A briefing from Drystone Chambers says that, according to its author, while it may seem straightforward, it can be hard in practice to determine when a bank account is not a bank account. This is said to have caused a number of Asset Freezing Orders to be discharged; where orders have frozen Forex trading accounts, ISA fund accounts, or other accounts which contain money but do not meet the definition. In-depth checks are required to determine if an account is an account to which the legislation applies (see section 303Z5 of POCA 2002, inserted by the Criminal Finances Act 2017), you have to determine what the regulated body behind the account is authorised to do.
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