Short answer: The police can freeze a company bank account under section 35 of the Criminal Procedure Code 2010 when they suspect money in it is linked to an offence, often because the company unknowingly received scam proceeds. The company can ask a court to release funds for day-to-day operations and must later show it is entitled to the money.
Finding your company bank account frozen in Singapore by a police order is alarming, but it does not mean the company is accused of anything. Usually the account has received money the police are tracing, such as a payment from a customer who was themselves defrauded. This guide explains why a police freeze happens, how it differs from a bank’s own restriction, the court routes to release funds, and the records that keep the business running in the meantime.
Key facts at a glance
- A police officer of or above the rank of inspector may, by written order, direct a bank not to allow any dealings with property in an account for the period stated in the order (Criminal Procedure Code 2010, section 35(2)(b)).
- Interest and other payments credited into the account after the order are caught by the same order (section 35(5)).
- Any person prevented from dealing with the property can apply to court for release of all or part of it (section 35(7)). For a company incorporated in Singapore, one permitted ground is money needed for day-to-day operations (section 35(8)(e)).
- The seizing officer must report the seizure to the relevant court once the property is no longer needed, or one year after the date of seizure, whichever is earlier (section 370(1)).
- In deciding who is entitled to seized property, the court may consider whether it was acquired through legitimate sources such as income, investments or trading (section 370(7)(a), in force since 14 November 2024).
- CPF contributions must still be paid by the 14th of the following month even if the account is frozen; late payment interest is 1.5% per month (CPF Board).
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.
Why would the police freeze a company bank account in Singapore?
The police freeze an account when they suspect that money in it is connected to an offence, is evidence of an offence, or was used or intended to be used to commit one. Section 35(1) of the Criminal Procedure Code 2010 (CPC) lets a police officer seize, or prohibit dealings in, any such property.
For a legitimate business, the usual trigger is an ordinary-looking receipt with a criminal history behind it:
- a customer pays an invoice using money obtained from a scam victim;
- a scam victim is tricked into paying your company directly for goods you actually sell;
- a customer’s own account is compromised, and the funds are traced onward to you.
The Ministry of Home Affairs told Parliament on 7 April 2026 that the police only freeze accounts where there is reason to suspect the funds are involved in illicit activities such as scams. Suspicion about the money is not a finding against the account holder. Section 35(9) also explains why a freeze can reach money that has changed hands: property includes anything into which the original property was converted or exchanged.
If your business was the target of a payment diversion fraud rather than the recipient, see our guide to invoice fraud when a supplier’s bank details change by email.
A third possibility is that IRAS has appointed the bank as its agent to collect overdue tax. See what an IRAS agency appointment means and how to get the account released.
Is it a police freeze or the bank’s own restriction?
Ask the bank in writing. A police freeze is a written order under section 35(2) of the CPC, while a bank restriction is the bank’s own decision under its account terms and risk processes. The way out is different.
| Feature | Police freeze (CPC section 35) | Bank-initiated restriction |
|---|---|---|
| Who decides | A police officer of inspector rank or above, by written order | The bank, under its customer agreement and internal policies |
| Who can lift it | The police, or a court under section 35(7) or at the section 370 stage | The bank, once satisfied with the company’s explanation |
| Consequence if the bank ignores it | Fine of up to S$3,000 for the bank (section 35(6)) | Not applicable |
| First step for the company | Contact the Investigation Officer and brief a criminal law solicitor | Answer the bank’s queries with documents on source and purpose of funds |
Banks have their own reporting duty. Under section 45 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA), a person who, in the course of business, knows or has reasonable grounds to suspect that property represents the proceeds of criminal conduct must report it to a Suspicious Transaction Reporting Officer. So a bank may say little, and even after a police freeze ends it decides for itself whether to keep the relationship.
What is the legal basis for freezing and releasing the funds?
Seizure is governed by section 35 of the CPC, and what happens to the property afterwards by sections 370 to 372. These are criminal procedure provisions; the Rules of Court 2021, which govern civil proceedings, are not the source of the procedure here.
- Section 35(2) lets an officer direct a bank to deliver the property to the police, or not to allow dealings in the account for a specified period.
- Section 35(7) and (8) let a court release all or part of the property, but only on listed grounds: basic expenses such as rent, taxes, insurance premiums and utilities; reasonable legal fees; routine maintenance fees; extraordinary expenses; prior liens or judgments; and, for a Singapore-incorporated company, day-to-day operations.
- Section 370 requires the officer to report the seizure to the relevant court when the property is no longer needed (subject to conditions), or one year after seizure, whichever is earlier. The court then makes an order, ordinarily delivery to the person entitled. The relevant court is a Magistrate’s Court unless the property was seized for a particular inquiry, trial or proceeding.
- Sections 371 and 372 deal with delivery: a known owner gets a notice to collect within a period of at least 48 hours; if the owner cannot be found, a public notice invites claims within 6 months.
Sections 370 to 372 were amended by Act 24 of 2024 with effect from 14 November 2024. Section 370(7) now lets the court consider whether a claimant acquired the property through legitimate sources, which puts contemporaneous business records at the centre of any claim. The current text is on Singapore Statutes Online.
Who can apply for release of a frozen company bank account, and when?
The company itself can apply, because section 35(7) allows any person prevented from dealing with property to apply, and a company is a person in law. You do not have to wait for the investigation to end.
There are three practical routes, often used together:
- Ask the Investigation Officer. The police unfreeze accounts once they are found not to be involved in criminal activity and are no longer needed for investigation, trial or other proceedings, according to the Ministry of Home Affairs (18 September 2023).
- Apply under section 35(7) for partial release, for urgent needs such as payroll, rent and suppliers while the investigation continues.
- Claim the property at the section 370 stage by showing the company is entitled to the money.
Where the court is satisfied an offence was committed in respect of property, it may order its disposal as it thinks fit (section 370(2)(b)). So if a scam victim’s money is still in the account, ring-fencing that amount and seeking release of the rest is usually more realistic than asking for everything back.
How do you get funds released from a company bank account frozen in Singapore?
Move quickly, keep everything in writing, and separate the disputed receipt from the rest of the balance.
- Confirm the source of the freeze. Ask the bank which accounts are affected, the date of the order and the Investigation Officer’s contact. Do not route payments around the freeze.
- Identify the suspect transaction from bank statements and the ledger.
- Build the source-of-funds pack for the suspect receipt and for the rest of the balance (see the table below).
- Brief a criminal law solicitor. Any court application is conducted by a Singapore Advocate and Solicitor. If you do not have one, speak to a lawyer before giving a statement or a long written explanation.
- Offer the documents to the Investigation Officer, with your solicitor, and ask whether the untainted balance can be released.
- If needed, the solicitor applies to court under section 35(7), showing which section 35(8) ground applies, usually day-to-day operations, with a costed list of outgoings.
- Diarise the first anniversary of the seizure, the latest date for the section 370 report, and be ready to establish entitlement.
What documents prove the company’s legitimate source of funds?
Documents created at the time of the transaction carry the most weight. Section 370(7)(a) lets the court consider legitimate sources such as income, investments or trading, and section 55 of the CDSA makes it relevant whether a person holding property can account satisfactorily for how they came by it.
| Document | What it shows | Who usually prepares it |
|---|---|---|
| Invoice, quotation and purchase order for the suspect receipt | The payment was for real goods or services at a commercial price | Finance team or bookkeeper |
| Delivery orders, shipping documents, service reports, correspondence | Performance took place and how the deal arose | Operations and sales teams |
| Bank statements and general ledger extract | Composition of the frozen balance and its legitimate inflows | Bookkeeper or accountant |
| Latest financial statements and management accounts | The normal trading pattern and income level | Accountant |
| Bizfile business profile and statutory registers, including registrable controllers | Who owns and controls the company | Company secretary |
| Board resolution authorising the application and the person giving evidence | The company’s representative has authority | Company secretary, with the solicitor |
| Payroll register, CPF records, lease and supplier invoices | The operating expenses for which release is sought | Payroll provider and finance team |
If the books are behind, bring them up to date before the application. Our guide to source of funds and KYC for corporate bank accounts covers the evidence banks expect.
How long does it take and what does it cost?
There is no fixed timetable. The police release accounts when they are no longer needed, and the outer marker in the CPC is the section 370 report, due no later than one year after seizure.
| Stage | Typical timing | Main cost drivers |
|---|---|---|
| Gathering records and contacting the Investigation Officer | Days to a few weeks, depending on how current the books are | Internal time; accountant’s time if the ledger needs updating |
| Section 35(7) release application | Depends on court scheduling and whether the Prosecution objects | Solicitor’s fees, volume of evidence, whether contested |
| Section 370 report and order | When no longer needed; report due within 1 year of seizure at the latest | Solicitor’s fees if entitlement is disputed or there are competing claims |
| Bank review after release | Varies by bank | Internal time and accountant’s support |
Assumptions: one Singapore-incorporated company, one or two suspect receipts, no allegation against the company. We do not quote legal fees because they depend on the firm and the complexity; ask for a written estimate. Section 35(8)(b) allows release for reasonable legal fees if the frozen account is the company’s main source of cash.
How do you keep paying staff, CPF and suppliers while the account is frozen?
Use other unfrozen accounts or fresh funding, and seek release for essential outgoings. The Ministry of Home Affairs said on 7 April 2026 that people with frozen accounts may use other non-frozen accounts or apply for a new one, subject to the bank’s own due diligence and risk assessment.
- Payroll and CPF. CPF contributions are due on the last day of the month, and CPF Board takes enforcement action if they are not paid by the 14th of the following month, including late payment interest of 1.5% per month (CPF Board). Tell employees why payment is late and when to expect it. Directors can face personal exposure; see unpaid CPF contributions and director liability.
- Director funding. Document any director loan with a board resolution and loan note, paid into an unfrozen account.
- Suppliers and landlords. Tell key counterparties early, in writing, that a third-party investigation is causing the delay.
- Cash forecast. A 13-week cash flow supports a section 35(8)(e) application; our free tools can help with the numbers.
What does the company secretary prepare and what does the solicitor file?
The company secretary and accountant prepare the corporate and financial records; the solicitor advises, deals with the police and the Prosecution, and files any court application.
| Company secretary or CSP | Singapore Advocate and Solicitor |
|---|---|
| Up-to-date Bizfile profile and statutory registers | Advice on the freeze and on statements to the police |
| Board resolutions appointing a representative and approving funding | Preparing and filing the section 35(7) application |
| Reconciled accounts, payroll and CPF records | Correspondence with the Investigation Officer and the Prosecution |
| Minutes of the board’s decisions | Appearing in court and handling the section 370 claim |
Raffles Corporate Services does not act in criminal proceedings or give legal advice. A police freeze does not by itself require an ACRA lodgement, but if directors or signatories change as a result, the usual ACRA filings and bank mandate updates apply. To weigh a civil claim against the payer, see police report or civil claim; if the account is frozen by a civil court order instead, see company bank account frozen by a court order.
What mistakes make a police freeze harder to resolve?
The most damaging mistakes are moving money around the freeze and giving explanations the records cannot support.
- Withdrawing or transferring funds through another channel, or asking the payer to reverse the payment privately.
- Refunding the suspect receipt without police agreement, which may send money back into a fraud.
- Giving an unprepared statement before reading your own records.
- Letting the books fall months behind, so the untainted balance cannot be shown.
- Missing CPF and payroll deadlines in the hope the freeze lifts soon.
Many restrictions start with a bank review rather than the police. See how to respond to a bank KYC review of your company account.
Frequently asked questions
Does a police freeze mean my company is under investigation?
Not necessarily. The police may freeze property suspected to be connected with an offence, including money that reached an innocent recipient through a normal sale. Ask the Investigation Officer what role the company has in the case.
Can one suspect payment affect the whole account?
The order stops dealings with the property in the account, and in practice this can affect the whole balance. That is why a section 35(7) application usually asks for release of what operations need while the disputed amount stays frozen.
Can the company use the frozen money to pay its lawyer?
Yes, if the court agrees. Section 35(8)(b)(i) allows release of money needed exclusively for reasonable professional fees and expenses connected with legal services.
Will the bank close our account afterwards?
It might. The bank makes its own risk assessment, separately from the police. A prompt, documented explanation of the transaction improves the chance of keeping the relationship.
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: 29 October 2026. The Editorial Team, Raffles Corporate Services.