How do I remove a lien or put-on-hold from my bank account in a cyber crime case?

Visit your bank branch and submit a written application explaining the legitimate source of the funds, with supporting documents. The bank exercises Enhanced Due Diligence and files a grievance on the NCRP-CFCFRMS Grievance Redressal Module. If the Investigating Officer is satisfied after verification, the hold is directed to be removed within 15 calendar days.

What is the difference between a hold (lien) and a freeze on a bank account?

A hold or lien blocks only a specific disputed amount in the account while the remaining balance stays usable. A suspension of digital banking deactivates online/UPI/card services. A seizure or freeze blocks the entire account, including branch operations.

What is the 90-day rule for a hold placed on a bank account?

If no lawful direction to continue the hold is received within 90 calendar days of the grievance being submitted by the bank, the bank must intimate the law enforcement agency at least 15 days before expiry, and then remove the hold after Enhanced Due Diligence on the account holder's request, provided no court petition or extension is pending.

Which law governs the removal of a hold on funds in NCRP cases?

The process is governed by Section 10.1 of the MHA Standard Operating Procedure for NCRP-CFCFRMS (02.01.2026). Interim restoration of funds to a victim from a suspected account is made under Section 106(3) of BNSS 2023 (formerly Section 102(3) CrPC).

How to Remove Lien / Put-on-Hold from Bank Account in Cyber Crime – NCRP

What is a "Put-on-Hold" / Lien?
Under the CFCFRMS system, when a cyber crime complaint is filed on cybercrime.gov.in (NCRP), the system can instruct banks to place a hold or lien on a specific amount in a suspected account. Unlike a complete freeze or seizure, a hold means: the money is still in the account, but the account holder cannot withdraw or transfer the held amount. The rest of the account balance (if any) remains usable. This is different from a full account freeze — see the comparison below.

Hold vs. Freeze vs. Seizure — What's the Difference?

Action	What It Means	Rest of Account	Governed By
Put on Hold / Lien	A specific amount is blocked; cannot be withdrawn by the account holder	Usable (balance above the held amount)	SOP Section 10.1 / CFCFRMS
Suspension of Digital Banking	Online/mobile banking, UPI, debit card suspended; may still use branch services	Branch operations may continue	SOP Section 10.2 / BNSS S.106
Seizure / Freeze	Full account access blocked including branch operations	No access	Section 106 BNSS / Court order

Step-by-Step Process to Remove the Hold / Lien

Visit Bank Branch

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Bank files grievance on CFCFRMS

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IO Verifies

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Hold Removed

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Or Appeal to DGO

Visit Your Bank Branch Immediately

Go to the branch where your account is held or any other designated branch. Carry valid identity proof (Aadhaar, PAN) and your bank passbook/statement. If you are a senior citizen, specially abled, or terminally ill, an authorised representative may visit on your behalf with proper documentation.

Submit a Written Explanation to the Bank

Submit a written application explaining why the transactions that triggered the hold are legitimate. Include supporting documents: invoices, salary slips, agreements, bank statements, or any other proof of the bonafide nature of the credit in question. Use the sample application format below.

Bank Exercises Enhanced Due Diligence (EDD)

The bank will verify your KYC and review your explanation under RBI's CDD/EDD framework. If convinced of the bonafide nature of the transaction, the bank will submit a formal grievance on your behalf on the NCRP-CFCFRMS Grievance Redressal Module. The bank must do this within 7 calendar days of your complaint.

Grievance Assigned to Investigating Officer

The SHO of the concerned police station assigns the grievance to the Investigating Officer (IO). If there are multiple holds from different complaints (possibly from different states), the grievance is routed to each relevant IO, with notification to the District Grievance Officer.

IO Issues Notice for Verification (Within 7 Days of Grievance)

The IO will issue a notice — physical or electronic — to the suspected account holder (who is the party against whom the hold was placed) to appear, preferably via video conference. A bank representative will be included. The account holder gets up to 15 calendar days to present their case. You as the aggrieved person should also prepare your response if asked.

IO Orders Removal of Hold (Within 15 Days)

If the IO is satisfied with the explanations and the amount is found to be legitimately yours, the IO will direct the bank to remove the hold within 15 calendar days of receiving the grievance. The bank will then remove the hold and update the CFCFRMS portal. If the IO is not satisfied, they must record reasons and communicate them to you within the same 15 days.

Appeal to District Grievance Officer (If Unsatisfied)

If the IO does not act within 15 days, the grievance is automatically escalated to the District Grievance Officer. If you are unsatisfied with the IO's decision, you may also file a review request within 15 calendar days of receiving the IO's decision by visiting the designated bank branch. The District Grievance Officer (rank: Addl. SP / Dy SP) must decide within 15 days.

90-Day Automatic Expiry of Hold

Even if the grievance is not fully resolved, if no lawful directions regarding continuation of the hold are received within 90 calendar days of the grievance being submitted by the bank, the bank must intimate the concerned law enforcement agency. If no extension is requested and no court petition is pending, the hold is removed. See the 90-day rule box below.

Key Timelines — Hold Removal

Bank to file grievance on CFCFRMS: within 7 calendar days of account holder's complaint
IO to issue notice to account holder: within 7 calendar days of grievance receipt
Account holder to respond to IO's notice: up to 15 calendar days
IO to direct hold removal or record reasons: within 15 calendar days of grievance receipt
Bank to remove hold after IO direction: within 15 calendar days of IO order
Review request to District Grievance Officer: within 15 days of IO's decision
District Grievance Officer to decide: within 15 calendar days of escalation
IO to implement District Officer's order: within 2 calendar days
Banks to furnish information when requested: within 2 calendar days
Maximum hold without continuation directions: 90 calendar days from grievance date
Bank to intimate LEA before 90-day expiry: 15 days before expiry

The 90-Day Rule — Critical Protection for Account Holders

This is one of the most important protections in the SOP. If a hold has been contested through the grievance mechanism and no lawful directions regarding continuation or removal are received within 90 calendar days from the date the grievance was submitted by the bank, then:

The bank must send an SMS to the SHO 15 days before the 90-day deadline
If no court petition is pending and no extension is requested by the LEA, the bank shall remove the hold after EDD and on request from the account holder
If the IO needs more time for investigation, they may request an extension for up to 90 additional calendar days

What If the Suspect Account Holder Contests?

If the suspected account holder — the person whose account was flagged in the cyber crime complaint — files a written contest against the refund within 15 calendar days of the order to restore funds, the IO or Police Officer shall follow the due process of law and proceed with investigations. The account holder must cooperate with the investigation. If this is your situation, consult a cyber lawyer immediately.

Sample Application to Bank for Removal of Lien / Hold

Submit this written application to your bank branch requesting them to exercise EDD and file a grievance on CFCFRMS for removal of the hold on your account.

To, The Branch Manager, [Name of Bank], [Branch Name & Address] Date: _______________ Subject: Request to Remove Lien / Hold on Account and File Grievance on NCRP-CFCFRMS Respected Sir/Madam, I, [Full Name], am the holder of [Savings/Current] Account No. [Account Number], IFSC: [IFSC Code], at your branch. I am writing to inform you that an amount of Rs. [Amount in figures] (Rupees [Amount in words] only) has been put on hold / subjected to a lien in my account in connection with a cyber crime complaint registered on the National Cybercrime Reporting Portal (NCRP / cybercrime.gov.in). Account Details: - Account Holder Name: [Full Name] - Account Number: [Account Number] - Account Type: [Savings / Current] - Branch: [Branch Name, City] - IFSC Code: [IFSC Code] - Amount Under Hold: Rs. [Amount] - Date Hold was Placed (if known): [Date] - Complaint/Reference Number (if known): [NCRP Complaint No., if available] I wish to state that I am NOT involved in any cyber crime and the amount held in my account is entirely legitimate for the following reasons: [Clearly explain the source of funds. For example: "The amount of Rs. _____ was credited to my account on [date] from [Name of sender / Company Name] as [salary / business payment / loan repayment / sale of property / gift / transfer from family member]. Supporting evidence is enclosed."] I request you to: 1. Verify my KYC and conduct Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) as required under RBI guidelines. 2. File a formal grievance on my behalf on the CFCFRMS Grievance Redressal Module within 7 calendar days of receipt of this application, as mandated by the MHA SOP dated 02.01.2026 (Section 10.1). 3. Include all supporting documents and my explanation in the grievance submission. 4. Ensure the grievance is forwarded to the concerned Investigating Officer (IO) for verification. 5. Keep me updated via SMS/email on all communications and decisions. I am available for verification via video conference at any time convenient to the IO or the bank. I am also willing to appear at the branch if required. I request the removal of the hold at the earliest after due verification. Thanking you, Yours faithfully, [Full Name] [Complete Postal Address] [Mobile Number] [Email ID] [Aadhaar Number / PAN Number] Enclosures: 1. Self-attested copy of Aadhaar Card / PAN Card 2. Copy of Bank Passbook / Bank Statement (last 6 months) 3. Source of funds documentation: a. Salary slip / Form 16 (if salary credited) b. Business invoice / agreement (if business payment) c. Loan agreement / repayment schedule (if loan) d. Property sale deed / agreement (if property sale proceeds) e. Any other relevant proof 4. Written explanation detailing the nature of transactions

Legal Basis

The process for removal of hold/lien is governed by Section 10.1 of the Standard Operating Procedure (SOP) for NCRP-CFCFRMS, Custody, Restoration of Money and Grievance Redressal, issued by MHA, GoI, dated 02.01.2026. The interim restoration of funds to a victim from a suspected account is governed by Section 106(3) of BNSS 2023 (equivalent to Section 102(3) of CrPC). If the matter reaches court, applications may be filed under Sections 497, 498, or 503 of BNSS (formerly Sections 451 or 457 CrPC) for disposal of held amounts.