
Short answer: If your company bank account is frozen by a Singapore court order, read the order the same day, work out whether it is a freezing (Mareva) injunction or an enforcement order attaching the account, and comply strictly. Then use the built-in exceptions, make any required asset disclosure on time, and ask your solicitor about varying, discharging or objecting.
Finding your company bank account frozen is highly disruptive, because salaries, suppliers and rent all run through it. This guide is for the company on the receiving end. It explains how to tell which kind of order has frozen the account, what you may still pay, what you must disclose and by when, and how the order can be varied or discharged. If you are the party seeking the order instead, see our guides to obtaining a Mareva injunction and to Third Party Debt Orders.
Key facts at a glance
- A freezing injunction over assets in Singapore must be in Form 24, and a worldwide one in Form 25 (Rules of Court 2021, Order 13, Rule 1(6) and (7)).
- The standard Form 24 order allows a weekly sum for legal advice and dealings “in the ordinary and proper course of business”, with periodic accounting to the claimant.
- The standard order requires the defendant to tell the claimant in writing at once of all its assets in Singapore, confirmed by affidavit.
- The claimant undertakes to comply with any order to compensate the defendant if the court later finds the order caused loss that should be compensated (Form 24, Schedule 1).
- If a judgment creditor attaches the account under Order 22, the bank holds the money for 21 days after service of the notice of attachment, and objections must be filed within 14 days after service (Order 22, Rules 6(9) and 10(1)).
- A police freeze under section 35(2) of the Criminal Procedure Code 2010 is different; a court may release money needed for a Singapore company’s day-to-day operations (section 35(8)(e)).
Raffles Corporate Services works with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice. This article is general information only and is not legal advice.
Company bank account frozen: which kind of order is it?
There are three common reasons a company account is frozen in Singapore, and each needs a different response. The order or notice your bank forwards will tell you which applies.
| Type of freeze | When it happens | Legal basis | Main route to challenge |
|---|---|---|---|
| Freezing (Mareva) injunction | Before judgment, to stop assets being dissipated | Civil Law Act 1909, section 4(10); Rules of Court 2021, Order 13, Rule 1; Form 24 or 25 | Apply to vary or discharge the order |
| Enforcement order for attachment of a debt (often called a Third Party Debt Order or garnishee order) | After the claimant has a judgment or order for money against the company | Rules of Court 2021, Order 22, Rule 2(2)(c) | Notice of objection within 14 days, or a stay of enforcement |
| Police freeze | During a criminal investigation | Criminal Procedure Code 2010, section 35(2) | Court application for release under section 35(7) |
A freezing injunction does not take the money away; it stops the company dealing with its assets up to a stated value while the case is decided. An attachment goes further: unless challenged, the bank will pay the attached money to the judgment creditor.
A police freeze is not a civil order at all. A police officer of or above the rank of inspector may, by written order, direct a bank not to allow dealings with an account for a specified period. The court may release property only on the grounds in section 35(8), which include basic expenses, reasonable legal fees and, for a company incorporated in Singapore, its day-to-day operations. That route needs a criminal law practitioner; the rest of this guide deals with civil orders.
What does the law say about freezing orders and attachment?
The court may grant an injunction where it is “just or convenient” under section 4(10) of the Civil Law Act 1909, and the procedure is in Order 13 of the Rules of Court 2021. Attachment of bank deposits after judgment is governed by Order 22.
- Order 13, Rule 1(3) allows the claimant to apply without notice, with an affidavit explaining the urgency. This is why most companies only learn of the order after it is made. The State Courts Practice Directions 2021, paragraph 53(2), normally require at least 2 hours’ notice of the hearing, unless the case is extremely urgent or notice would defeat the application.
- Order 13, Rule 1(5) requires the applicant to disclose all material facts it knows or reasonably ought to know, including those adverse to its case.
- Order 22, Rule 2(2)(c) allows attachment of a bank deposit “whether or not the deposit has matured and despite any restriction as to the mode of withdrawal”.
- Order 3, Rule 2(8) to (10) lets the court revoke an order obtained without notice to the affected party, on an application made within 14 days after the party knows or should have known of the ground.
What should the company do in the first 48 hours?
Stop all payments out of the affected account until you know exactly what the order permits, and get the order to a Singapore litigation solicitor immediately. The standard form warns that a person who disobeys it is guilty of contempt and “may be sent to prison or fined”.
- Obtain the sealed order and the supporting affidavits. Under Schedule 1 to Form 24, the claimant undertakes to serve the affidavits and exhibits as soon as practicable.
- Note the case number, the court, the value frozen, the exceptions and the return date for the next hearing.
- Diarise every deadline: the asset disclosure, the return date, the 14-day objection window for an attachment and the 14-day window under Order 3, Rule 2(10).
- Brief directors, finance staff and bank signatories in writing. Form 24 says a company must not do a prohibited act “itself or by its directors, officers, employees or agents or in any other way”.
- Ask the bank which accounts are affected and how it will process permitted payments.
- Instruct a solicitor. Court proceedings, including any application to vary or discharge, are conducted by a Singapore Advocate and Solicitor. If you do not have one, speak to a lawyer the same day.
Can the company still pay salaries, suppliers and legal fees under a freezing order?
Usually yes, within limits. The standard Form 24 order does not stop the defendant dealing with assets in the ordinary and proper course of business, and it allows a stated weekly sum (or a reasonable sum) for legal advice and representation.
- Ordinary course of business. Payroll, rent, utilities and regular suppliers usually fall within it. Repaying a director’s loan, paying a dividend, selling a key asset or moving money to a related company may not. Clear anything unusual with your solicitor first.
- Accounting. The company must account to the claimant at the interval stated in the order for money spent under the business exception, so keep a payment log with invoices from day one.
- Source of funds. Before spending under the exceptions, the standard form requires the defendant to tell the claimant where the money is to come from.
- Agreed changes. The parties may agree in writing to increase spending limits or vary the order in other respects, which avoids a contested hearing.
- Directors sued personally. If a director is also a defendant, the standard form lets an individual spend a stated weekly sum on ordinary living expenses. That allowance is the director’s, not the company’s.
Form 24 also says the injunction does not stop a bank exercising a right of set-off for a facility granted before it was notified of the order, and no bank need enquire into a withdrawal that appears to be permitted.
What asset disclosure does a freezing order require?
The standard Form 24 order requires the defendant to inform the claimant in writing at once of all its assets in Singapore, whether in its own name or not and whether solely or jointly owned, giving value, location and details. The information must then be confirmed by affidavit within the time stated in the order.
For a company this means a schedule of every bank and securities account, receivables, property, equipment, shares in subsidiaries and any assets held by nominees. Start from the latest management accounts and bank reconciliations and update balances to the disclosure date. Choose a director or officer with real knowledge of the finances to swear the affidavit. An incomplete or misleading affidavit can lead to committal proceedings for contempt. If the deadline is unrealistic, ask for more time before it expires, not after.
After judgment, a creditor can also apply under Order 22, Rule 11 for the company’s officers to be examined, or to file an affidavit, on the company’s property.
| Document | Purpose | Who usually prepares it |
|---|---|---|
| Sealed order, supporting affidavits and exhibits | Shows what is frozen, the exceptions and the claimant’s case | Served by the claimant’s solicitors |
| Schedule of assets with values and locations | Meets the written disclosure duty in the order | Finance team, checked by the solicitor |
| Disclosure affidavit | Confirms the asset information on oath | Solicitor drafts; a director swears |
| Payment log with invoices | Business-exception accounting and any later damages claim | Finance team or accountant |
| Board resolution | Appoints solicitors and authorises the deponent | Company secretary |
How do you vary or discharge a freezing order?
Form 24 states that the defendant, or anyone notified of the order, may apply to the court at any time to vary or discharge it, but must inform the claimant first. Otherwise the order remains in force until trial or further order.
Grounds a solicitor will commonly consider include:
- Non-disclosure of material facts by the applicant, in breach of Order 13, Rule 1(5).
- No real risk that the company would dissipate assets to defeat a judgment.
- The claim itself is not sufficiently arguable.
- The value frozen exceeds the realistic claim, so the order should be reduced.
- The exceptions are too tight to keep the company trading, so they should be widened.
- The company offers security, such as a bank guarantee or payment into court, in exchange for releasing the account.
The claimant’s undertaking in damages matters here. Under Schedule 1 to Form 24, if the court later finds the order caused loss to the defendant and decides it should be compensated, the claimant will comply with any order the court makes, and the court may require security for this. Our guide to the undertaking as to damages explains how it works. Record lost contracts, late-payment charges and other losses from the first day.
Legal costs depend on the facts, so we do not quote figures. Official filing fees are set by the courts (see our guide to court fees in Singapore), but solicitors’ fees are the larger cost. The main cost drivers are:
| Cost driver | Why it matters |
|---|---|
| Agreed variation or contested hearing | A written agreement on spending limits costs far less than a contested application. |
| Volume of evidence | Non-disclosure and merits arguments need detailed affidavits and exhibits. |
| Local or worldwide order | A Form 25 worldwide order may involve assets and advisers in several countries. |
| Security offered | A bank guarantee carries its own fees and collateral requirements. |
What if the account was attached after a judgment?
If the freeze comes from an enforcement order for attachment of a debt, act quickly. The bank must not release the attached money until 21 days after it was served with the notice of attachment, or until any objection is decided, and the company has 14 days after service to object.
| Step under Order 22 | Time limit | Rule |
|---|---|---|
| Creditor applies for the enforcement order | Not earlier than 3 days after the court order is served on the company | Rule 2(3) |
| Copy of the notice of attachment served on the company | Within 7 days after the attachment, unless the court directs otherwise | Rule 6(6) |
| Bank tells the Sheriff how much is available | Within 14 days after service on the bank | Rule 6(9)(a) |
| Notice of objection filed | Within 14 days after service of the notice of attachment | Rule 10(1) |
| Bank holds the money | Until 21 days after service, or until any objection is decided | Rule 6(9)(b) |
| Bank pays the creditor if there is no objection | Within 7 days after that 21-day period | Rule 6(10) |
- A notice of objection must identify the debt in dispute, state the grounds and include supporting evidence. If the creditor does not consent to release, the Sheriff may direct the objector to apply to court by summons within 7 days (Rule 10(2), (4) and (5)).
- The company may apply for a stay of enforcement where a “special case” makes immediate enforcement inappropriate (Rule 13).
- Payment by the bank is a valid discharge of its liability to the company even if the enforcement proceedings are later set aside (Rule 4), so act before the money is paid out.
- The Sheriff’s commission is 2% of the gross amount attached, with a minimum of S$100 and a maximum of S$50,000 (Rule 9(2)).
Often the quickest solution is to pay or settle the judgment debt and then apply, with the creditor’s consent, for satisfaction to be recorded under Order 22, Rule 3.
What does the company secretary prepare, and what does the solicitor file?
The solicitor runs the court process. Your company secretary or corporate service provider supplies the records and governance documents, often within days.
| Company secretary or CSP | Singapore Advocate and Solicitor |
|---|---|
| Board resolution appointing solicitors and authorising a director to swear affidavits | Advising on the order, its exceptions and the merits of a challenge |
| ACRA business profile, constitution and registers | Drafting and filing the asset disclosure affidavit |
| Management accounts, bank reconciliations and asset lists | Applications to vary or discharge, objections and stay applications |
| Payment log and invoices for business-exception accounting | Negotiating agreed variations with the claimant’s solicitors |
| Board minutes while the order is in force | Hearings and any claim on the undertaking in damages |
A freezing order or attachment does not by itself require an ACRA lodgement, but tell your accountant, because a pending claim or frozen balance may need disclosure in the next financial statements.
What are the common mistakes companies make?
Most problems come from acting too fast or too slowly.
- Moving money to another account or a related company “to keep trading”, which is likely to breach the order.
- Assuming only the company is bound. Form 24 also makes it a contempt for anyone notified of the order to knowingly assist in or permit a breach, so directors and staff who carry out a prohibited payment are exposed too.
- Missing the 14-day objection window for an attachment.
- Filing an incomplete or late asset disclosure.
- Treating a police freeze or a bank’s own compliance hold as if it were a civil court order.
Frequently asked questions
Will I be told before a freezing order is made against my company?
Often not. Order 13, Rule 1(3) allows an urgent application without notice. The practice directions usually require 2 hours’ notice of the hearing, but not where notice would defeat the application.
Can the company keep trading while its account is frozen?
Usually, yes. The standard order allows dealings in the ordinary and proper course of business, with periodic accounting to the claimant.
Does a frozen account mean the claimant has won?
No. A freezing injunction only preserves assets pending the outcome. An attachment follows an existing judgment, but the company can still object within 14 days or seek a stay.
Do our ACRA and tax deadlines pause while the account is frozen?
No. Annual return, AGM and tax deadlines continue to run. The Compliance Deadline Calculator in our free tools works out your due dates from your financial year end.
Sources: Rules of Court 2021; State Courts Practice Directions 2021, Part VI; Criminal Procedure Code 2010. For company secretarial support during a dispute, see Singapore Secretary Services.
Need help with this?
Raffles Corporate Services can handle the ACRA filings, compliance documentation and records for you, and where court proceedings or legal advice are needed, we work with a panel of experienced Singapore law firms who offer cost-effective and efficient legal service and advice.
Email: [email protected]
Call, SMS or WhatsApp: +65 8501 7133
Last reviewed: 25 October 2026. The Editorial Team, Raffles Corporate Services.
