Sylwester Suszek – The Exit, in Five Acts

2026-04-21

By Robert Nogacki · Skarbiec Law Firm · April 21, 2026

On April 16, 2026, the president of zondacrypto, a Polish cryptocurrency exchange, announced that the firm’s reserves were inaccessible. The keys to the cold wallet, he explained, had been taken by his predecessor, who had vanished in 2022 and never been found. Commercial registries in four countries—Britain’s Companies House, Switzerland’s Handelsregister, the Czech Sbírka listin, and Estonia’s Äriregister—tell a different story. By the time Sylwester Jan Suszek disappeared from a gas station in Czeladź, in Upper Silesia, on March 10, 2022, he no longer held any formal position in the BB Trade group. The last of them, the presidency of the Estonian operating company, had slipped from him four months earlier. The first, control over a British subsidiary, eight months earlier. In the interim, his roles had been taken up, jurisdiction by jurisdiction, by the same man who now speaks to clients about missing keys. If this was a disappearance, it was an uncommonly well-prepared one. The story ends on a Bahamian note that looks like the setting of a James Bond film. In a certain sense, it is one.

I.

In the canton of Zug, a six-hour drive from Czeladź, a Swiss notary pressed his seal to the articles of a new company on June 14, 2021. Ten days later, the firm entered the commercial registry. Its name was Divisio Holding AG. Its number, CHE-161.370.248. Its first address was at 14 Chamerstrasse, care of Afrag AG—a Swiss domiciliary address of the familiar sort, one of dozens registered to the same doorstep. This is how an AG is incorporated in Switzerland: one rents the name-plate of a firm that sends out invoices later. Seven months after its founding, Divisio would move a short distance away, to 78 Baarerstrasse, into the chambers of Dr. André Terlinden. Same Zug, different lawyer.

The share capital was a hundred thousand Swiss francs, fully paid, divided into a thousand registered and restricted shares. The sole shareholder: Przemysław Janusz Kral, born in Bytom, Poland; by profession, an attorney. The corporate purpose was to hold and manage equity interests—and, in a clause to which we will presently return, “Die Gesellschaft kann ihren direkten oder indirekten Aktionären oder Tochtergesellschaften Darlehen gewähren”. The company may extend loans to its direct or indirect shareholders and to its subsidiaries. An unremarkable provision, until, three years later, that same company lends someone within its own group seventy-five million euros’ worth of Bitcoin. The loan is denominated in Czech, booked in Estonia, and given the name Laen 7—a name in a language no one uses to do business in any of the jurisdictions involved. But that is getting ahead of the story.

Six days after its registration, on June 30, 2021, Divisio purchased its first asset: a company in England and Wales, No. 12800239, which had been incorporated ten months earlier in Telford, at 1 Wellington Road, Donnington. Its name was BB Trade Pro Limited. Its capital consisted of a hundred ordinary shares at a pound apiece. Its shareholder was a Luxembourg entity, Luxbay SA, at 2 Place de Strasbourg—an address to which, some years before, Sylwester Jan Suszek had quietly relocated, during the period when the Polish press still thought of him as a Silesian businessman from Katowice.

The British company’s SIC code was 82990, Other business support service activities. It is the code chosen by firms that do not yet know what they will do. Or know, and would rather not say. It is, in the British register, the equivalent of the Czech “hire and leasing of water vehicles” in a landlocked town.

The company had not been formed in order to be sold for a hundred pounds. That would have been the joke. The company had been formed as a vehicle for the transfer of control. In Zug, one does not establish an AG in order to buy a corner shop.

II.

At Companies House, documents are scanned in black and white and stamped with a barcode. Barcode XA9LAE2W is Form CS01, a Confirmation Statement, filed on July 27, 2021. Barcode XA9LADUZ is Form PSC07, a notice that a person has ceased to be a Person with Significant Control. Barcode XA9LADXS is Form PSC02, a notice of a Relevant Legal Entity assuming the same role. Three separate sheets. Each describes a different facet of the same event. All three are dated June 30, 2021. The event they record is simple: Sylwester Jan Suszek ceased to be the person controlling BB Trade Pro Limited. Divisio Holding AG took his place.

In the Nature of control field: “the relevant legal entity holds, directly or indirectly, 75% or more of the shares in the company.” Plain, correct, without flourish.

It is worth noting what did not happen. There is no trace, in the British register, of a dispute, an illness, a debt. It is a notarially smooth transfer. Luxbay SA—the Luxembourg company Suszek ran together with a man named David Luksenburg (at a certain point in a lawyer’s career, he stops remarking on such names, because he would be remarking on them too often)—sold its hundred shares of its British subsidiary to a freshly minted Swiss parent. The parent had come into being the week before. It had one owner. And that owner was the man who, over the following eight months, would quietly, methodically, jurisdiction by jurisdiction, acquire everything Suszek still held.

III.

In Ostrava, in the Moravian-Silesian region of the Czech Republic, at V Zátiší 810/1, a company called EXPOFÉR SERVIS HOUSE s.r.o. has existed since 2018. The firm was originally formed the year before, in the hamlet of Dolní Marklovice, and relocated to Ostrava in the spring of 2018. The listed line of business, in its early filings, was cautiously general: an unrestricted trade license and the lease of real estate. But in the notarial deed NZ 37/2024, to which we will come, a different phrase appears, and it is the phrase that explains why this particular company matters at all. Hire and leasing of water vehicles.

Boats.

The Czech Republic is, as is known, not a country where one sees the sea. Ostrava sits on the Oder, which in Ostrava is some forty meters wide and flows northward. It is navigable, mostly in the sense that it flows. One does not see yachts. One can, with effort, imagine a kayak. A Czech company whose declared business is the leasing of water vehicles, registered seven hundred kilometers by land from the nearest coastline, is a construction at which any lawyer must permit himself a small smile. Not from malice. From a certain sympathy for the language of business, which in such moments simply loses its footing.

The balance sheets filed under the registry reference C 70610/KSOS look, in the early years, the way a small Czech boat-rental company’s ought to look. Assets around fourteen million Czech koruna. Negligible equity. Four employees. Modest turnover. In 2018, a loss. In 2019, a larger one. And in 2020, the first thing no ordinary business misfortune can account for: the average number of employees falls to zero. The company that is supposed to hand kayaks to somebody no longer has anybody to hand them. Formally, the business continues. Operationally, the company is hollow.

Someone then begins to fill the hollow company. The capital reserve account (Ážio a kapitálové fondy, the line through which a shareholder injects cash outside the nominal share capital) rises in 2020 to sixty-nine million koruna. But the real wave arrives the following year. On the closing balance sheet for 2020, the company’s intangible assets stand at zero. On the closing balance sheet for 2021, they stand at 178.5 million koruna. Over twelve months, in a Czech boat-rental firm with no employees, intangible assets worth about seven million euros appeared out of nothing.

Intangible assets are the balance-sheet line where one stores the things one cannot see. Licenses. Know-how. Software platforms. The question rather asks itself: what intangible assets can a boat-rental company without employees possibly hold? One does not find out from the balance sheet, which is not in the business of explaining. The balance sheet is in the business of writing down a number.

The capital reserve rises alongside. In 2021, the shareholder contributes 214 million koruna—nearly nine million euros in a single year. In 2022, another 113 million. In 2023, another 260. By the end of 2023, the capital reserve stands at 657 million koruna, or twenty-six million euros. The intangible assets stand at 543 million koruna, or twenty-two million euros. Still no employees. Still no auditor—as a small entity, none was required.

On September 24, 2021—fewer than three months after Divisio’s acquisition of the British BB Trade Pro Limited—Divisio Holding AG became the sole shareholder of EXPOFÉR. Three months after that, on January 3, 2022, in Zug, Terlinden signed his next document. Acting on behalf of Divisio in its capacity as the jediný společník, the sole member, of EXPOFÉR SERVIS HOUSE s.r.o., he adopted a rozhodnutí jediného společníka. The document was executed in Zug. Three weeks later, on January 24, 2022, a Polish attorney practicing before the Czech bar, Mgr. Romana Mrózková, reg. no. 4509, performed its electronic conversion for the Czech registry, under the reference 145298160-133164-220124135503. The text, in bilingual Polish and Czech—because it concerned Polish citizens—reads:

“odvolává stávajícího jednatele pana Sylwestra Jana Suszka, nar. 28.12.1987, bytem 41-902 Bytom, ul. Gliwicka 18/3, Polská republika, z funkce jednatele a jmenuje nového jednatele pana Przemysława Janusza Krala, nar. 1.6.1980, Gawronów 22, 40-527 Katowice, Polská republika”.

It removes Suszek. It appoints Kral. A Czech document, two Polish citizens, a Swiss company as shareholder, an Ostrava boat-rental company as its object. Four jurisdictions on a single sheet of paper.

Between that January day in Zug and the day Suszek would disappear in Czeladź, nine weeks would pass.

IV.

A great deal has been written about March 10, 2022—all of it, and then some. It was three in the afternoon. It was March, and March in Czeladź is the kind of month in which, if it is not raining, it ought to be. Sylwester Suszek left a business meeting at a fuel depot belonging to his associate. He got into his car. The depot’s surveillance system—as in any good crime novel, or any very bad one—happened to be down. The associate explained that there had been a malfunction. In Polish fuel depots, malfunctions of this kind occur at a frequency that might merit its own study.

Four days later, Suszek’s phone registered somewhere near the A1 motorway, in a place to which no one who knew him could have imagined him going by choice. Then the phone fell silent, like everything else. For four years, his sister has said in interviews that she is certain her brother is dead.

This is the version one knows. It is also the version in which March 10, 2022, is the first day of the story.

Let us set the clock a different way. Eight months after June 30, 2021. Five months after November 5, 2021. Two months after January 3, 2022. By that March day, Suszek no longer formally controlled BB Trade Pro Limited. He was no longer the jednatel of EXPOFÉR. And—this is the point that today deserves particular attention—he was no longer the president of BB Trade Estonia OÜ, the operating Estonian company that held the exchange’s license and its clients. The Estonian registry had removed him on November 5, 2021. Three days later, on November 8, 2021, Przemysław Kral had assumed the presidency. On that same date, the exchange ceased to call itself BitBay and began to call itself zondacrypto.

Which means that at the moment he disappeared in Czeladź, Sylwester Jan Suszek held no formal position of any kind in the BB Trade group. None. He had descended the ladder over eight months, one rung at a time. The first rung was removed on June 30, 2021, in Companies House. The second on September 24, 2021, with the transfer of the EXPOFÉR shareholding to Divisio. The third on November 5, 2021, in the Estonian register. The fourth on January 3, 2022, with the Czech removal as jednatel. When, on March 10, 2022, he vanished physically in Czeladź, there was no longer any jurisdiction from which one could have removed him by document.

The man disappeared at the moment when the structure was ready for him to disappear.

The sequence—United Kingdom, Switzerland and the Czech Republic, Estonia, the Czech Republic again—has a certain property. It is descending. First, a peripheral company in a tightly supervised jurisdiction. Then the holding company in Switzerland and the operating one in the Czech Republic. Then the Estonian entity that held the clients. Finally, the physical vanishing in Poland. As if someone were peeling the man away in layers, beginning with the layer held by the hardest registry to falsify, and ending with the layer held by the body.

The consolidated financial statement of BB Trade Estonia OÜ for 2022, signed by the new board on January 12, 2024, does not mention Suszek a single time. It does not say when he ceased to be president. It does not say how Divisio Holding AG came to control the company, though control it does: in the statement, Divisio appears as emaettevõtja, the parent entity. The statement begins its account of the board’s activity on December 10, 2023—when Guido Bühler joined, and the board became a body of three—as though the company had not existed before.

The auditor, Assertum Audit OÜ, issued a qualified opinion. The reason was put plainly: the auditor was unable to confirm the existence of cryptographic assets with a stated balance-sheet value of a hundred and fifty-five million euros. The third-party service providers said to hold them do not issue backward-looking confirmations. For the year 2021, the previous auditor, Crowe DNW OÜ, had declined to issue any opinion at all. Kral’s statement of April, 2026—that the reserves are inaccessible because the keys to the cold wallet are with the missing predecessor—is therefore not new information. It is the formal articulation of a problem that auditors had been signaling in the company’s own filings since 2022. The Katowice Regional Prosecutor’s Office has confirmed publicly that the exchange “has not had access to its so-called cold wallet since 2022.”

There is a criminal scenario—that the disappearance on March 10 was a crime, a killing or a kidnapping, and that the entire preceding sequence has some independent explanation, unrelated to the gas station. This scenario would require a rather elaborate construction. One that would account for why, in the eight months leading up to that March, in four jurisdictions, in favor of a single person, Suszek had been stepping in orderly fashion out of the structure he had built. No such construction has been offered.

There is also a second scenario. A simpler one.

V.

When the German fintech Wirecard AG collapsed under the weight of its own deceit—on June 18, 2020, its auditors at Ernst & Young refused to sign the accounts; on June 25, the firm filed for insolvency—it emerged that 1.9 billion euros of its stated reserves did not, in fact, exist. Its chief operating officer, Jan Marsalek, was already in the air on June 19, 2020, aboard a private plane departing Bad Vöslau, a small aerodrome outside Vienna. The plane flew to Minsk. Waiting in Minsk was a man named Stanislav Petlinsky, a Russian intermediary who had booked the flight in another name. He made the onward arrangements.

The public was given the story that Marsalek had flown to the Philippines. “To find the missing reserves.” The Philippines later said officially that he had never crossed the border, and that entry documents had been forged. He was in Moscow. One does not, as a rule, look for 1.9 billion euros in the Philippines, except perhaps in the sand; but the story held, in the press, for weeks. Which says something about journalism. And something sadder about public attention.

The reader reads this six years later, and the rest is known. Bellingcat, Der Spiegel, and The Insider have established that Marsalek’s first documented meeting with an officer of the Russian military intelligence service, the GRU, took place on July 6, 2014, in Nice. That Wirecard, a payments company, ran for years something in the nature of a covert financial channel for Russian operations in Libya and Syria. That Marsalek’s trips to Russia—Bellingcat counted more than sixty—were made using multiple Austrian passports, and left traces in Moscow border databases where entries of protected persons are logged.

The London trial of a Bulgarian espionage network, which concluded in guilty verdicts in March, 2025, proved that Marsalek directs from Moscow a network of operations against European journalists and dissidents. In Russia, he lives under two established identities: “Konstantin Bayazov,” described as an Orthodox priest, and “Aleksandr Mikhailovich Nelidov”. Under the second, he was seen in occupied Crimea in 2023.

All of this—and I write this conscious that a lawyer is writing, not a journalist—is in the Marsalek case not hypothesis. It is fact.

The most important lesson of the Marsalek case is this: the disappearance of such a man is not the first day of the story. It is the last. For nearly a decade before the night of June 19, 2020, Marsalek had been building his way out. Passports, Moscow contacts, financial channels, substitutions. On that night, he simply boarded a plane that had been waiting in a queue for years.

In the Suszek case, we do not have a decade documented. We have, on the registry side, eight months. Eight months in which, across four countries, the same man descended the rungs of a structure he had built, and rung by rung another man took them over. And those eight months—let me be clearly understood—are only what the commercial registers make visible. What may have been happening earlier, beyond the reach of registers, requires a different kind of inquiry.

The Russian angle in the Suszek case is not, today, documented in open sources. I make no claim. I merely note that Central and Eastern European cryptocurrency exchanges, in the period from 2018 to 2022, faced an operational question: what to do about clients from sanctioned jurisdictions. From Russia, Belarus, and later Iran. I note that a 2020 Polish investigative television program, Superwizjer on TVN, identified among the associates of BitBay—the predecessor of zondacrypto—persons connected with organized crime. And I note that the architecture of the present-day group—two Luxembourg companies at 2 Place de Strasbourg, a Swiss Divisio, an Estonian license, a Czech EXPOFÉR with twenty-two million euros in invisible assets, and a Bahamian BB Trade Bahamas Ltd added in 2024—is consistent with an operational model in which offshore entities handle clients the principal license may not. Whether that model was in fact executed, I do not know. I know that the apparatus enabling it is in place. Paid for. Plugged in.

A person who had stood atop such a structure for five years would be, in the taxonomy of foreign intelligence services, an asset of more than trivial value. In the Marsalek case, that taxonomy ended as we now know it to have ended.

VI.

In November, 2022, nine months after Suszek’s disappearance, something began to take shape at EXPOFÉR SERVIS HOUSE s.r.o. The company was still, formally, in the business of unrestricted trade licenses and property rental, but it was no longer Suszek running it. It was Kral. For a year, the balance sheet continued to swell, with intangible assets rising from thirteen to twenty-two million euros. Then, on January 16, 2024, by notarial deed NZ 37/2024, executed in Ostrava by Mgr. Jan Mihálik, Divisio Holding AG—this time represented by Mgr. Romana Mrózková, acting under a power of attorney granted the previous month in Zurich by Terlinden and authenticated by the Zurich notary Beat Buxcel—adopted a resolution to change the company’s business purpose.

From the leasing of boats.

To a list of thirteen new categories. The more eloquent items, in the Czech original, read: “Poskytování služeb spojených s virtuálním aktivem” and “Poskytování služeb pro právnické osoby a svěřenské fondy”. Services connected with virtual assets. Services for legal entities and trusts. A Czech company seven hundred kilometers from the sea, with twenty-two million euros of unseen assets, became, in January of 2024, a Czech provider of virtual-asset services and services to trusts. In a company that had never held a single private cryptocurrency, or a single trust.

Or, for that matter, a single boat.

One could file all of this under the heading of a Central European anomaly. Except that the same move was repeated, eleven months later, in Poland.

On December 17, 2024, three changes were entered in a single day into the Polish commercial registry, KRS 0000847033. First: the company KP IMMOBILIARE sp. z o.o.—the same company whose Katowice address at Gawronów 22 had appeared in the document removing Suszek from EXPOFÉR—changed its name to BB TRADE POLAND sp. z o.o. Second: the existing shareholder, Kral with one hundred percent, was replaced by Divisio Holding AG. Third: the principal listed activity was changed from real estate (PKD 68.10.Z) to other financial service activities (PKD 64.99.Z), with IT programming codes and financial-support codes added alongside. The amendments to the articles were executed by the Katowice notary Agata Niełacna-Szopa, Rep. A 3498/2024.

This is no longer a singular anomaly. It is a pattern. The same man, in the same year, in two different jurisdictions, took a peripheral company with an entirely different purpose, folded it into his Swiss holding structure, and reoriented it toward virtual-asset or financial services. A Czech one, with 543 million koruna of intangible assets appearing from nowhere. A Polish one, formally empty, with a share capital of five thousand zloty, but charged with the “BB Trade” brand just as that brand was being relocated out of its original Polish operational homes. Two separate vehicles, one scheme.

A brief Polish epilogue is worth recording. On September 15, 2025, by a resolution numbered 1, Rep. A 2897/2025 (again before Niełacna-Szopa), the shareholder, Divisio Holding AG, resolved to dissolve BB Trade Poland sp. z o.o. and to open its liquidation.

VII.

The final date in this story is also the most puzzling.

In Luxembourg, a company called S&B Investment SA, RCS B237594, exists at 2 Place de Strasbourg. The same address at which Luxbay SA is registered. The same address Suszek gave as his service address at Companies House. One address, an entire warehouse of companies—a Luxembourg specialty.

S&B was formed in September, 2019. In its early years, its directors were Suszek and the same David Luksenburg. The company held interests in various entities of the group, among them Murano Estate and the old BB Trade Poland.

On November 14, 2023, the board of S&B Investment SA was altered. Kral became a director. Suszek was removed.

November 14, 2023. A year and eight months after Czeladź.

For the 614 days between March 10, 2022, and November 14, 2023, S&B Investment SA filed annual accounts, changed addresses, restructured partnerships, issued powers of attorney. It functioned. And one of its two directors, formally, was a man no one could find. The Luxembourg commercial register was accepting documents that someone must have been signing in his name.

There are three scenarios, and only three. Either in Luxembourg it was not known that Suszek had disappeared—which requires the premise that Luxembourg lawyers do not read newspapers or use the internet. Or Suszek had, before March 10, 2022, executed powers of attorney of broad scope, and those attorneys-in-fact acted in his name over the following 614 days; in which case their names must be in the Luxembourg register. Or Suszek himself signed the documents over those 614 days, which means that someone, somewhere, was in contact with him.

Each of these scenarios alters the rest of the story differently. The first is implausible. The second and the third are, in their consequences, of the greatest interest.

VIII.

Eight months. Four jurisdictions. One missing man. One successor. Two parallel cycles of structural transformation in two countries. An Estonian operating company Suszek left four months before Czeladź. Auditors who, for two consecutive years, have been unable to confirm the existence of clients’ assets.

I will close as one ought to close a text about a disappearance.

If a Polish client of zondacrypto wished to understand where his money may have gone, he ought to begin not with the terms and conditions but with a weekend’s viewing of the James Bond films. The terms and conditions are a legal bore. The series is twenty-five films. Both sources lead to the same place.

The Bahamas.

In Casino Royale, Bond meets Le Chiffre at the Ocean Club in the Bahamas. In Thunderball, Emilio Largo sinks stolen atomic bombs off the coast of New Providence, in the Bahamas. In Licence to Kill, Franz Sanchez runs his business there. The cinema has chosen the island as the setting for money-laundering, vanishings, and the discreet settling of matters no one could settle elsewhere. The screenwriters were not particularly imaginative. They had merely been reading the papers.

FTX Digital Markets, Sam Bankman-Fried’s firm, registered in Nassau under the Digital Assets and Registered Exchanges Act, abbreviated DARE, collapsed in November, 2022, with an eight-billion-dollar hole in its balance sheet. The legal architecture was unimpeachable. The clients did not get their money back.

Why the Bahamas? Geography, yes. Climate, yes. But above all: they are far away. Far from Warsaw, from Brussels, from Frankfurt, from Tallinn. Far even from Miami, though from Miami it is an hour’s flight. Distance in the regulatory world is not measured in kilometers, but in the number of mutual legal assistance requests that must be filed before a prosecutor can see a document. By that measure, the Bahamas are very, very far away.

The Securities Commission of The Bahamas maintains a register of digital asset businesses authorized under DARE. It is the same regulatory category in which FTX Digital Markets had operated. On the register, as of November 30, 2025, one finds BB Trade Bahamas Ltd., a Bahamian company of the Zonda group, consolidated in 2024. Let us examine the entry more closely.

Address: 201 Church Street, Sandyport, Nassau. Website: TBD. To Be Determined. Five months after registration, the company under the supervision of the Bahamian counterpart of the SEC has no website. They have not yet decided. Telephone: a Polish mobile number. In the official register of the Commonwealth of the Bahamas.

Principal: Przemysław Kral. Directors: Kral, Dawid Sendecki, Guido Bühler, Reece Chipman. The CEO is the last of the four. Compliance Officer: Samuel Wilkinson. Money Laundering Reporting Officer: Samuel Wilkinson. Two control functions which, in any reasonable regulatory regime, must be separated because one controls the other, here integrated in a single person. Mr. Wilkinson controls Mr. Wilkinson. The results of the inspection are known to Mr. Wilkinson. Mr. Wilkinson has no objections to raise.

Registration: Approved on Condition. Conditional. What the conditions are, the register does not disclose. How many there are, it does not disclose. Whether they have been satisfied, it does not disclose. We do, however, know that they exist. That, at least, is something. Sanctions: None. Not yet. Other licenses outside the Bahamas: None. In a group declaring activity in Malta, Estonia, Italy, and Poland, the Bahamian company is a jurisdictional island unto itself.

FTX Digital Markets, too, had been registered under DARE. FTX Digital Markets, too, had been based in Nassau. FTX Digital Markets, too, had had a single person controlling the structure through the apparatus of directorships. Sam Bankman-Fried later testified in federal court that he had never intended to defraud anyone. The jury concluded otherwise. I am not comparing Zonda to FTX. I am comparing the Bahamian DARE register to the Bahamian DARE register. What the two entries share, first, is the legal architecture. Second, the geography. Third—and this is the most interesting part—the fact that these are jurisdictions chosen not because they are the best, but because they are the farthest.

A Polish client who, in April, 2026, cannot withdraw his Bitcoin from a platform in Tallinn, will one day attempt to recover it from Nassau. He will fill out the forms of the Securities Commission of The Bahamas. He will call the Polish mobile number listed in the Bahamian supervisory register. Everything will be in perfect order.