Zondacrypto: Kral’s Defense Promises a “Vast Fortune.” We Took Inventory
The defense says the money exists. Zonda’s own filings, the blockchain, and a decade of landmark crypto investigations suggest exactly how to check.
Kancelaria Prawna Skarbiec · Robert Nogacki, Attorney at Law (radca prawny) · August 26th, 2026
Zondacrypto has entered a new phase: in late August, Roman Giertych, one of Poland’s most prominent defense attorneys, took over the defense of the exchange’s C.E.O., Przemysław Kral, and into the Zonda case came the sentence we had been waiting for since April: Kral, the defense announced, will put a vast fortune on the table. Two words in the Polish original, “ogromny majątek,” and not a single countable noun, yet for the first time since this story began, the defense and the victims are talking about the same object: Zonda’s money. For weeks we have been repeating that names without wallets should not be enough, and the phrase deserves precision at the outset, because it will carry this entire text: by wallets we mean cryptocurrency wallets, and strictly speaking the private keys to them, since in crypto the person who holds the key is the person who controls the funds. If the defense declares that the fortune is on the table, performance has exactly one verifiable form: surrender the keys, or transfer the assets to addresses secured by prosecutors. Balances on a blockchain are public; we can count them within hours. We therefore treat the announcement the way a good negotiator treats an opening offer: with complete seriousness and complete verification. What follows is an inventory, meaning everything that can be known today about Zonda’s assets from documents the company itself signed, from the corporate registries of half a dozen countries, and from the chain itself, together with the strategic arithmetic: what the declaration means, whom it is really addressed to, and what its performance would look like, to the benefit, as it happens, of every player at this particular table. Throughout, we mark what is certain, what is probable, and what nobody knows.
A Promise, Read Like a Chess Move
It began with a verb. Television dispatches in late August announced that the head of Zondacrypto had “become a small crown witness” and was giving extensive explanations to prosecutors. Grammar tends to be more precise than headlines: under Polish procedure, “explanations” (wyjaśnienia) are given only by a suspect or a defendant, so if the reports are accurate as to the act itself, the most important news is this: charges have been filed. Shortly afterward, Giertych confirmed that he had taken the case, and the promise of a vast fortune followed. The quotation is exactly that long, two words; everything beyond them, wallets included, is the language of this text, not of the defense.
Let us note something easily lost in the fever of headlines: this is a professional’s move. A defense lawyer of this caliber does not choose words casually, and the word “fortune,” in a case involving hundreds of millions, is not an ornament but the opening of a negotiation with the only party capable of accepting it. The law the declaration invokes has an entry price, and it is worth stating up front, because the rest of this piece is an itemized bill for that price. The colloquial “sixty,” from Article 60, Section 3, of the Polish Penal Code, is not a status but a sentencing directive: since an amendment effective October 1st, 2023, a court applies the extraordinary mitigation of punishment on the prosecutor’s motion, for a cooperating perpetrator who discloses the persons involved in the crime and its essential circumstances. The benefit is conferred in the judgment, sometimes years later, and after the judgment come the loyalty regimes of Articles 434, Section 4, and 540a of the Code of Criminal Procedure. The full crown witness, under the Act of June 25th, 1997, goes further: a mandatory condition of admission is the disclosure of one’s own assets and of the known assets of the other perpetrators, and the prosecutor may additionally condition the motion on the return of proceeds and reparation of the damage. We dissected the anatomy of both institutions in July (in Polish); today a single sentence of synthesis suffices: in both variants, the currency of the bargain is the same, assets disclosed and delivered, not announced. Hence the question of this report, plain as a court record: what fortune, whose, and where.
Method: The Documents They Signed Themselves
We do not have to guess, or take anyone’s word, including our own. There exist two documents that no one in this case can retract, because they were filed in the Estonian commercial registry under penalty of criminal liability and bear the C.E.O.’s qualified electronic signature: the consolidated annual reports of BB Trade Estonia OÜ, the Estonian company behind Zondacrypto, for 2023 (signed June 30th, 2024) and for 2024 (signed July 29th, 2025). The latter is also the last public X-ray of the company, full stop: no report for 2025 has been filed, and the registry carries a notice of the entity’s possible deletion.
They read like a roman à clef in which the key was left in the lock. The line assigning the 2024 profit, more than €34 million, contains one phrase: “futher investments,” typo included. Within one and the same report, the issue date of the company’s own ZND token appears once as October 18th and once as October 24th, 2024. The supervisory board planned from March, 2025, was to seat, alongside two financiers, Giorgio Chiellini, the Juventus defender. We mark this honestly: these are facts from the document, the highest level of certainty available; conclusions drawn from them are our interpretation, and we will flag them as such. Methodologically, we add to the filings three external instruments of measurement, each with a different evidentiary nature: the commercial registries of several countries, the public blockchains, and the accumulated experience of the great financial investigations, from Madoff to Bybit. A good inventory, like a good audit, rests on the confrontation of sources, not the selection of a convenient one.
A Balance Sheet of Other People’s Money
At first glance, the balance sheet is imposing: €768.2 million in total assets at the end of 2024, north of three billion złoty. Then one reads the other side of the same page. Liabilities to customers: €722.4 million. Equity: €35 million, less than five per cent of the balance-sheet total. Cash: €9.7 million. Ninety-four per cent of this balance sheet is other people’s money. And here real accounting begins, because the mere act of carrying customer funds on the operator’s own balance sheet is a constitutional declaration: a custodian who keeps client assets segregated reports them off balance sheet, or with a mirror-image liability and zero freedom of disposal; an entity that pulls them into its own totals and “invests them further” has stopped being a depositary and become a credit institution without the license, the buffers, or the supervision that licensed institutions are required to maintain for precisely this contingency. The European Union’s MiCA regulation makes segregation of client funds an explicit duty. The 2024 report, meanwhile, states in black and white, in Estonian: “Kliendi vahendid on edasi investeeritud nii lühi kui ka pikaajaliselt.” The clients’ funds have been invested onward, short and long term.
That sentence, the one our April analysis began with and the Polish press then quoted from Gazeta Wyborcza to Business Insider, stood in frontal contradiction to the exchange’s own terms of service, which assured users that the operator neither invests nor lends client funds; Poland’s consumer-protection authority, UOKiK, later confirmed that a clause permitting the investment of client funds sat in those terms until December 30th, 2024. The filings let us measure the practice to the euro: the line item “liabilities arising from the use of client funds” grew from €1.8 million at the end of 2022, through €19 million at the end of 2023, to €82.7 million at the end of 2024. A forty-five-fold increase in two years. That is not an incident. That is a business model, duly booked.
A model all the more legible because the legitimate commission business was withering in parallel, in plain sight: revenue of €23.8 million in 2021, €6.2 million in 2022, €4.7 million in 2023, €6.1 million in 2024, seventy-seven per cent of it from Poland. And net profit for 2024? €8.4 million, nearly a hundred and thirty-nine per cent of revenue. A company whose profit exceeds its entire sales is earning not on services but on bookkeeping. The note on other operating income shows on what: of €20.6 million in that line, roughly €19.5 million relates to the company’s own ZND token, issued in October, 2024, and carried at “fair value” in the company’s own wallets. In the fair-value hierarchy, such an instrument is textbook Level 3: a valuation from a model, and from a market in which the issuer itself is the market maker, with a supply of seven hundred million units and a treasury holding nearly a third of the issue. A balance sheet that writes its own price tag has a short and instructive history in finance: it is precisely the construction the world saw in Alameda Research’s balance sheet, stuffed with the FTT token, shortly before FTX filed for bankruptcy in November, 2022. Strip out the token and Zonda’s 2024 ends in a deep operating loss. Canned air, we wrote in April (in Polish), and the annual report merely quantifies the metaphor. Our July findings on how clients actually lost money added the demand side of that ledger: ZND bonuses as bait, and an internal price drifting away from the market’s.
The Map of the Outflow
If client funds were “invested,” let us ask the documents into what. The answer fits in a single note, and it is the most important passage in the case. The company’s loan receivables grew within one year from €12.3 million to €93.6 million; on a stand-alone basis, the parent extended €114 million in loans in 2024, of which, after consolidation, that is, after netting out intragroup lending, €89.5 million was pushed outside the group. The queen of the note is “Laen 7,” Estonian for Loan 7: a loan of €75,016,307, denominated in cryptocurrencies, at a floating rate, due in 2025. The report does not name the borrower. It discloses no collateral. For a sense of the diligence gradient: another loan in the same note, €2.9 million at two per cent until 2041, is secured by a €10 million mortgage; yet another, of €334,000, by a pledge of eighteen ether. Three million guarded like a crown jewel, seventy-five million in crypto sent out on a handshake. Accounting has a name for the note’s second dissonance, too: maturity transformation. This company’s liabilities were deposits payable on demand; its assets included a receivable running to 2041. Banks practice that mismatch under a license, with capital and liquidity supervision. The exchange practiced it with other people’s money and none of the three.
Around the queen circles a court. Advances to a related party: from €8.3 million to €30.5 million. A €6.3 million capital injection into the Polish company Orion Software, to a carrying value of €19.3 million. Services purchased from related parties: €5.8 million in a single year. Management compensation: from €169,000 to €815,000. Advertising: from €0.4 million to €5.7 million, against €9.7 million of cash in the till; that is what it looks like, in numbers, when fresh deposits are shoveled into a system that has stopped closing out withdrawals for the old ones. And finally the subsequent-events paragraph, the one a financial auditor reads twice: by July 28th, 2025, €58.3 million had been “repaid” on Loans 6 and 7. The audit opinion was signed on July 29th, 2025. One day later. In audit methodology, that conjunction of dates has a technical name, window dressing at the cutoff, and a procedure to match: the examination of subsequent events requires establishing where the money came from and where it went next. The report does not say, and today no one publicly knows; it is the first question both for the interim trustee in Tallinn (in Polish) and for the prosecutors.
As for the credibility of the numbers themselves, let the history of the audit opinions testify, told in the language of auditing standards. For 2021, the auditor issued a disclaimer of opinion; in the audit lexicon, a disclaimer is the extreme case, an inability to gather evidence on a position so pervasive that no opinion can be formed at all, here: bitcoin carried at €145.7 million. For 2022, a qualified opinion, a scope limitation concerning €155.2 million in crypto-assets. For 2023, qualified again, this time €172 million; management offered the auditor a notarized declaration in place of evidence that takes half a minute to produce, since a microtransaction signed with the known private key would have sufficed. The auditor declined to accept an act of faith in place of proof of control. For 2024, the opinion is suddenly clean, without a word about what evidence of the assets’ existence materialized after three years of its absence; we note the change in the company’s favor as honestly as we note everything else, and just as honestly we ask about its methodological source, because a clean opinion following two qualifications and a disclaimer is an event that must have an explanation in the audit file. For 2025 there is no opinion of any kind, because there is no report. And, for the record, a distinction that journalism tends to blur: an audit of financial statements is not a proof of reserves; the first examines books, the second cryptographically demonstrates command of keys, which is exactly why the microtransaction was such an elegant test. This company’s paper wealth is part of the problem, not its solution.
An Atlas: One Fortune, Many Jurisdictions
The group’s geography is itself an answer to the question of why a vast fortune is so difficult to lay on a table: it does not lie in any one place.
Switzerland. The owner of BB Trade Estonia OÜ is Divisio Holding AG, of the canton of Zug; the group also includes Zonda Token AG. The assets contain, in addition, a stake of about one per cent in a Swiss financial institution, carried at €3.8 million, which we described in April as Zonda’s Swiss investment (in Polish). A €10 million credit from SEBA Bank was repaid in 2024; the institutional creditor exited this story whole before the retail clients learned there was a story.
The Bahamas. From 2024, BB Trade Bahamas Ltd appears in the consolidation, and in parallel, as we established in the registries that spring, the C.E.O. registered new companies in the Bahamas, listing a Polish telephone number in the paperwork; Gazeta Wyborcza mapped the Bahamian trail at the time (in Polish). The calendar suggests a rational business motive: July 1st, 2026, was the MiCA deadline, after which European operations without a CASP license lost their reason for being. Our April assessment was that it looked like a contingency plan; no one has falsified that assessment since, and we log it as a working hypothesis, not a verdict.
The Czech Republic, Luxembourg, Britain. In the registry lattice around the exchange’s vanished founder (in Polish) sit the Ostrava company EXPOFÉR SERVIS HOUSE s.r.o., incorporated by notarial deed in January, 2024, the Luxembourg entities LUXBAY SA and S&B Investment SA, and the British BB Trade Pro Limited. The asset significance of these nodes remains to be examined; their existence is documented in the registries, and the experience of cross-border cases teaches that one draws the map before the questions, not after.
Malta and Poland. Malta supplies the prehistory (in Polish): Pinewood Holdings, the formal operator of BitBay, Zondacrypto’s predecessor brand, a company with €1,200 in assets, which never applied for a Maltese license, and whose director gave as his residential address “Villa No 21, Jumeirah, Dubai,” a district the size of a city. Poland supplies the epilogues: BitBay sp. z o.o., struck from the corporate register (in Polish) in February, 2026, without liquidation, with an official annotation of no assets; BB Trade Poland sp. z o.o., in liquidation; the payment intermediary Payment Technology, which at peak moved 275 million złoty a month, bankrupt and fined by the Polish financial regulator; Femion Technology, subject of a bankruptcy petition. The pattern is regular: where supervision ends, the company ends.
Monaco. The C.E.O. resides in Monaco; we described in May the mechanics by which sponsorship bought credibility (in Polish), and the principality’s prosecution service is one of three now examining the case (in Polish). Spring reports placed him in a succession of countries, and some of those reports could not be verified, which we said plainly at the time; for the purposes of this inventory only one sentence matters, neutral as a protocol: on the day of any asset freeze, the authorities will need one address for service and one signed schedule of assets, and the extradition procedure we analyzed in April (in Polish) remains, in this case, a real instrument rather than a rhetorical one.
Destination: Kraken. Finally, there is the stream we counted transfer by transfer: five hundred and eleven transfers to accounts of the Kraken/Payward group, roughly seventy-six million złoty in total, executed while customer withdrawals were already frozen; we published the flow map in April (in Polish). Payward is a constellation running from Payward Inc. in the United States, through Payward Ltd in London, to vehicles in Ireland, Cyprus, Bermuda, and the Cayman Islands; reaching those funds requires mutual legal assistance measured in quarters. The experience of the great collapses supplies, at the same time, a calibration of expectations we set out separately (in Polish): Madoff’s victims eventually recovered more than ninety per cent; FTX customers, in real terms, twenty-two to twenty-five per cent measured in bitcoin; Mt. Gox creditors, twenty-one to twenty-three per cent of their original coins; QuadrigaCX, thirteen per cent; Three Arrows Capital, just over one. The spread between those numbers was always made by the same variable: how much was secured before the assets scattered across the world.
The School of Great Chain Investigations: The Ledger Does Not Forget
Before we come to Zonda’s wallets, one object lesson, because in this case it calibrates both the victims’ expectations and the strategy of every other participant. Blockchain forensics already has its classics, and their common denominator is time, which works for the ledger.
August, 2016: 119,754 bitcoin vanish from the Bitfinex exchange. For five and a half years the case passes for hopeless, until, in February, 2022, the U.S. Justice Department seizes more than ninety-four thousand of those bitcoin and announces the largest financial seizure in its history, worth $3.6 billion at the time; the sentences come in 2024, eight years after the hack. September, 2012: more than fifty thousand bitcoin are siphoned from the Silk Road; for nine years they are a legend, until, in November, 2021, investigators find them in the Georgia home of James Zhong, partly on a single-board computer hidden in a popcorn tin, and confiscate $3.36 billion; the U.S. Attorney closes the file with a sentence that ought to hang over every desk in this industry: we will hold you accountable, no matter how long it takes. The year 2011: the Mt. Gox intrusion; volunteer analysts at WizSec spend years assembling the attribution from public transactions, in 2017 the operator of the BTC-e exchange, through which the loot was laundered, is arrested in Greece, and in 2023, twelve years after the theft, the Justice Department charges the men it says stole six hundred and forty-seven thousand bitcoin. From 2011 to 2021, Bitcoin Fog operates, the longest-running mixer on the darknet; in 2024 its operator receives twelve and a half years, thirteen years after launching a service whose only product was the erasure of trails. The year 2020: a Chinese court, in the PlusToken pyramid case, orders the forfeiture of 194,775 bitcoin and 833,000 ether, the largest single pool of crypto-assets in the history of confiscation. February, 2025: $1.5 billion vanishes from Bybit, the largest theft in the industry’s history; the perpetrators push the entire haul through cross-chain protocols in ten days, and even so the analytics firms label the addresses in real time, most of the stream remains traceable for weeks, and the first freezes land at the ramps back into ordinary money. For symmetry, a counterexample of tempo: the Colonial Pipeline ransom of May, 2021, the F.B.I. recovers within a month, because it comes into possession of the private key to the address holding 63.7 bitcoin. With a key, seizure takes hours. Without one, years.
The methodology behind these cases is public and has been described in the academic literature for a decade: the common-input heuristic clusters the addresses funding a single transaction as one owner; change-address analysis and peel chains reconstruct the route of split balances; and address labeling at licensed brokers turns every exit into fiat currency into a gate with an identity check. Mixers do not annul the methodology; they raise its price, as the Bitcoin Fog verdict shows, and as does the Greek freeze of Bybit funds executed many months after the laundering. And the XRP Ledger, on which we found the wallet described below, is an even more obliging environment for an investigator than Bitcoin: account-based rather than built on unspent outputs, with a complete history of every transaction since 2013, and with destination tags that function as exchanges’ internal reference numbers. The strategic conclusion of this whole school is single and directly applicable here: on a blockchain, information about flows is never lost; it only loses value as a bargaining chip, because with every passing quarter the authorities establish it themselves. Whoever holds knowledge of a fortune holds a depreciating asset. The rational player trades it early.
The Chain: Two Wallets, One Lesson
About two wallets in this case we know more than about all the rest of the fortune combined, because a blockchain does not accept notarized declarations.
The first is the famous forty-five hundred bitcoin. On April 16th, the C.E.O. publicly pointed to an address that was to prove the exchange’s reserves. We checked its history in the public explorers (in Polish): the address has been dormant since March, 2016, ranks thirty-ninth on the global list of wallets inactive for more than eight years, and nothing on the chain connects it to BitBay or to Poland. The alternative is merciless for the estate: either the wallet does not belong to the company, or it does and no one can open it; in both variants, those bitcoin are not on anyone’s table. We put forward a hypothesis about the address’s provenance publicly and labeled it, explicitly, a hypothesis, with an appeal to Chainalysis, Elliptic, and TRM Labs for verification; the school in the preceding section teaches patience, for the Mt. Gox attributions took six years to ripen.
The second wallet we found ourselves, on the XRP Ledger: an account holding 1,129,000 XRP, roughly 5.7 million złoty at May prices. It was activated directly from a Zonda account on November 27th, 2023; all significant inflows come from Zonda, and the outflows return to Zonda under a recurring internal tag. On the evening of April 7th, 2026, within sixteen minutes of a deposit from Kraken, 129,999.6 XRP were fired at this address in two steps. The next day, the exchange froze withdrawals. On April 11th, exactly one thousand XRP left the wallet for Binance, the classic pattern of a test transfer, and since then not a single outgoing transaction has occurred. We presented the attribution as deductive, resting on the chain of circumstantial evidence and the methodology above, not on any statement by the company; for the authorities we laid out four operational paths, from data requests to Kraken and Binance about the balance holders to real-time monitoring of the address. And that is the lesson of both wallets at once: the chain shows everything and surrenders nothing. To see a balance to the last drop and be unable to seize it without the private key: that is the entire difference between knowledge and security, between a name and a wallet.
The scale of what left through the chain is measured by the analyses of Recoveris, a crypto-recovery firm: the exchange’s operational reserves melted by more than ninety-nine per cent, and between December, 2025, and April, 2026, roughly twenty-one million dollars flowed out of company wallets in more than five hundred transactions. Spring press analyses, based on the company’s operational data, indicated that liabilities to customers fell from €722 million to about €343 million over 2025 alone; we called it a run (in Polish) and noted that satisfying some creditors selectively at the expense of others can be a crime, and can be reversed in bankruptcy.
What Is Actually on the Table
Let us set out the inventory. On the security side: €4 million frozen by prosecutors in a French bank account under the E.U.’s mutual-recognition regime; an Estonian court’s injunction of July 27th, 2026, barring the company from disposing of its assets, with an interim trustee still establishing whether anything exists in Estonia beyond the furniture; a license revoked on June 29th; a joint Polish-Estonian investigative team; and the National Prosecutor’s Office investigation in Katowice, merged in July with the file on the founder’s disappearance and extended to January 17th, 2027. On the knowledge side: an identified XRP wallet, a counted stream to Kraken, mapped receivables led by Loan 7 and the related-party advances, the Swiss stake, the Orion Software shares. On the claims side: at least 350 million złoty in damage according to the prosecution, more than €80 million according to the Estonian press, between thirty and fifty-seven thousand victims according to divergent estimates, and, at the end of 2024, €722 million in liabilities to customers over the C.E.O.’s own signature.
The distance between the first and the third columns of that inventory is measured today not in euros but in private keys. And it is precisely at that distance that the defense’s declaration is aimed.
Article 60: The Price, the Audiences, and the Test of Performance
Now the strategic layer, because the declaration of a vast fortune is not a rhetorical gesture but an opening move in a game with written rules, in which every participant has a legible objective function. Let us lay out the board honestly, in order, attributing bad intentions to no one; good ones will do.
The first addressee is the prosecutor, because since October 1st, 2023, Article 60, Section 3, is triggered exclusively on the prosecutor’s motion. And a prosecutor optimizes for the defensibility of decisions: a motion for extraordinary leniency toward the C.E.O. of a collapsed exchange can be defended before the public and before superiors only if, next to the explanations, the file contains an asset freeze under Article 291 of the procedure code, on itemized, counted components. The second addressee is the future court, which optimizes for a judgment that will not be disturbed; the loyalty regimes of Articles 434, Section 4, and 540a are, from this vantage, not a trap but a credibility mechanism, the device that makes a promise of cooperation worth anything at all, because breaking it carries a price. The third addressees are the other potential co-perpetrators, for whom every such declaration reprices the race: information is worth most to the one who speaks first, and melts with each one who speaks later. And over all of them ticks the clock from Section VI: since July’s consolidation of the investigation, the authorities establish on their own, with every quarter, what still carries bargaining value today. Within that structure, an early, complete, and performed asset declaration is simply the rational move; and if the defense’s announcement is the announcement of such a move, then we, as counsel for the victims, have an interest in making its performance simple, fast, and safe for every participant. The golden bridge in this case has, in any event, an unornamented form: a seizure protocol, a signed inventory, addresses designated by the prosecution. We are not closing that road. We are paving it.
The declaration itself, meanwhile, will pass or fail three tests, and we speak of them just as openly. The test of composition: does the fortune contain clients’ crypto-assets and the private keys to them, or rather paper, meaning shares, intragroup receivables, self-issued tokens, and intangibles; the balance sheet dissected above suggests the group’s wealth was overwhelmingly paper, €93.6 million in loans, €30.5 million in advances to related parties, a token carried at Level 3 fair value. The test of title: whose fortune is it, given that the operator’s formal owner is a Swiss holding company and the declarant is a board member; someone else’s assets can be pointed to, not delivered, and one’s own assets of unestablished origin will meet Article 45, Section 3, of the Penal Code and the reversed burden of proof of extended confiscation. The test of performance: private keys, or transfers to addresses designated by the prosecution, verify within hours, because balances on the chain are public; paper takes years to value and sells at a discount. If the declared fortune contains crypto-assets and keys, we will count them within hours and say so publicly, with the same care with which we noted the clean 2024 opinion. If it does not, the victims should hear that in plain words.
There remains, finally, the coordination of parallel proceedings, because strategy without logistics is poetry. The loans due in 2025 have already been “repaid” in directions publicly unknown; the run drained hundreds of millions from the platform; every week of delay is a risk of transfers beyond the reach of execution. In parallel, bankruptcy proceedings are under way in Estonia, and the anti-cumulation clause of Article 415, Section 1, of the procedure code requires vigilance that no claim be consumed twice. The priority remains security and compensation within the criminal case, because only there do evidentiary compulsion, asset freezing, and reparation converge, with the damages reaching the victim without a queue and without deductions for a trustee’s fees. From this follows the catalogue we will raise at every conversation about any leniency whatsoever: a full, signed inventory of the declarant’s own assets and of the known assets of others; disclosure of private keys, or transfers to addresses secured by the prosecution; a map of the group’s receivables, Loan 7 and the advances first; consent to security over the Orion Software shares, over the Swiss stake, and over the claims against the Payward group. The “sixty” is not a status; it is a promissory note. It is redeemed in the judgment, and its cover is checked before acceptance, not after.
Conclusions
The inventory yields a result that fits in four sentences. Verifiably on the table today: €4 million in a French bank, an Estonian company under a court injunction, an XRP wallet visible to the last drop and inaccessible without a key, and a sheaf of receivables to be litigated across several jurisdictions. Facing them: liabilities signed at €722 million. Stretched between the one and the other is a two-word declaration that can be performed within hours, keys suffice, and that until the day of performance must be booked the way an accountant books an announcement: off balance sheet. The school of the great chain investigations, where this case began for us in April and which carried it onto the pages of The New York Times and into feeds from China to the KuCoin app, teaches two things at once: that the ledger never forgets, and that the value of knowing what it holds melts with every quarter. Both lessons now work in the victims’ favor and, we note without irony, in favor of anyone who decides to lay the fortune out early. Our side of the table is ready.
Politics does not interest us. Wallets do.
A Note on Method
We mark levels of certainty throughout: data from financial statements and public registries we treat as certain as to the document’s content; on-chain attributions as probable inferences from circumstantial evidence; media reports on whereabouts and procedural status as accounts requiring confirmation. The criminal proceedings and the Estonian bankruptcy proceedings are pending; every person named in this text, the company’s C.E.O. included, enjoys the presumption of innocence, and the legal qualification of any acts belongs exclusively to the authorities. The quotation rendered here as “a vast fortune” translates the two Polish words of the defense’s public statement, “ogromny majątek”; the language of wallets, the tests of the declaration, and the entire strategic layer are ours. The comparative cases rest on U.S. Justice Department releases and press reports linked in the text. Legal and factual status: August 26th, 2026. Sources: the consolidated annual reports of BB Trade Estonia OÜ for 2023 and 2024 (ariregister.rik.ee); the commercial registries of Estonia, Switzerland, the Czech Republic, Luxembourg, Malta, Britain, and Poland; the XRP Ledger (XRPScan); the Recoveris report; and the firm’s own publications and press coverage listed in the appendices.
Robert Nogacki – licensed legal counsel (radca prawny, WA-9026), Founder of Kancelaria Prawna Skarbiec.
There are lawyers who practice law. And there are those who deal with problems for which the law has no ready answer. For over twenty years, Kancelaria Skarbiec has worked at the intersection of tax law, corporate structures, and the deeply human reluctance to give the state more than the state is owed. We advise entrepreneurs from over a dozen countries – from those on the Forbes list to those whose bank account was just seized by the tax authority and who do not know what to do tomorrow morning.
One of the most frequently cited experts on tax law in Polish media – he writes for Rzeczpospolita, Dziennik Gazeta Prawna, and Parkiet not because it looks good on a résumé, but because certain things cannot be explained in a court filing and someone needs to say them out loud. Author of AI Decoding Satoshi Nakamoto: Artificial Intelligence on the Trail of Bitcoin’s Creator. Co-author of the award-winning book Bezpieczeństwo współczesnej firmy (Security of a Modern Company).
Kancelaria Skarbiec holds top positions in the tax law firm rankings of Dziennik Gazeta Prawna. Four-time winner of the European Medal, recipient of the title International Tax Planning Law Firm of the Year in Poland.
He specializes in tax disputes with fiscal authorities, international tax planning, crypto-asset regulation, and asset protection. Since 2006, he has led the WGI case – one of the longest-running criminal proceedings in the history of the Polish financial market – because there are things you do not leave half-done, even if they take two decades. He believes the law is too serious to be treated only seriously – and that the best legal advice is the kind that ensures the client never has to stand before a court.
