The Exchange Has Frozen My Account and I Can’t Withdraw My Crypto

A frozen account is not one thing. Withdrawals may be suspended while trading still works, the whole account may be locked, a single asset or address may be blocked, or one transaction may be on hold pending review.

Ask the platform in writing to state what has been restricted, on what date, and under which clause of its terms. A written answer — or a refusal to give one — is often the most useful document a lawyer will have later.

Many freezes are not a refusal to pay you but compliance or anti-money-laundering holds: a source-of-funds query, an unfinished identity check, a sanctions flag, or a transfer that failed travel rule checks. VARA implemented new travel rule requirements on 24 February 2026.

The distinction matters because the response differs completely. A compliance hold is usually resolved by giving the platform what it asked for, properly and once. Treating a documentation request as a fight tends to extend a hold rather than shorten it.

Work out the platform’s real status rather than the one it advertises. VARA covers Dubai outside the DIFC, the DFSA the DIFC, the FSRA ADGM, and the CMA onshore UAE and the ordinary free zones. A claimed licence can be checked.

Be precise about the entity. Large exchanges operate through groups, and the company named in your terms of service may not be the one holding any UAE licence. The name on the app is not the answer; the name on the contract is.

VARA publishes enforcement actions on a standing public register and issues individual regulatory notices, including notices of fines and alerts addressed to investors and the marketplace. If your platform has already been the subject of one, you may be one of many.

Separately, VARA maintains a Public Register of virtual asset service providers, and this is where people misread things. The register lists firms that are fully licensed **and** firms that hold only an In-Principle Approval. VARA states that an In-Principle Approval is a conditional step in the licensing process, and that applicants holding one are strictly prohibited from initiating operations, conducting virtual asset activities or servicing clients until they obtain the full licence. So finding a platform on the register does not mean it was entitled to take your business — you have to read which status it holds.

The check costs nothing and is easy to skip. Take a dated copy of whatever you find, including the status shown. If nothing appears at all, record that too — the regulatory route may be thinner than you hoped.

An unlicensed platform marketing into the UAE is not automatically beyond reach. VARA’s Marketing Regulations 2024 apply to domestic and foreign entities alike, covering marketing in or targeting the UAE. An entity sits outside them only if all three conditions hold together: not located in the Emirate, conducting no virtual asset activity there, and doing no marketing in or targeting the UAE.

One correction is worth making, because much commentary gets it wrong: those regulations and their guidance contain no reverse-solicitation safe harbour. The DIFC does have an express unsolicited-request exemption under Article 41A of the Regulatory Law 2004; the ADGM position is not established on the sources checked.

Export your transaction history, statements and balances now, in whatever formats the platform allows, and save them outside it. Screenshot the account showing the restriction, with the date visible. Keep every message, ticket number and automated email.

Keep whatever first brought you to the platform as well — the advertisement, the social post, the referral message, the onboarding emails. If the marketing rules become relevant, that material is the evidence.

Where a platform is genuinely licensed, a complaint to its regulator is usually the first serious step, and in Dubai a grievance route exists under Administration Resolution No. 3 of 2023. A regulator supervises the firm rather than compensating customers.

The civil route — a claim in the DIFC Courts, the ADGM Courts or the onshore courts, depending on where the entity sits — is what can order payment, but it needs an identifiable defendant who can be served. Nobody can promise your assets will be released.