A hold on bank funds may arise from different authorities and procedures. In September 2026, ASFI clarified that, for municipal tax obligations in La Paz, the competent authority issues the order and the financial system executes it. Before paying, challenging or requesting release, it is therefore important to identify who ordered the measure, the debt supporting it and the procedural stage of the matter.

1. The bank does not order the hold on its own

ASFI states that a fund hold is not ordered by ASFI or by the financial institution. The instruction comes from a competent authority — which may include a court, the Public Prosecutor’s Office, the Bolivian Tax Service (SIN), Customs, the Gaming Authority or a municipal government — and is then routed for execution. In the matter reported by ASFI on September 10, 2026, the orders came from the La Paz Municipal Tax Administration for vehicle and real-estate tax debts.

2. Information to request immediately

A practical first step is to ask the financial institution for the origin, amount and reason for the hold and for a copy of the legal instruction supporting it. Those details help identify the issuing authority and the underlying administrative or judicial file. Acting only on a banking-app screenshot or verbal information is usually not enough.

3. Notice and procedural history

The authority ordering the hold must notify the affected person through the channels applicable to the relevant proceeding. The file should therefore be reviewed for resolutions, notices, dates, procedural addresses and prior tax-assessment or collection actions. The existence of a hold does not, by itself, establish that every prior procedural step was valid.

4. Funds that may be legally protected

ASFI notes that financial institutions must respect funds corresponding to wages, salaries, pensions, retirement benefits and social benefits that are legally protected from attachment, subject to the applicable legal conditions. If the hold reached such funds, their source should be documented before requesting the appropriate relief.

5. How is a hold released?

The bank cannot simply lift the measure at its discretion. ASFI explains that the competent authority that ordered the hold must issue the release instruction, which is then routed to the financial institution. The legal strategy must therefore address the underlying proceeding: payment or regularization when appropriate, a payment plan, clarification, challenge or another remedy available under the applicable rules.

6. If the debt is administered by SIN

Bolivia’s Tax Code authorizes the Tax Administration, during tax enforcement, to adopt coercive measures including retention of payments owed by third parties to the debtor to the extent necessary to secure collection. In 2026 the SIN also adopted payment-plan measures and, under RND 102600000022, a procedure through which eligible taxpayers may request use of retained funds for the initial payment or cash guarantee of a payment plan.

7. Documents useful for a legal review

For an initial assessment, it is useful to gather the hold instruction, bank statements or notices, resolutions and notices issued by the authority, identification of the tax obligation, payment receipts and any prior filings. This makes it possible to distinguish among an unpaid debt, a notice issue, a measure that should already have been lifted, or another situation requiring a specific procedural response.

Official references

ASFI – Guidance on fund holds and the authority ordering them ↗SIN – Use of retained funds for payment-plan initial payment and guarantee ↗SIN – Law No. 2492, Bolivian Tax Code ↗

This article is general information prepared from the official sources listed above. Rules and procedures may change and the specific file should be reviewed before taking action.

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