An exporter accepted RMB 50,000 after an overseas customer said it had no mainland Chinese bank account and would arrange payment through an intermediary. Three days after the money arrived, the recipient bank account was frozen. The exporter believes this was an ordinary trade payment. The practical question is how to prove that good-faith position to the investigating authority.
In this situation, the most important response is not anger. It is proof.
A freeze is not a finding of guilt—but the recipient must actively explain the payment
Many people assume that because they did nothing wrong, a brief explanation to the investigator will be enough. In practice, it rarely is.
When an account receives fraud-linked funds, investigators must follow the payment chain. A freeze is an investigative measure, not a conviction. But the difference between a frozen account and criminal responsibility must be established with evidence; the statement “I am innocent” has little practical force on its own.
Article 144 of the Criminal Procedure Law of the People’s Republic of China permits people’s procuratorates and public security authorities, where necessary for a criminal investigation, to inquire into and freeze a criminal suspect’s deposits, remittances, bonds, shares, fund units and other property.
The point to prove is that the transaction was independent of the case
The evidence ordinarily needs to show that the recipient did not know the funds were problematic, that the payment had a genuine commercial basis, that the price was reasonable, that the goods or services were actually delivered and that no other suspicious conduct occurred.
Article 145 of the Criminal Procedure Law provides that frozen deposits, remittances and other property that are verified as unrelated to the case must be released and returned within three days.
Four categories of evidence are essential
First, preserve the contract or order documents. Contracts, quotations, packing lists, waybills, customs or logistics records, invoices and complete order records can establish a genuine sale. The sentence “it was payment for goods” cannot be independently verified.
Second, explain the third-party payment. This is often the hardest and most important part: why did someone other than the buyer pay, what relationship did that person have with the buyer, did the recipient already know the payer, were there earlier transfers, and was third-party payment agreed in advance? A message or email identifying a specific payer because the buyer lacked a mainland account can connect the logic.
Third, show that the amount matches the goods and a commercially reasonable price. A payment markedly different from ordinary consideration may itself be a warning sign.
Fourth, preserve the full communications. Do not delete messages after the freeze. Complete communications are direct evidence of the trade, the reason for the payment arrangement and the recipient’s state of knowledge. Deletion can destroy evidence and create suspicion of concealment.
Complete documents do not guarantee an immediate release
Even after receiving all the documents, an investigator may explain that the principal case is still unresolved and the account cannot yet be released. That may reflect the real procedural position rather than delay for its own sake.
If the account directly received victim funds, it may be treated as a Level 1 account in the payment chain. Before the wider case is characterized, the authority may be unable to isolate one payment as unrelated.
The right response is not passive waiting. Follow the verification process after submission and, where necessary, explain face to face how each item of evidence fits the transaction and payment chronology.
A second-tier or indirect account still requires scrutiny
Where funds passed through another account first, the recipient may be described as a second-tier or indirect account. Greater distance from the original fraud payment may make the evidence easier, but it does not remove risk.
If the holder was a friend of the intermediary, had repeated prior transfers, or knew the exchange and payment method was obviously irregular, the matter may extend beyond release of the freeze to investigation of concealing criminal proceeds or assisting cybercrime.
The first question is therefore not simply “can the account be released?” It is how the authority currently understands the holder’s conduct.
Take four steps immediately
- Confirm the restriction. Ask the bank for the full name of the authority, case reference, amount, period and available contact details.
- Preserve every item of evidence in its original form. Back up messages, transfers, contracts, invoices, logistics and delivery materials.
- Understand the current characterization. Identify the account’s place in the payment chain and how the authority views the holder before deciding how to respond.
- Do not delay. A freeze may be renewed. Early organization and effective communication create a better chance of resolving the matter at a key procedural stage.
The law can protect an innocent recipient, but innocence is not merely a conclusion. It must be demonstrated by the evidence.
Matters that are resolved successfully often share the same features: the recipient acts quickly, provides accurate material and cooperates with verification. The hardest cases are often those left for months in the hope of automatic release, or affected by earlier attempts to handle the case-linked record through irregular channels.
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