Lithuanian law allows a bank to freeze a suspicious transaction for a maximum of 10 business days without formal law-enforcement action. Where such an account is frozen, it is the law of that jurisdiction, not UK law, that governs the customer’s rights. When a financial institution identifies a suspicious transaction, it must suspend it and report it to FCIS within three business hours (Art. e2-1187-643/2024, ruled that the institution had failed to prove any legal basis for withholding the clients’ funds. Justinas Jarusevičius is an attorney representing clients in financial services litigation, including the case against NIUM EU, UAB described above.