What is a Customer Information Order?

We are increasingly approached by individuals and/or companies who have had their personal and/or business bank account(s) frozen by virtue of an Account Freezing Order (“AFrO”) where they are adamant there has been no breach of any applicable laws and regulations.

In some cases, the relevant authorities may have proceeded to apply for an Account Forfeiture Order (“AFO”).

In addition, we are starting to be approached by individuals and businesses who have been affected by a Crypto Wallet Freezing Order.

Below, we examine all these measures in more detail.

What are some of the less well-known measures?

There are also several other less well-known measures that could be used, often earlier, in any financial crime investigation.

Recently, we examined another less well-known measure that could be used much earlier in a financial crime investigation, specifically the Account Monitoring Order (“AMO”).

In our latest article on this topic, we examine a further less well-known order, specifically – a Customer Information Order (“CIO”).

What is a Customer Information Order?

In the context of a police or National Crime Agency financial crime investigation, a CIO is an order made by a Court requiring a financial institution to disclose whether a specific person of entity holds an account, and to provide details of any such accounts.

To grant a CIO, the appropriate officer (e.g. the police or the NCA) must persuade the Judge that there are reasonable grounds to suspect that the person is involved in the specific criminal activity being investigated.

A CIO can be used by law enforcement agencies to quickly establish whether a suspect individual or entity uses (i.e. holds account(s) with) a specific financial institution which can then be further investigated (e.g. by way of an AMO).

CIOs can be issued in relation to financial crime investigations, including confiscation, civil recovery, exploitation proceeds and money laundering investigations.  AMOs cannot be issued in relation to detained cash, detained property investigation or frozen funds investigations.

How to challenge a Customer Information Order?

Any person affected by a CIO (i.e. the financial institution or the customer) may apply to the court that issued the CIO for a variation or discharge thereof.

Given that a CIO indicates a financial crime investigation, it is recommended to seek urgent legal advice to assist with any application to vary or discharge the AMO.

What is an Account Freezing Order and Account Forfeiture Order?

In previous articles, we have extensively discussed what AFrOs and AFOs are and the Serious Fraud Office’s use of AFrOs.

What is an Account Freezing Order?

The rise and fall of the Serious Fraud Office’s Account Freezing Orders?

How to challenge an Account Freezing Order or an Account Forfeiture Order?

What is a Crypto Wallet Freezing Order?

We have also discussed what a Crypto Wallet Freezing Order is.

Serious Fraud Office secured first Crypto Wallet Freezing Order

Crypto Wallet Freezing and Forfeiture Orders: what do the numbers say

What does all this mean?

The relevant authorities are increasingly turning to AFrOs and AFOs (and their crypto-related equivalents) to disrupt alleged criminal conduct.

Prior to your account being made subject to an AFrO or AFO, you may have found that your bank account has been closed, which can be an indication of a whole host of other issues.

NAVIGATING FINANCIAL INSTITUTION-RELATED CHALLENGES

What can I do to try and challenge a wrong decision to close my personal and/or bank account(s)?

In the meantime, we are increasingly being approached by individuals who have been “de-banked” in circumstances where they feel that they have always acted in full compliance with the relevant bank account’s Terms and Conditions and all other legal and applicable rules and regulations.

We have previously written about how other issues individuals may face, including account closures, are not limited to political figures in the UK and affect many thousands of lawful individual and business customers every year.  These cases have exposed the difficult balance many financial institutions and their individual and business customers must navigate to gain and maintain access to basic banking services.

To assist those whose accounts have been closed, Gherson’s Financial Crime, Investigations and Regulatory Team have previously written blogs titled:

“Why has my bank account been closed?”

“Why has my business bank account been closed?”

“140,000 SMEs “de-banked” last year – why could I have been de-banked?”

“What are the proposed new laws aimed at preventing de-banking?”

“Why the proposed new laws to try and prevent de-banking to not go far enough”.

“Am I entitled to a basic bank account in the UK?”

“How to challenge crypto-related bank account closures”

“De-banking and crypto – will the landscape be positively changed by the introduction of new rules for both?”

What can I do to try and challenge a wrong-imposed CIFAS marker

We are also being increasingly approached by individuals who feel that a financial institution has wrongly imposed a CIFAS marker in their name.

If you have always acted in full compliance with the relevant bank account’s Terms and Conditions and all other applicable legal rules and regulations, then you should have a good basis to challenge the bank’s decision to implement any CIFAS markers.

A strong challenge will often involve demonstrating through evidence that you have not breached the bank’s Terms and Conditions or any rules and regulations, and that all transactions were at all times done in full compliance will all applicable laws and regulations.

In a previous blog, we examined what a CIFAS marker is and how to try and get it removed, as well as what you can do if a CIFAS marker has been wrongly imposed.

We have also looked at Challenging a crypto-related CIFAS Marker: what you can do.

Adverse information on compliance databases

We are also being increasingly approached by individuals who feel that incorrect and/or inaccurate data about them stored in compliance databases is having an adverse effect on their relationship with financial institutions and are facing subsequent issues, such as bank account closures or difficulties in opening a bank account.

We have also written a series of blogs on a basic overview of the main functions of compliance databases like World-Check and how you can correct information about yourself on such databases?

HOW GHERSON CAN ASSIST

Gherson’s Regulatory, White-Collar and Investigations team are highly experienced in providing assistance on what you can do if your bank freezes or closes your account.  This includes assisting you in submitting a request under data protection legislation, otherwise known as a Data Subject Access Request, to ascertain what information banks and other financial institutions may be holding on you and their decision making, and then analysing the response and assisting with any appropriate challenge.

If you have any questions arising from this blog, please do not hesitate to contact us for advice; send us an email at enquiries@gherson.co.uk or alternatively, follow us on X, Facebook, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2026