LocatePhase 1
Where it is stuck
With the payment order receipt and the transfer reference, we find out whether it is being held by the Chinese bank, an intermediary bank or your bank in Spain.
The detail that changes everything.
Blocked transfer from China to Spain
If a transfer from China does not reach your account or the bank has held it, the bank is usually asking you for information about the source of the money. Law 10/2010 prevents it from executing transactions it cannot verify (Art. 7(3)). We find out which bank has stopped it and what it needs, and we prepare the response so the transfer is released.
Transfer from China on hold? We tell you what to do
Tell us the amount, the date, the sending bank, the receiving bank and what you have been told, and we will guide you.
- Reply within 24 h
- No commitment
- Confidential
- First step
- Find out which bank is holding it
- Bank complaint deadline (payments)
- 15 business days
- Annual FX quota in China
- USD 50,000
- Spanish law
- Art. 7(3) Law 10/2010
How we help
From a held transfer to money in your account
An international transfer can be stopped at the sending bank, at an intermediary bank or at the receiving bank. The first step is to find out where it is and what is missing.
RequestPhase 2
What exactly is missing
We ask the bank in writing to specify what information or documents it needs to complete the transaction.
No guesswork.
EvidencePhase 3
The source of the money
We gather evidence of where the money comes from and the route it has taken: contracts, statements, tax records and proof of the currency exchange.
A complete chain.
DataPhase 4
The transfer details
We check that the payment order carries the payer and payee information required by Regulation (EU) 2023/1113 and that it matches your documents.
Name, account and address.
ResponsePhase 5
A dossier for the bank
We send the documents in order, with a clear explanation of the transaction, and keep proof of delivery.
All in one go.
ComplaintPhase 6
If the bank does not respond
If the deadlines pass with no response, we prepare the complaint to the bank’s customer service department and then to the Bank of Spain.
Through the proper channels.
Common reasons
Why a transfer from China gets stuck
Most blocks are not permanent: the bank is waiting for information it does not have.
Source
The bank does not know where the money comes from
A large amount, or one that differs from your usual activity, requires the bank to ask where it comes from.
Data
Information is missing from the payment order
If the transfer arrives without complete payer or payee information, the bank may hold it until it has that information.
FX
Getting the money out of China required more formalities
Transactions above the annual foreign exchange quota are reviewed in more detail in China before they are sent.
Profile
The transaction does not fit your profile
If the bank knows you as an employee and you receive an amount that does not add up, it will ask for a documented explanation.
What the law says
A held transfer, by the numbers
Data from Law 10/2010, Regulation (EU) 2023/1113 and the rules on bank complaints.
Art. 7(3) Law 10/2010 No transaction
The bank does not execute transactions if it cannot apply due diligence, with no liability on its part except in cases of unjust enrichment.
Art. 19 Law 10/2010 Duty to refrain
Where there are indications of money laundering, the bank refrains from executing the transaction and reports it to SEPBLAC.
Art. 24 Law 10/2010 Confidentiality
The bank cannot tell you whether it has reported the transaction to SEPBLAC.
Regulation (EU) 2023/1113 Information
The transfer must be accompanied by the payer’s name, account and address, and by the payee’s name and account.
Art. 69 Royal Decree-law 19/2018 15 business days
The time the bank’s customer service department has to answer a complaint about payment services.
SAFE · 2007 rules USD 50,000
Annual quota for individuals to buy and sell foreign currency in China.
Have you been waiting days for a transfer from China?
We tell you which bank has it, what is missing and how to present it.
Frequently asked questions
Blocked transfer from China: common questions
Why has the bank blocked my transfer from China?
Almost always because it needs to verify where the money comes from before executing the transaction. Law 10/2010 prevents it from executing transactions if it cannot apply due diligence measures (Art. 7(3)). It may also hold the transfer if the payment order arrives without complete payer or payee information.
How do I know which bank has stopped the transfer?
Ask the sending bank for the payment order receipt and its reference, and ask your bank in Spain whether it has received the transfer. An international transfer may pass through intermediary banks, and each of them may ask for information. Knowing where the transfer is is the first step to knowing whom you need to answer.
What documents are required to release a transfer from China?
Those that prove the source and route of the money: the contract or transaction that generated it, statements from the source account, tax returns and proof of the currency exchange. If the transfer comes from your own account in China, also proof that the account is yours.
How long can the bank hold my money?
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 respond with everything at once. If the bank does not answer you, you can complain to its customer service department, which must respond within 15 business days for payment services.
Can the bank send the transfer back to China?
If it cannot apply due diligence, the bank does not execute the transaction and may end the relationship with the customer (Art. 7(3)). In practice, a transfer that is not accepted may end up being returned to the bank that sent it. Providing the documents in time avoids reaching that point.
Will the bank tell me the exact 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.
Do China’s foreign exchange controls play a role?
Yes. China’s State Administration of Foreign Exchange (SAFE) sets an annual quota of USD 50,000 for individuals to buy and sell foreign currency and reviews transactions above it in more detail. The documents you filed in China to send the money are often useful in Spain too.
Can I complain if the block drags on?
Yes. First to the bank’s customer service department: 15 business days for payment services (Art. 69 of Royal Decree-law 19/2018) and one month for other matters. If it does not respond or you disagree with its answer, to the complaints service of the Bank of Spain. A complaint works better if you have already provided the documents you were asked for.
Practical guide
What to do if your transfer from China does not arrive
The steps, in order, to find out where the money is and what you need to provide.
Locate the transfer
Reference, date, amount and the banks involved: without these, you will not know whom to answer.
Ask for the list in writing
Getting the bank to specify which documents it needs avoids piecemeal submissions.
Respond with everything
A complete, well-organized dossier is what shortens the block the most.
Your transfer in 10 steps
- Get the payment order receipt and the transfer reference.
- Check with your bank in Spain whether the transfer has arrived and is being held.
- If it has not arrived, ask the sending bank whether it has sent it or is holding it.
- Ask the bank holding it, in writing, what information it needs.
- Check that the payer and payee details match your documents.
- Gather proof of the source of the money: contract, payslips, sale, dividends or inheritance.
- Add the statements from the source account and proof of the currency exchange.
- Apostille and translate the Chinese public documents you are going to submit.
- Submit everything together, with a short explanation of the transaction, and keep the acknowledgment of receipt.
- If there is no answer in time, complain to the customer service department and then to the Bank of Spain.
Source: Law 10/2010 (Arts. 7, 19 and 24), Regulation (EU) 2023/1113, Royal Decree-law 19/2018 (Art. 69) and China’s State Administration of Foreign Exchange (SAFE).
Glossary
Key terms for a held transfer
These terms appear in the bank’s messages and in Law 10/2010.
PayerSender
Payer
Holder of the account the transfer is sent from.
Their details accompany the payment order.
PayeeRecipient
Payee
Holder of the account the money is going to.
Name and account in the payment order.
IntermediaryBank
Intermediary bank
An institution that an international transfer passes through between the sending bank and the receiving bank.
It can also ask for information.
TFRRegulation
Regulation (EU) 2023/1113
EU regulation that sets the information that must accompany transfers of funds.
Payer and payee information.
CDDObligation
Due diligence
Measures by which the bank identifies the customer and checks their transactions.
Arts. 3–7 Law 10/2010.
RefrainingHold
Duty to refrain from executing transactions
The bank does not execute a suspicious transaction while it reports it to SEPBLAC.
Art. 19 Law 10/2010.
SACComplaint
Customer service department
The bank department that receives the 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.
Only after going to the SAC.
SAFEChina
State Administration of Foreign Exchange
The Chinese authority that controls the buying and selling of foreign currency.
Annual quota of USD 50,000.
Playbook
Where the transfer gets stuck and what to do
At the Chinese bank
What usually happens: sending the money out requires more formalities or exceeds the annual foreign exchange quota.
What you do: provide the documents supporting the transaction there.
At an intermediary bank
What usually happens: it asks for information about the payer, the payee or the reason for the payment.
What you do: respond through the sending bank or the receiving bank.
At your bank in Spain
What usually happens: it needs to know the source of the funds before crediting them.
What you do: submit the source of funds dossier.
Returned to the sender
What usually happens: the bank could not complete due diligence.
What you do: prepare the documents before sending it again.
No response from the bank
What usually happens: the review drags on and nobody tells you what is missing.
What you do: ask for it in writing and, if they do not answer, file a complaint.
Mistakes that prolong the block
These are the most common mistakes when a transfer from China gets stuck.
- Waiting without asking which bank has the transfer.
- Sending the documents to a bank that is not the one holding the transfer.
- Repeating the transfer before the first one is resolved.
- Payer or payee details that do not match the documents.
- Answering piecemeal, each time the bank asks for something new.
Contact
Book a call
Tell us the amount, the date, the banks involved and what you have been told, and we will tell you how to get the transfer released.
Held transfers under Law 10/2010 and Regulation (EU) 2023/1113
Updated October 16, 2026
When an international transfer gets stuck, it is almost always because a bank has not been able to complete the due diligence measures required by Law 10/2010. If the transfer comes from China, Chinese exchange controls come into play as well.
Why it is held
The bank cannot execute a transaction if it cannot apply due diligence (Article 7(3) of Law 10/2010), and it must review transactions that do not fit the customer’s profile, including the source of funds (Art. 6). If there are indications of money laundering, it refrains from executing the transaction and reports it to SEPBLAC (Art. 19). We explain this in our page on the duty to refrain from executing transactions.
The transfer details
Regulation (EU) 2023/1113 requires a transfer to be accompanied by the payer’s name, account and address, together with an identity document number or other identifying detail, and by the payee’s name and account. If this information is missing, the bank may hold the transfer. We cover this in our page on transfers of funds (TFR).
Foreign exchange controls in China
China’s State Administration of Foreign Exchange (SAFE) sets an annual quota of USD 50,000 for individuals to buy and sell foreign currency and reviews transactions above it in more detail. A large transfer may already be delayed at its origin.
How to complain
First to the bank’s customer service department, which must respond within 15 business days for payment services (Art. 69 of Royal Decree-law 19/2018), and then to the complaints service of the Bank of Spain. We explain how the customer service department of financial institutions works.
Where this fits
A held transfer is almost always resolved by proving the source of funds. If the money comes from China, prepare the dossier as we explain in proving the source of funds from China to a Spanish bank.