{"id":2106958,"date":"2026-08-25T15:02:44","date_gmt":"2026-08-25T13:02:44","guid":{"rendered":"https:\/\/kohenavocats.fr\/2026\/08\/25\/french-bank-frozen-uk-transfer-after-brexit-source-of-funds-remedies\/"},"modified":"2026-08-25T15:02:44","modified_gmt":"2026-08-25T13:02:44","slug":"french-bank-frozen-uk-transfer-after-brexit-source-of-funds-remedies","status":"publish","type":"post","link":"https:\/\/kohenavocats.fr\/en\/2026\/08\/25\/french-bank-frozen-uk-transfer-after-brexit-source-of-funds-remedies\/","title":{"rendered":"Why Has a French Bank Frozen My UK Transfer After Brexit? Source-of-Funds Documents, AML Checks and Remedies"},"content":{"rendered":"

A British resident in France may discover that a transfer from a UK account has been paused, rejected or returned without a clear explanation. The bank may refer to \u201ccompliance\u201d, \u201csecurity\u201d, \u201cBrexit\u201d or a request for further documents. Those words do not all describe the same legal situation. A temporary request for proof of the origine des fonds<\/em> (source of funds) is different from a payment refusal, a restriction on the account, or a formal termination of the banking relationship.<\/p>\n

Brexit does not create a general prohibition on sending legitimate money from the United Kingdom to France. A French bank must, however, identify its customer, understand the purpose of the relationship and monitor transactions under the French anti-money-laundering framework. A bank can therefore ask why a transfer is being made, where the money came from and who will receive it. It may also be unable to explain every internal suspicion because some reporting information is confidential.<\/p>\n

This article addresses the practical legal problem faced by a British person living in France: how to distinguish a lawful compliance review from an unjustified or badly managed block, how to assemble a credible document file, and how to complain or seek relief. It does not set out the French property purchase process. If the transfer is connected with a property transaction, the focus here is limited to proving its origin, destination and lawful purpose.<\/p>\n

I. Why has my French bank frozen a UK transfer after Brexit?<\/h2>\n

A. What is a French bank actually checking on a UK transfer?<\/h3>\n

The first question is not whether the transfer is \u201cBritish\u201d, but whether the bank can reconcile the transaction with its knowledge of you. The French term vigilance<\/em> means the bank\u2019s anti-money-laundering due diligence<\/a>. It is a continuing process, not a one-off formality completed when the account was opened.<\/p>\n

Under Article L. 561-5 of the French Monetary and Financial Code<\/a>, the regulated institution must, before entering into the relationship, \u201cidentifient leur client<\/em>\u201d \u2014 identify its customer \u2014 and verify the relevant identification information. For a British resident, that normally means keeping a consistent identity file: passport or national identity document, French address, residence status where relevant, tax-residence information and the account\u2019s beneficial owner. A bank may return to these points when the transaction is unusual, even if the account has been open for years.<\/p>\n

The next step is understanding the relationship itself. Article L. 561-5-1<\/a> requires information about \u201cl’objet et la nature de cette relation<\/em>\u201d, meaning the purpose and nature of the banking relationship. A transfer from a UK salary account to a French current account may be simple if it follows the customer\u2019s known pattern. A large one-off transfer after the sale of a house, an inheritance, a pension crystallisation, an investment exit or a family gift requires a fuller explanation.<\/p>\n

Article L. 561-6<\/a> adds the requirement of \u201cune vigilance constante<\/em>\u201d, or constant vigilance, including examination of transactions so that they remain consistent with the institution\u2019s knowledge of the customer, the business relationship and, where appropriate, the origin of the funds. The rule is important for British residents because a change of country, tax residence, income source or beneficiary may alter the bank\u2019s risk assessment without implying that the customer has done anything wrong.<\/p>\n

\u201cSource of funds\u201d and \u201csource of wealth\u201d should be separated in your response. Source of funds answers the immediate question: which identifiable event produced the exact pounds or euros now being transferred? Source of wealth describes the broader way in which you accumulated your assets over time. HM Revenue & Customs explains the distinction in its anti-money-laundering guidance<\/a>. A bank may need both levels of explanation when the transfer is large or inconsistent with the account history.<\/p>\n

For example, a UK house sale should be supported by the completion statement, the sale contract or conveyancer\u2019s statement, the account statement showing receipt of the proceeds and the transfer confirmation. A pension payment may require the pension provider\u2019s statement, the award or drawdown document and the bank statement. An inheritance may require the grant of probate, estate accounts, a notarial or executor\u2019s letter, the inheritance-tax paperwork where relevant and the statement showing the payment. An investment sale may require the broker\u2019s contract note and the statement showing the proceeds. The objective is a traceable chain, not a large bundle of unrelated documents.<\/p>\n

The payment itself is also a legally defined operation. Article L. 133-3 of the Monetary and Financial Code<\/a> describes a payment operation as including \u201cverser, transf\u00e9rer ou retirer des fonds<\/em>\u201d \u2014 paying in, transferring or withdrawing funds. Article L. 133-6<\/a> provides that \u201cune op\u00e9ration de paiement est autoris\u00e9e si le payeur a donn\u00e9 son consentement<\/em>\u201d: a payment is authorised when the payer has consented. These provisions do not compel a bank to ignore an anti-money-laundering alert, but they show why \u201cthe transfer came from the UK\u201d is not by itself a complete legal explanation for an indefinite block.<\/p>\n

On the UK side, the GOV.UK guidance on payment information<\/a> explains that payment providers may need complete payer and payee information and may request documents from a reliable, independent source. Your UK bank may therefore ask questions at the sending stage, while the French bank asks questions at the receiving stage. A transfer can be paused by either institution, and the customer should identify which bank has actually stopped the funds before sending repeated instructions.<\/p>\n

The practical test is coherence. Does the name on the UK account match the name on the French account? Does the amount correspond with the documentary event? Is the beneficiary a known person, a solicitor, a notary, a family member or a business previously disclosed to the bank? Does the stated purpose match the customer\u2019s tax residence and financial profile? Can the customer explain the movement from the original source to the sending account and then to France? A clear answer to those questions often resolves an ordinary review more quickly than an argument about Brexit.<\/p>\n

B. Can a French bank legally freeze or reject a transfer because it comes from the UK?<\/h3>\n

A French bank may pause a transfer while it completes a lawful compliance review. That does not mean that every refusal is justified, and it does not mean that a bank can use \u201cBrexit\u201d as a substitute for a reasoned analysis. The legal reason matters because the available response changes according to the reason.<\/p>\n

For a particularly complex transaction or one of an unusually high amount, Article L. 561-10-2<\/a> requires an enhanced examination. The text refers to asking about \u201cl’origine des fonds et la destination de ces sommes<\/em>\u201d \u2014 the origin of the funds and the destination of the sums \u2014 as well as the purpose of the operation and the identity of the person benefiting from it. A bank may legitimately ask for a document file before allowing the transfer to proceed.<\/p>\n

Where the bank knows, suspects or has good reason to suspect that funds come from a qualifying offence or are connected with terrorist financing, Article L. 561-15<\/a> requires a report where the statutory conditions are met. The provision uses the words \u201csavent, soup\u00e7onnent ou ont de bonnes raisons de soup\u00e7onner<\/em>\u201d \u2014 know, suspect or have good reasons to suspect. In the circumstances covered by Article L. 561-16<\/a>, the institution must \u201cs’abstiennent d’effectuer toute op\u00e9ration<\/em>\u201d, abstain from carrying out the operation, until the statutory reporting step has been made, subject to the exceptions in the Code.<\/p>\n

The customer must also understand the confidentiality problem. Article L. 561-18<\/a> states: \u201cLa d\u00e9claration mentionn\u00e9e \u00e0 l’article L. 561-15 est confidentielle.<\/em>\u201d The declaration referred to in Article L. 561-15 is confidential. A bank may therefore be unable to tell you whether it made a report or what information prompted it. Asking the bank to confirm the existence of a confidential report is unlikely to produce a useful answer. You can instead ask what non-confidential documents are missing, whether the transfer is pending or rejected, and whether the funds will be returned if it cannot be executed.<\/p>\n

Article L. 561-22<\/a> also contains protections for regulated institutions acting within the statutory reporting mechanism, beginning with \u201cAucune action en responsabilit\u00e9 civile ne peut \u00eatre intent\u00e9e<\/em>\u201d in the circumstances described by the provision. That protection does not grant a bank unlimited freedom to mishandle every customer instruction. It explains why a court or complaint authority will distinguish a protected AML decision from a technical error, an unexplained delay, a misapplied internal rule or a refusal based only on nationality.<\/p>\n

The recent case law of the French commercial chamber helps draw that line. In its judgment of 25 March 2026, Pourvoi n\u00b0 24-18.093<\/a>, the Cour de cassation referred to the bank\u2019s \u201cdevoir de non-immixtion<\/em>\u201d, its duty not to interfere in the customer\u2019s affairs, and held that the bank\u2019s ordinary role is not to investigate the origin, reason or opportunity of every authorised movement. The decision also treated the international character of the transfers as insufficient, on the facts before it, to constitute an anomaly. That is a useful warning against a blanket Brexit explanation, while still leaving room for a genuine AML alert.<\/p>\n

In Pourvoi n\u00b0 24-10.168, 12 June 2025<\/a>, the commercial chamber examined a bank\u2019s handling of transfers involving a foreign account and the circumstances capable of alerting it. In Pourvoi n\u00b0 22-23.136, 1 October 2025<\/a>, it considered the European payment framework and the consequences of apparent anomalies. These decisions do not create an automatic right to immediate execution; they require the bank\u2019s conduct to be assessed against the information available, the customer\u2019s instructions and any anomaly that was apparent at the time.<\/p>\n

That distinction produces four practical situations. First, the transfer may be pending because the bank has requested documents. Second, it may have been rejected or returned because a required field, beneficiary detail or compliance condition was not satisfied. Third, the account may be restricted, so several operations are affected. Fourth, the account may be terminated under the rules governing the banking relationship. The last two situations are not solved by sending one more payslip. They require a separate review of the account notice, the reason given and the customer\u2019s ability to continue using a French account.<\/p>\n

The existing guidance on a French bank closing a British resident\u2019s account<\/a> concerns notice and remedies for termination. The separate right-to-account procedure<\/a> applies when a person has been refused an account, not simply when one transfer is being reviewed. Linking the cases is useful for navigation, but treating them as the same legal problem can send the complaint to the wrong institution.<\/p>\n

II. What documents and remedies can a British resident use?<\/h2>\n

A. Which source-of-funds documents should a British resident prepare?<\/h3>\n

Start with a chronology, not with an emotional explanation. Write down the date and amount of the transfer, currency, sending account, receiving account, beneficiary, payment reference, date on which the French bank asked questions, documents already supplied and the current status shown by each bank. Save the confirmation of the payment order. Under Article L. 133-9<\/a>, the moment at which a payment order is received has legal significance, so the bank should be able to identify when it received the instruction and whether the instruction was complete.<\/p>\n

Then prepare a compact source-of-funds file. The file should allow a compliance officer who does not know your personal history to follow the money without guessing. It should contain the following elements, adapted to the transaction rather than copied mechanically:<\/p>\n