Our company has a business PayPal account. We received a payment from a client/customer via PayPal payment plaftorm online via credit card for $ XXXX. PayPal immediately provided full credit of the payment to our business account on the same day the payment was made and invoice was annotated on PayPal 's online system as, " Completed. '' Again, the client has been provided with the service and was invoiced for that service. Approximately 4-days later, PayPal 's Risk Operations Department initiated a limit to our account for the remaining funds available in our business - $ XXXX. A telephone call was initiated with PayPal 's Resolution Team to discuss why a limit was put on our account. We complied with PayPal 's request for supporting documentation and online submission of explanations of specific transaction conducted on our business account - i.e. incoming payments between $ XXXX, along with providing documentary evidentiary support for the {$10000.00} credit card payment received, fully credited and processed by PayPal on the same day - without any limitations, holds and/or restrictions to access to those funds. After being provided with two separate email notifications by PayPal - detailing the 24-48hr turnaround response for resolution of the matter ; we were notified during a telephone call by XXXX of the Risk Operations Department that a " ... 180-day hold would be placed on $ XXXX, on our account for risk liability purposes to protect PayPal. '' Based on legal review of PayPal 's Acceptable Use Policy XXXX we were not told or lead to believe that PayPal 's de facto decision to withhold funds legally earned, paid, credited and utilized, were in violation of PayPal 's Acceptable Use Policy, as contained herein this complaint. Specifically, we were informed verbally and via email that the funds being withheld for 180-days are for the specific justification of maintaining PayPal 's Risk Liability at a level required by PayPal. PayPal subsequently - on the same day, before the close of the business banking day, after we communicating our intent of filing an official complaint with the XXXX Treasury - Office of Comptroller of Currency ; reactivated our business debit XXXX, and provided us access XXXX - which needed to be transferred from a XXXX currency accounts with PayPal XXXX. XXXX accounts have been placed at zero balances, because we were in need of payment of online subscription payments for online access to a private service. 
