Fintech Lab
Lesson 18Risk and operationsIntermediate
Sanctions and the wallet freeze
A regulatory hold is reclassification, not removal.

A user gets flagged by your KYC team, possible sanctions match, awaiting manual review. Their wallet funds must be frozen: they cannot withdraw, transfer, or spend. The money is still yours-on-paper (you still owe them) but it must be unspendable. The pattern: move the funds from an 'Available' liability sub-account to a 'Frozen' liability sub-account. Total liability unchanged; classification changed.

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