complete due diligence. That is why it is best to reply with everything at once and, if the bank does not respond, to file a complaint.

Does the bank have to tell me the reason?

Not always. Article 24 of Law 10/2010 prohibits it from disclosing that it has reported information to SEPBLAC or that it is examining the transaction. What you can do is ask it to specify which documents it needs.

Can the bank close my account?

Yes. If it cannot apply due diligence during the business relationship, the bank must end it, and it bears no liability for this unless there is unjust enrichment (Article 7(3) of Law 10/2010). Even so, the balance is yours: the question is how it will be returned to you.

What if the transfer involves cryptocurrency?

If the money comes from an exchange or from selling crypto-assets, the bank will want to see its full trail. We explain this in bank account blocked over cryptocurrency and proving the source of your crypto.

What if it comes from China or the UAE?

The substance is the same, but the documents change: China applies the Apostille and has exchange controls; the UAE does not apply the Apostille. We cover this in blocked transfer from China to Spain and blocked transfer from the UAE to Spain.

How do I file a complaint if the bank does not respond?

First with the bank’s customer service department: 15 business days for payment services (Article 69 of Royal Decree-law 19/2018) and one month for all other matters (Article 30 of Law 44/2002). If it does not respond or you disagree with its answer, you can then go to the complaints service of the Bank of Spain.

What to do if the bank holds your transfer

The steps, in order, to find out what is happening and what you need to provide.

First

Find out the reason

Source of funds, payment order details, sanctions lists or a garnishment: each cause has its own path.

Next

Ask for the list in writing

Getting the bank to specify which documents it needs saves you from submitting them piecemeal.

Finally

Reply with everything

A complete, well-organized dossier is what shortens the block the most.

Your transfer in 10 steps

  1. Get the transfer receipt and its reference.
  2. Ask your bank whether it is holding the transfer or whether it is at another bank.
  3. Ask in writing what information or documents it needs.
  4. Check whether there is a garnishment on the account: if there is, the path is different.
  5. Check that the payer and payee details match your documents.
  6. Gather the contract or invoice that explains the reason for the payment.
  7. Gather proof of the source of the money and the statements that show its trail.
  8. Submit everything together, with a short explanation of the transaction, and keep the acknowledgment of receipt.
  9. Do not repeat the transfer while the first one is still being held.
  10. If there is no response in time, file a complaint with the customer service department and then with the Bank of Spain.

Source: Law 10/2010 (Arts. 6, 7, 19 and 24), Regulation (EU) 2023/1113, Royal Decree-law 19/2018 (Art. 69) and Law 44/2002 (Art. 30).

Working glossary

Key terms for a blocked bank transfer

These terms come up in the bank’s messages and in Law 10/2010.

CDDObligation

Due diligence

Measures the bank uses to identify the customer and check their transactions.

Law 10/2010, Arts. 3–7.
SourceProof

Source of funds

Where the money in the transfer comes from.

Law 10/2010, Art. 6.
ExaminationAnalysis

Special examination

A written analysis of an unusual transaction or one with no apparent economic purpose.

Law 10/2010, Art. 17.
RefrainingBlock

Duty to refrain from executing transactions

The bank does not execute a suspicious transaction while it reports it to SEPBLAC.

Law 10/2010, Art. 19.
ConfidentialitySecrecy

Prohibition of disclosure

The bank cannot tell the customer that it has reported their transaction to SEPBLAC.

Law 10/2010, Art. 24.
TFRRegulation

Regulation (EU) 2023/1113

The EU regulation that sets the information that must accompany transfers.

Payer and payee.
SanctionsLists

International financial sanctions

Measures that require freezing the funds of persons and entities included on lists.

Screened before execution.
Customer serviceComplaint

Customer service department

The bank department where you file your first complaint.

15 business days for payments.
Bank of SpainSupervisor

Complaints service

The second route if the bank does not respond or you disagree with its answer.

After going through customer service.
Playbook

What to do depending on the reason for the block

Reason
What the bank usually asks for
What you do

Source of funds

What the bank usually asks for: proof of where the money comes from.

What you do: hand over the source-of-funds dossier.

Purpose of the payment

What the bank usually asks for: the contract or invoice that justifies the transfer.

What you do: provide the document and explain the transaction.

Payment order details

What the bank usually asks for: the full details of the payer or the payee.

What you do: correct them with the sending bank.

Sanctions lists

What the bank usually asks for: confirmation that you are not the person on the list.

What you do: provide your ID and that of the other party.

Garnishment

What the bank usually asks for: nothing, because it is complying with an order from an authority or a court.

What you do: contact the authority that ordered the garnishment.

Mistakes that prolong the block

These are the most common mistakes when the bank holds a transfer.

  • Waiting without asking what is missing.
  • Repeating the transfer before the first one is resolved.
  • Sending loose documents with no explanation tying them together.
  • Replying piecemeal, each time the bank asks for something new.
  • Moving the money through third-party accounts to get around the block.

Book a call

Tell us the amount, the date, whether you are sending or receiving the transfer and what the bank has told you, and we will tell you how to get it released.

Blocked transfers under Law 10/2010

Updated October 16, 2026

When a bank holds a transfer, it is almost always because it has not been able to complete the due diligence measures required by Law 10/2010: knowing the customer, the source of the funds and the purpose of the transaction.

Why the transfer is held

Article 6 of Law 10/2010 requires the bank to review transactions, “including the source of funds,” and Article 7(3) prevents it from executing them if it cannot apply due diligence. If this becomes impossible during the business relationship, the bank must end the relationship. We explain this in source of funds.

The duty to refrain

If there are signs of money laundering, the bank refrains from executing the transaction and reports it to SEPBLAC (Art. 19), and it cannot tell you so (Art. 24). We explain this in duty to refrain from executing transactions and suspicious transaction reporting.

Payment data and sanctions lists

Regulation (EU) 2023/1113 sets the information that accompanies a transfer: we cover it in transfers of funds (TFR). If the name matches a sanctioned person, the bank checks this before executing the transfer: see international financial sanctions.

How to file a complaint

First with the customer service department: 15 business days for payment services (Article 69 of Royal Decree-law 19/2018) and one month for all other matters (Article 30 of Law 44/2002). Then with the Bank of Spain. We explain this in customer service departments of financial institutions.

Specific cases

If the transfer is for a home, see bank block on a property purchase. If it comes from China or the UAE, see blocked transfer from China and blocked transfer from the UAE. And if it involves cryptocurrency, see account blocked over cryptocurrency.

Blocked transfer Law 10/2010 Due diligence Source of funds Duty to refrain Regulation (EU) 2023/1113 Bank of Spain Bank complaints