Zondacrypto: The Trustee Reached Kral. The CEO Replied in Twenty-eight Pages That Look Written by A.I.

The interim trustee of the bankrupt zondacrypto exchange has made contact with its chief executive. Przemysław Kral, whom journalists, clients, and, according to what a client from Vienna told the Estonian court, the justice system have been looking for since April, wrote back within a week, at twenty-eight pages. The trouble is that the reply looks like the work of a large language model: twenty-five points on a single skeleton, the phrase “not in a position” twenty-two times, the prosecutors’ address twenty-five times, not one provision of law, and not one name of an actual contract. Artificial intelligence is not, in itself, a reproach; the reproach is the direction in which it was pointed. A model answers questions if it has the data and is allowed to answer; this one was told not to answer, and it carried out the instruction in twenty-five variations, each time with a new list of documents that do not exist and the same address to which one should apply.

The consolation is that Przemysław Kral at least picks up his mail. Since April, the exchange’s chief executive, a possible crown witness in the Zondacrypto case, “has been” in Monaco, Israel, South Africa, Botswana, and on the Persian Gulf, in that order; the client from Vienna who filed the bankruptcy petition told the Estonian court, citing press reports, that Przemysław Kral had fled to Israel.

Between these presumed journeys, the CEO explained to the interim trustee that he has no access to the servers, the cloud, the data repositories, or the backups, because Polish authorities control them as part of a criminal investigation; that some of the information he cannot pass on, because it is covered by the secrecy of that investigation; that the accounting records he does not have, because the accountant has not returned them; and that for data one should apply to the accountant and to the Polish prosecutors. The trustee took note of this and, in the final point of his report of August 21, 2026, announced that in the proceedings ahead he would first attempt “rational cooperation” with the board, above all with Kral, as board member and beneficial owner of the company. The trustee wants to cooperate with the CEO, the CEO cooperates with the prosecutors, the prosecutors have the servers. The circle is closed, and the clients stand in the middle of it.

That is the starting position of the largest bankruptcy, by liabilities, that the Estonian courts have seen in years: a trustee without documents, a CEO with time to write, 432 million euros of debt, and 167,000 euros of assets. The CEO cannot be found, but he can be written to. He wrote back that everything he knows is secret, and that everything public is something he does not know.

Twenty-eight Pages and One Sentence

The CEO’s reply of August 12 runs to twenty-eight pages and twenty-five points, and it has one construction, repeated with the regularity of a form: I am not in a position to provide, because the servers and the cloud are secured by the Polish authorities, the accounting documents are with the accountant, part of the information is covered by the secrecy of the investigation, please address the National Prosecutor’s Office in Katowice, case reference 1001-109.Ds.77.2022, address enclosed (quotations are from the original English). The phrase “not in a position” occurs twenty-two times, the prosecutors’ address twenty-five times, the accountant’s name fifty-one times, the readiness to supplement the reply twenty-five times. The only enclosure is an unaudited management balance sheet as of December 31, 2025; its source file was created on March 5, 2026, six weeks before the CEO publicly displayed the address with 4,503 bitcoins as the exchange’s reserve; according to the file’s metadata, it was printed by the same accountant who, the letter says, has returned nothing to the CEO. The letter’s file was generated on an iOS device at 4:14 a.m., Universal Time. The trustee’s request was dated August 5, so the reply arrived a week after the day on which the court had ordered the statement of assets to be filed. The accountant answered the trustee faster than the CEO did: the printouts of the monthly turnovers of every account, of the balance sheet, and of the income statement for the period from January 1, 2025, to April 22, 2026, on which we draw below, are dated August 6, the day after the request. The CEO needed a week to write that there were no books.

Where the regularity comes from can be seen in the syntax. Twenty-five answers stand on a single skeleton of five members, and the closing formula drifts across the document: “if and when” in the first points, a bare “if” from point 2.2 through 2.9, “if and when” again once a new chapter begins. The lists of documents the CEO cannot produce are tailored to each topic and always generic: for pledges, “pledge instruments, asset schedules, registry filings, release documents, enforcement notices”; for works contracts, “contractor agreements, work orders, acceptance certificates”; five to eight kinds per point, and not one name of an actual contract, counterparty, premises, or lender. A CEO would remember a particular lender and a particular address and forget the typology; a model does the reverse, having read thousands of such contracts and none of these.

The hedges are symmetrical (“has, or does not have”; “exist or do not exist”), and the debtor instructs the trustee how to review documents for completeness, authenticity, and data protection, and explains to him that zondacrypto is a brand, not a legal entity. A debtor does not teach a trustee his trade; a model, trained to be helpful, teaches everyone, even when told to say nothing. In twenty-eight pages there is not a single provision of law: the refusal rests on the “confidentiality of those proceedings,” with no article of Polish criminal procedure and no section of the Estonian Bankruptcy Act on a debtor’s duties. The legal English is flawless; the tone is uniform from the first page to the last.

In our judgment the letter looks like the work of a language model that was handed the trustee’s request, the balance sheet, and a handful of facts, and then expanded them point by point. Stylometry is not proof; we offer this as an assessment, not a finding. A human added what the model could not have known: the four names of payment operators, the accountant’s name (spelled, in all fifty-one places, differently from the way she spells it on her own printouts), the figures from the balance sheet, the remark about BURFA MEDIA OÜ, and the thesis about a media campaign. The model added to that thesis the sentences describing it as “the position of the Company’s management,” requiring “independent legal and evidential assessment”; the one place in the letter where anyone distances himself from the CEO is his own letter.

The weak point of the construction is substantive, not stylistic: the secrecy of pre-trial proceedings protects what is in the prosecutor’s file, not what a board member knows about his own company by virtue of running it. Whoever lent seventy-five million euros to a company of which he is the CEO knows it without looking into the investigation file. The letter does not claim that the CEO does not know; it claims that he is not in a position. The difference between those two sentences is the entire content of twenty-eight pages.

On one point the CEO’s memory works. Asked about accounts, he lists, “to the best of my recollection,” ZEN.COM, Sygnum, AMINA, and TryPay. He does not remember Tpay, Fenige, or Clear Junction, the three accounts holding 105,000 euros, 63 per cent of everything the trustee found (table below); through Clear Junction alone, forty-three million euros passed in 2025. He adds that most relationships with operators have been terminated or notices of termination sent; the question of whether the 167,000 is still there thus has a false bottom. The CEO’s memory records what is not there and omits what is; it is like his company’s balance sheet.

The CEO’s numbers. The injured parties, by his count, are “approximately 3,000,” and the total of reported claims “approximately PLN 100,000,000”; the sum he gives “based solely on media reports,” the number “to the best of the information presently available” to him. His own enclosure, in the same correspondence, shows 343 million euros of liabilities to clients and eighty-eight million of others, some 1.9 billion złoty in all. A hundred million is about five per cent of that, and, incidentally, exactly the figure the Minister of Justice gave for the value of the suspects’ seized assets. The exchange advertised itself as a platform with more than a million users; the trustee’s report speaks of as many as thirty thousand injured parties. Between a million and three thousand lies the whole difference between marketing and liability.

Causes. The collapse, the CEO writes, “did not result from ordinary commercial underperformance alone”; it was “materially influenced by an intense political and public campaign” and by “adverse media publications” that, “in my view, contained inaccurate, misleading or unverified allegations,” and the resulting reputational pressure and loss of confidence, he writes, undermined the company’s relationships with financial and payment institutions. The other causes are secret, being covered by the investigation, and the date on which the business ceased the CEO cannot give, because the cessation “was a developing process.”

The company “has or may have claims against persons whose actions caused damage to the Company,” but against whom, the CEO is “not authorised to disclose.” Nor does he admit insolvency: “I do not accept that the existence, date or cause of the Company’s alleged insolvency can be determined solely from the present absence of operations or from public reporting.”

A company with 432 million euros of debts and 167,000 euros of assets is thus, on his account, not insolvent; it merely does not operate, and it does not operate because of a political and public campaign.

The books, to which we return below, date that process to the month and put figures on it; the campaign does not appear in them.

Two details in closing. In his preliminary reservations the CEO asks that “no private keys, seed phrases, passwords or access credentials should be transmitted by ordinary email,” and then explains in twenty-two points that he has access to nothing; ten days after this letter, someone used the key to Zonda’s XRP wallet. And he refers the trustee for documents to the accountant, who, as the report shows, has already handed the trustee everything on hand, and everything on hand was made from aggregate totals supplied by management. The circle has a third segment: the trustee asks the CEO, the CEO refers him to the accountant, the accountant hands back what came from the CEO.

And there is one point on which the CEO is right. He notes that in the factual part of the court’s order the bankruptcy petition concerns a company called “BURFA MEDIA OÜ,” asks whether this is a translation error, and reserves “all rights” on that account. It is not a translation error. The sentence about a petition against the debtor BURFA MEDIA OÜ stands in the Estonian original of the July 27 order and was copied into the order of August 27; the court corrected it on September 2, in the same ruling in which it inserted the missing clause on main proceedings within the meaning of Regulation 2015/848. The operative part names the debtor correctly, and none of this decides the order’s validity, but an adversary in litigation looking for a handhold received one from the court as a gift.

A Notary on the Riviera: Full Access to 4,503 Bitcoins

One page, in English, headed “Statement”; the signature of Przemysław Kral as a person authorized to represent BB Trade Estonia OÜ alone; beneath it, a certification of the signature by a notary in Villefranche-sur-Mer, dated June 26, 2025. The CEO declares that the wallet at the address 16aEn4p6hK4FMpLtJGpoQZMZ946sDg1Z6n, on which, according to the public data on mempool.space, 4,503 bitcoins (stated to the satoshi) had accumulated as of December 31, 2024, belongs to the company, and that the company has “unlimited, full and exclusive access” to it. He makes the declaration “under the protection of all legal consequences, including criminal liability.” An integral part of the statement is a screenshot: the balance, twenty-eight unspent outputs, and a total received equal to the balance, which is to say not one outflow in the address’s history.

This is the same address the CEO displayed in mid-April of 2026 as the exchange’s reserve, adding that the company did not hold the keys to it, because the missing founder did; we traced the history of the address in our piece on Zonda’s cold wallet. The same address of which the trustee’s report says that access was lost, and from whose loss, dated to the end of 2022, the trustee counts the onset of possible permanent insolvency. According to the June, 2025, statement, the key existed; according to the April, 2026, statement, it had been gone for three years. Between those dates nothing happened to the key; what changed was the addressee of the statement. One of the two claims is false. If the June one is true, the company has access to assets that its own books valued, at the end of 2025, at more than 330 million euros; it is not insolvent, and for five months it has been declining to pay its clients by choice. If the April one is true, the CEO certified a falsehood before a notary, under criminal liability, and every balance sheet that rested on that wallet certified it along with him; as we will show below, all of them did.

Three notes on the document. The notary certified the signature, not the contents: the formula “certifie la signature” says only that the person who was supposed to sign did sign. Proof of control over a Bitcoin address consists in signing any message with the private key; it takes three minutes, costs nothing, and anyone can check it, as we showed when writing about Zonda’s cold wallet. The CEO chose the slower, costlier proof, because the cheap one required a key. And the last operation on the address before the date to which the statement attests: a deposit of 647 satoshis on December 29, 2024. To receive a deposit, no key is needed.

Why the company needed, in June of 2025, a notarized statement about the state of a wallet at the end of 2024, the document does not say. The date suggests a hypothesis: four days later, the Estonian deadline for filing the 2024 annual report ran out, and the auditors examining the exchange’s accounts had been unable, for three years running, to confirm that the company controlled the assets it reported, as we described in our piece on Zondacrypto’s loans. A management declaration stood in for the proof that management could not produce; in June of 2021, Suszek had performed the same maneuver, certifying with his own signature eighty pages of charts from the exchange’s internal system, as we described in our piece on Zonda’s exchange contracts. That certificate gave no address; this one does, and it is the first document in which the company itself lays claim to 16aEn4p6. For the trustee, this is more than a curiosity: if the statement is true, 4,503 bitcoins belong to the estate, and the key to them is held by a board member with whom the trustee proposes to cooperate rationally. The place of signature we record without comment: Villefranche-sur-Mer is the town where, not quite four months later, a house was bought for eight million euros with the proceeds of a ZND conversion, as we showed in our piece on the money “from Suszek” and Zonda’s contracts.

A Balance Sheet Standing on One Address

The wallet in the statement also answers the question of what sits in the “cryptocurrencies” line of the exchange’s balance sheet. The quarterly statements of wallets and client balances that the exchange handed to its accountant as the sole source for entries on crypto assets and client balances, for the third and fourth quarters of 2025, show 4,517 bitcoins in the exchange’s wallets as of December 31, 2025, valued at roughly 74,600 euros apiece, or 337 million euros. That is 98 per cent of the main cryptocurrency account (343 million euros; with the exchange’s own ZND and TMPL tokens the whole line comes to 346.5 million), which the balance sheet as of April 22, 2026, copied to the cent. The remaining hundred-odd currencies, all together: six million euros. The statements give no addresses, but 4,517 bitcoins cannot be assembled from anything other than the 4,503 in the wallet from the statement plus a dozen or so in operating wallets; a quarter earlier the figure was 4,509, the same wallet and six bitcoins of change. This is a conclusion from arithmetic, not an entry in a document; but the equation has no other solution.

As of December 31, 2025; figures rounded. The statements are the company’s own documents, verified by no one; client balances include accounts on the exchange and on the ZND platform.

In cryptocurrencies other than bitcoin, the exchange owed its clients the equivalent of 185 million euros; in its wallets it held six million euros’ worth. Of bitcoin, clients held 2,072, and the exchange reported 4,517: a surplus of nearly 2,450 bitcoins, which on paper covered every shortfall in every other currency, with room to spare. The whole of that surplus is the wallet from the statement. Without it, coverage of clients’ crypto assets on December 31, 2025, stood at two per cent. The exchange was solvent in one currency, the one to which, according to its CEO, it had no key, and insolvent in every currency to which it did.

A quarter earlier, the wallets were not yet empty. On September 30, 2025, the exchange reported more than 1,300 ether, 3.6 million XRP, two million DOGE, and 9,500 SOL; by December 31, there remained 179 ether, 83,000 XRP, half a million DOGE, and 5,750 SOL, while client balances in those currencies barely moved. This answers a question we posed in our piece on Zonda’s exchange contracts: what became of the fifty-eight million euros’ worth of cryptocurrency that Admitrade returned between July 23 and 26, 2025. Two months after the return of 6,400 ether, the exchange had 1,300 in its wallets; after the return of 6.3 million XRP, 3.6 million; after the return of sixteen thousand SOL, 9,500. By year’s end a few per cent remained. It came back in July and was gone by New Year’s Eve. The trustee’s report dates the outflow of twenty-one million dollars to Kraken from mid-December; the exchange’s own statements show the wallets draining throughout the fourth quarter. The direction of the second movement remains unknown; its calendar no longer is.

The monthly turnovers that the accountant handed the trustee together with the balance sheet add two things to that calendar. The first is rhythm. The crypto-asset and client-balance accounts move in the books only in the months that close a quarter, in a single entry that cancels the old balance and writes in the new one from the exchange’s report; the last such entry is dated December 31, 2025, and for January, February, March, and April of 2026 there is not one posting on those accounts. Of the cryptocurrencies of the run period the ledger therefore knows nothing; it knows only that on New Year’s Eve there were 4,517 bitcoins, 4,503 of them sitting at the address in the statement. The second is the name of a product. The receivable from Admitrade was booked on accounts called “Admitrade EARN fiat,” 14.4 million euros on January 1, 2025, and “Admitrade EARN crypto,” 75.0 million. The money clients placed in the Earn program was, in other words, a loan to Sroka’s company; a client who clicked “Earn” was financing the strategic liquidity provider without knowing that he was one. In July both accounts fell to zero and the Earn liabilities to clients returned to their ordinary balances: what Admitrade gave back was credited to clients on paper and dropped into a pool that was empty by New Year’s Eve. The ledger knows of no loss on this loan, because in June it raised the receivable to exactly the sum Admitrade later returned; the valuation followed the repayment, not the other way round. Two directions of outflow from the pool are visible already: between June and September of 2025 the Bahamian company drew from it stablecoins worth 5.3 million dollars to buy ZND tokens, as we described in our piece on Zonda’s exchange contracts, and in the autumn cryptocurrency was converted into euros at Sygnum, where the turnover of the account “Sygnum crypto transactions” reached nine million euros in October and twelve million in December. Where the rest went, the blockchain will say, not the ledger: the two hundred and forty-five transfers from Admitrade in July of 2025 are the one moment in this case at which the date, the amount, and the entry address of coins into the exchange’s wallets are all known.

A Crypto Exchange… Without Crypto

BB Trade Estonia OÜ has no account at any bank operating in Estonia and no agreement with any Estonian lender. A company licensed in Tallinn since 2020 kept no money in the country of its license. It kept it in Poland, where since April we have been asking where Zonda’s client money is: with the payment processors handling Polish clients’ złoty deposits. Account balances, mostly as of March 31, 2026:

For AMINA and Sygnum, the country follows the Swiss account numbers; the report describes the former as AMINA (Austria) AG. Amounts rounded.

In all, 167,000 euros. The report describes the assets identified as the sum of account balances and “identifiable crypto-asset balances,” but the arithmetic leaves no room for crypto assets: the accounts alone make up the whole 167,000. That is a conclusion from addition, not a sentence from the report, but it is a hard one to dispute. Poland’s largest crypto exchange left within the trustee’s reach not one cryptocurrency that could be touched. It left cash in Poland: 131,000 euros, or 78 per cent of the assets identified, sits with three Polish payment processors, according to balances from March; whether it is still there, nobody has confirmed.

The rest of the inventory does not exist. Real estate: none, confirmed in the land register. Vehicles and boats: none, confirmed in the transport register. Tangible fixed assets: none. The Zondacrypto trademark, carried in the books at 272,000 euros, the trustee values at zero, on account of the brand’s reputation. The Zondacrypto mark has achieved a recognition every marketing department dreams of and a valuation no accountant would dream of. The books also contain an A.T.M., an entry called “Payment technology ATM” at just under 2,350 euros. Nobody knows where it stands, whether it stands, or whether it is an A.T.M.; the trustee valued it at zero, the only withdrawal this machine has ever processed.

In July, when the court was only just freezing the assets, we wrote about Zondacrypto’s bankruptcy that the Estonian proceedings might physically capture little more than the furniture. There is no furniture. The one thing nobody moved out of Estonia was the company’s registration number; there was no way to wire it.

What did reach the file were findings previously known only from private analyses. The average balance of the main hot Bitcoin wallet fell, between August of 2024 and March of 2026, from 55.7 bitcoins to 0.18, a decline of 99.7 per cent; between mid-December of 2025 and April 2, 2026, some twenty-one million dollars left the exchange’s wallets for a single address at the Kraken exchange. The firm Recoveris described this in April, and in the same month we showed, in our piece on withdrawals from Zonda, that the hot wallet was topped up by hand before every withdrawal; today it is the content of a court document. Of the wallet holding 4,503 bitcoins, dormant for a decade and linked to the company by no evidence whatsoever, as we showed in our piece on Zonda’s cold wallet, the report says only that access to it was, according to the CEO, lost, and that from that moment the trustee dates possible permanent insolvency: the end of 2022. The last document in which the company itself attested to the state of that wallet is dated June 26, 2025; we described it above.

The wallet served this exchange the way the elephant serves the zoo in Sławomir Mrożek’s story: shown off to the visitors, it turned out to have been inflated with gas only when it floated away. More than three years of accepting deposits after the date that the exchange’s own trustee identifies as the possible onset of its insolvency: that is the shortest summary of this case.

The Trustee Has No Clients

That same company had, as of April 22, 2026, a week after its CEO announced the loss of access to the cold wallet, a balance sheet showing assets of nearly 477 million euros. Cryptocurrencies: 346.5 million. Long-term financial investments: 128.6 million. Equity: plus 44.7 million. The result for the period from January 1, 2025, to April 22, 2026 (the year 2025 was never closed in the books): 5.13 million euros. Of that, according to the accountant’s income statement, 1.81 million falls on 2025 (the management balance sheet the CEO attached to his reply says 1.35 million; it is the same ledger in its March version, before later corrections), which leaves 3.31 million euros for the hundred and twelve days of 2026, that is, for the run on withdrawals.

An exchange that was not paying out its clients’ money was earning, on paper, about a million euros a month. Insolvency was no obstacle to profitability; it interfered only with payments. Were this balance sheet true, it would be the first bankruptcy in history of a company whose only problem was profit. What remains is to establish what that profit was made of.

The income statement answers that question. Revenue for the sixteen months came to 42.5 million euros, of which sales of services, meaning commissions on trading, deposits, and withdrawals, made up 6.6 million; trading commissions fell month after month, from 495,000 euros in January of 2025 to 104,000 in March of 2026. The remaining 35.7 million is the company’s own token. “ZND Token Claim,” 20.5 million: tokens the company awarded to itself and booked as revenue at the market price. A released liability from the ZND public sale, 7.7 million. An off-market sale of tokens in February of 2025, 4.7 million. “TMPL Token Claim,” 2.8 million, booked in February and March of 2026, when clients could no longer withdraw. On the other side, 24.7 million of write-downs on its own ZND, among them three identical amounts of 3,257,762.13 euros at the end of March, June, and September, and 9.8 million in December, when the company’s stock of tokens fell in the books from 10.9 million to 880,000; two months earlier the company had paid a person from the founder’s circle eight million euros for ZND tokens at the December, 2024, price. The year 2025 closed with a profit only because of the tokens: without them it would have been a loss of some six million euros, and without the accrued and never-paid interest on the Orion loan, 2.6 million in 2025, payable after the repayment of the last tranche, that is, in the twenty-thirties, a loss of some nine million. The 2026 profit for the hundred and twelve days of the run, 3.3 million, consists of 2.8 million of TMPL tokens awarded to itself and 0.85 million of interest from Orion.

The exchange’s profit came from tokens it awarded to itself and from interest it charged itself on a company it financed itself. It was a closed circuit in which the only foreign body was the clients. It broke down when they wanted to take something out of it.

In the “cryptocurrencies” line sits the phantom of 4,503 bitcoins; we showed this above, on the very statement from which the accountant copied the line. It is the same mechanism we described in April, in our piece on Zondacrypto’s loans, in the financial statements for 2021 through 2024: for three years the auditors could not confirm that the company controlled client assets, and for three years the company carried them on its balance sheet.

The report explains where the picture comes from. Until April 22 the books were kept by an outside accountant, Accounting Advisory OÜ. Entries were made on the basis of data and documents supplied by management; the accountant had no access to accounts, wallets, or providers’ systems, and could verify nothing. Some data, including liabilities to clients, arrived only as periodic aggregate totals; the quarterly statements we described above are precisely those. The accountant, the trustee notes, admitted that the books do not reflect the company’s actual situation. The accountant is also a creditor: in order-for-payment proceedings concluded on June 7, 2026, it claimed 7,638 euros from the company for its services. This is at once the best-documented claim in the case, being the only one with a source document: the accountant’s invoice for keeping books without source documents.

On the liabilities side, obligations to clients stand at 429 million euros: 321 million in crypto assets and 86.7 million in other items. These are aggregate balances. The trustee states that, on the materials available, they cannot be attributed to particular clients, periods, or transactions. This is not his discovery. The auditor of the 2021 financial statements, which we described in our piece on ZEN and Zonda, wrote the same thing about thirty-four million euros of client liabilities: the company’s accounting system did not allow anyone to establish to whom, and in what amounts, they were owed. In 2026 the trustee found the same hole the auditor described in 2022. The trustee has liabilities but no creditors: he does not know to whom, how much, or for what. An ordinary bankrupt knows whom he owes and has nothing to pay with. This one has nothing to pay with and does not know whom; the bankruptcy has been simplified by one variable.

The 86.7 million euros of “other obligations to clients” continues the 82.7 million euros of “liabilities from the use of client funds” in the 2024 statements, a debt the company booked against itself for reaching into client money in breach of its own terms of service. In the accountant’s balance sheet, discussed below, this is a single account, “Other obligations clients”: 82.7 million euros on January 1, 2025, and 86.7 million on April 22, 2026. The debt to clients for the use of their money kept growing for another sixteen months, by four million. The total of all known liabilities as of April 22, 432 million euros, with the caveat that the true figure may be higher, was adopted by the court in its bankruptcy order as established.

The absence of a client ledger has a practical consequence for every creditor that few say out loud. The trustee will not verify a filed claim against the exchange’s records, because he does not have them; he will verify it against what the creditor submits. Account history, deposit confirmations, withdrawal orders, correspondence with the exchange: that is today the only ledger in existence, and it exists on the client’s side. Whoever files a balance from memory files an assertion; whoever files a balance from documents files a claim. The complete transaction data, more than 250 terabytes, were seized by the Katowice prosecutors, who are using the same data today to ask the victims where their deposits came from, as we describe in our piece on Zonda victims’ questioning and tax. How to calculate one’s own loss as of the day of the freeze and the day of the bankruptcy, we have described in our piece on the amount of loss in the Zonda case.

Opening Balance: Seventy-four Million Euros of Clients’ Money, Nine Million in the Till

The balance sheet from which the trustee copied the April 22, 2026, figures runs to four pages, with analytical accounts and three columns: the position on January 1, 2025, the change, and the position on April 22, 2026. The report uses the third column. The first two describe the sixteen months in which the exchange ceased to exist, and nobody comments on them. Together with the balance sheet the accountant handed the trustee the monthly turnovers of every account, so the differences in balances can be spread across months; that is where the dates below come from. One caveat remains: these are books of which the accountant told the trustee that they do not reflect reality, and an account’s turnover shows amounts and months, not the recipients of transfers.

On January 1, 2025, clients held 74.2 million euros in traditional currencies on the exchange (the account “FIAT obligations clients”). Across all its bank and payment accounts the exchange held 9.3 million euros. Coverage: 12.5 per cent. Adding the 14.4 million euros from the Earn program lent to Admitrade, about which we write separately in our piece on Zonda’s exchange contracts, the shortfall was fifty million. Clients kept seventy-four million on the exchange, and the exchange kept nine; the rest was trust, and trust has no IBAN.

By April 22, 2026, fiat liabilities had fallen to 2.9 million and cash to 415,000 euros, a drop of 95 per cent. The turnovers correct the first impression. The sixty-eight-million fall in liabilities is a single entry dated March 31, 2025, the quarterly rewriting of balances from the exchange’s report, not a stream of withdrawals: cash fell in that quarter by five million, not by sixty-eight. Clients did not withdraw that money; their balances in traditional currencies were reclassified, and the ledger does not say into what. Thereafter fiat liabilities rose and fell for reasons that can be seen: in June and July they rose by 11.2 million, as Earn funds returned to clients’ accounts, and in the fourth quarter they fell by 12.9 million, as clients withdrew them. The line “AA adjustments,” at 18.9 million euros, arose in a single entry on December 31; “AA” most likely stands for Accounting Advisory, so the label tells us who adjusted, but not what.

Cash has a calendar of its own. From March to August of 2025 it rose, from 4.2 to 21.3 million euros, as Admitrade repaid its loan. Then it fell: 15.7 million at the end of September, 7.3 in October, 2.9 in November, 3.0 in December, 0.94 million at the end of January of 2026, 0.67 in February, 0.42 in March. From September to December clients withdrew 12.9 million euros in traditional currencies, and in the same four months the company wired 13.3 million to Orion, 1.6 million to ZND Ventures, and paid out eight million from a ZND conversion to a person from the founder’s circle, whose purchase of a house in Villefranche we described in our piece on the money “from Suszek” and Zonda’s contracts. The account “ZEN Token EUR,” which received 2.19 million from Admitrade in May and 2.31 million from the sale of ether on Kraken in September, held 8.7 million euros on September 30 and was emptied to zero in October; whether it paid for the house, the turnovers do not say, because they do not show recipients; they say only that in the month of that payout an account of that size was emptied. The balance sheet as of December 31, the one the accountant printed on March 5 and the CEO enclosed with his reply, thus showed management, a month before the freeze, three million euros in cash and 343 million in cryptocurrency, 337 million of it at an address to which, as he announced in April, there is no key. In January of 2026 another two million went out. In March some twelve million euros still flowed through the accounts in each direction at balances close to zero: some clients’ deposits went out as other clients’ withdrawals. For April, when clients were being told about technical problems, the books record not a single transfer, and on the transit accounts for 2026 deposits and withdrawals there lay, on April 22, 6.2 million euros never reconciled with client balances, because after December 31 nobody rewrote the balances again.

The outflow has addresses. The accounts designated as token accounts, into which the proceeds of the issuance of the ZND token flowed in 2024, held 4.9 million euros at the start of 2025 (ZEN Token EUR 2.7 million, Sygnum EUR Token 2.1 million, and small change in złoty), and on April 22, 2026, less than zero in total. The złoty account at TryPay fell from 2.3 million to 48,000. Shares in subsidiaries rose over the same period from thirty-three to 43.6 million euros: 7.2 million euros of new payments went to ZND Ventures OÜ, the token’s issuer, at 598,000 a month until September of 2025, 395,000 as late as February of 2026 and 83,000 in March, of which 2.4 million was converted into reserve capital in May of 2025; 3.2 million to Orion, the Katowice subsidiary to which we devote a separate piece, on the account “Orion Investment agreement,” including 100,000 in March of 2026; just under 100,000 to the company in the Bahamas. According to the CEO’s balance sheet as of December 31, 2025, subsidiaries stood at 42.8 million, so 862,000 euros was paid in between January and March of 2026. Loans also appeared to entities absent from the trustee’s tally: 314,000 euros to “BB Trade (Cyprus)” at 10 per cent until 2030, in four tranches from April of 2025 to March of 2026, and 10,000 euros to “BB Trade Lithuania,” which the report calls a subsidiary. The group the trustee knows from his report has a Swiss company, Orion, ZND Ventures, and the Bahamas; the group the loan accounts describe also has Cyprus and Lithuania.

Two assets vanished without a goodbye. The investment in SEBA Bank AG, Zonda’s Swiss investment, carried in the books at 3.8 million euros, stands on April 22, 2026, at one cent; in the CEO’s balance sheet for the end of 2025 it appears as “SEBA AG 0.” The turnovers show how it went: in May of 2025 it was written off at a loss of 946,000 euros, and the price, 2.84 million, was booked not to any bank account but to the account “Sygnum crypto transactions,” where it hung until September and dissolved into the cryptocurrency turnover of the fourth quarter. The money for the shares in a bank was, in all likelihood, turned into cryptocurrency, and there the trail in the ledger ends. For how much, and to whom, the shares were sold, the agreement of January, 2025, tells us; we described it in our piece on Zonda’s exchange contracts. The same bank was lending to the exchange: the account “SEBA EUR Kantor” showed, from March to May of 2025, a balance of minus 1.9 million euros, cleared in June. And the A.T.M.: the “Payment technology ATM” entry arose in this period on the cash-and-banks account, between two accounts at SEBA. In the exchange’s books the A.T.M. was cash; the exchange was the only customer it ever paid out to.

The books also bear the marks of haste, and their older layers the marks of questions never answered. The revenue accounts (Income Trading, Income Fenige, TPAY income) sit on the liabilities side, among obligations to clients, while on the assets side hang the entries “Things in clarification” and “Missing invoices.” Client deposits via ZEN and TrustPay were booked as negative liabilities, minus 2.3 and minus 2.8 million, and a liability of 3.4 million euros to ZEN.COM UAB arose in this period, whose nature the balance sheet does not explain. The operator that did not answer the trustee has a line of its own in his balance sheet. The oldest entries did not move by a cent in the whole period: “BTC SEBA account 1104 1” with a balance of minus 19.8 million euros and its mirror image, “SEBA Trading crypto transfers ?”, plus 19.8 million, with a question mark in the name of the account; and “SEBA BTC custody account .4007” at 3.7 million, mirrored by “Blockchain Partner GP” at minus 3.7 million. The simplest reading: before 2025, bitcoins worth twenty million euros left an account at a Swiss bank, and the accountant, not knowing where they went, put down a question mark that stands there to this day. The answer lies in the SEBA, now AMINA, statements for 2022 through 2024; the trustee can ask for them.

Zero Avoidance Actions, for Now

The trustee has so far identified no grounds for setting aside transactions made before the bankruptcy. The reason is the same as everywhere: no transaction documents and no complete history of accounts and wallets. The direction, however, is visible without transaction documents, in the column of changes of the balance sheet the trustee himself attached.

Between January 1, 2025, and April 22, 2026, receivables from and investments in related parties grew by nearly fifty million euros: the loan to Orion, the Katowice subsidiary, by thirty-nine million, contributions to Orion by three million, to ZND Ventures by seven million, plus the new loan to the Cypriot company. All of it in a period the trustee himself dates as one of permanent insolvency, and Estonian bankruptcy law provides for challenging transactions made in such a period in favor of related parties. The monthly turnovers confirm this and date it. The Orion loan account carries, for the whole period, nothing but disbursements: 38.93 million euros in fifteen monthly installments, 3.6 million in January of 2025, 1.8 in February, 3.2 in March, 3.56 in April, 4.85 in May, 3.75 in June, 2.73 in July, 1.8 in August, 2.93 in September, 3.0 in October, 6.475 in November, 877,000 in December, 217,000 in January of 2026, 118,000 in February, and 20,000 on March 16, 2026, when all the company’s accounts together held 420,000 euros. More than half of the loan the trustee reports at seventy-five million went out in the last sixteen months of the exchange’s existence, and the largest monthly tranche in its history, November’s, went out in the month in which cash fell below three million. Add the investment agreement with Orion, 3.23 million, and Orion’s invoices for I.T. services, 2.7 million, at about 235,000 a month: 44.9 million euros to Katowice in a period in which the exchange’s entire sales came to 6.6 million. The list of addressees and the calendar are ready; all that is missing is the trustee’s signature on a statement of claim.

It is worth setting this beside what is already known from elsewhere. In July we showed, on blockchain data, in our piece on Zondacrypto’s clients, that between April 5 and 15 some ninety-nine million ZND tokens left the exchange’s wallet while clients were shown a price several times higher than anywhere else; in August, prosecutors charged the president of the Polish Olympic Committee, in the arrest over the Zonda token, with inciting the satisfaction of selected creditors to the detriment of the rest, thereby formally accepting that in April the company was on the brink of insolvency and was paying selectively. The material for avoidance actions exists; it just isn’t in Tallinn. Anyone counting on a quick reversal of the spring’s selective payouts should set that hope aside until the trustee obtains data from the prosecutors or gets it in Katowice by the route we describe in our piece on Orion. The warning to those who withdrew large sums just before the freeze stands; only the horizon changes.

What Follows for Creditors

The deadline for filing claims with the trustee, according to his notice, expires on October 27, 2026; a late filing, even if admitted, goes to the back of the queue. Claims are filed in euros at the value on the date of the bankruptcy declaration, August 27, 2026, with documentation to stand in for the nonexistent client ledger. We write in detail about deadlines and the form of filing in Zondacrypto Bankruptcy Declared: From Today, One Deadline Counts, and about the two tracks of proceedings in our guide Zondacrypto: How to Recover Your Money.

The picture of the estate after this report is as follows: 167,000 euros in cash, most of it in Poland and according to balances from March; zero cryptocurrency within reach; zero real estate and chattels; a brand without value; shares and receivables in subsidiaries, the largest of which, Orion of Katowice, gets a piece of its own; and 4,503 bitcoins to which, according to one of the CEO’s statements, the company has full access and, according to the other, has had none since 2022. Everything of value in this estate is either a claim requiring action in Poland or a key that one must ask a single man about. In parallel, the prosecutors have frozen more than a hundred million złoty in the investigation, reportedly above all in the assets of suspects, not of the company; an example is the four million euros in an account in France which, according to the prosecutors, derive from the sale of a Monaco company and do not belong to the exchange’s estate. The two sets overlap only slightly.

For a victim this means what we have been saying since April: a presence in both proceedings, documents instead of promises, and no advance payments to anyone who calls with a guarantee. Three things are new. There exists a statement, signed by the CEO and notarized, that the company has full and exclusive access to 4,503 bitcoins, dated ten months before the announcement that there are no keys. The CEO is reachable and writes back, at least to the Estonian trustee, though not in his own words. And the exchange’s books have monthly turnovers in which one can see whose receivables grew, and in which month of the year of the collapse, and that the cash ran out in January, a quarter before clients were told about technical problems; whose grew the most, we describe in our piece on Orion.

Legal and factual position as of September 12, 2026. The interim trustee’s findings are his assessments at a preliminary stage of the proceedings, not rulings of a court. Charges and arrests in the investigation are not findings of a court; all persons named enjoy the presumption of innocence. Assessments marked as hypotheses remain hypotheses. The balance sheet as of December 31, 2025, is an unaudited management document of the company; the balance sheet as of April 22, 2026, and the monthly account turnovers reflect books of which the accountant told the trustee that they do not reflect reality; and the quarterly wallet statements are the company’s own documents, verified by no one; an account’s turnover shows amounts and months, not the recipients of transfers. The statement of June 26, 2025, is a declaration of management whose contents the notary did not examine. Amounts are rounded.

Robert Nogacki

Robert Nogacki is a Polish attorney at law (radca prawny), the founder and managing partner of Kancelaria Prawna Skarbiec (Skarbiec Law Firm), which has operated continuously since 2006.

The law is equal for everyone, but the parties rarely are: on one side stands an organization with time, money, and lawyers, on the other a person with one business, one nest egg, and one life.

Clients rarely come to him with a legal problem. They come with a problem that also has a legal side: an audit that began with a single invoice, money entrusted to someone who has disappeared, a company that has to be passed on before it is too late. Most such matters are decided long before the first letter is written, in decisions made without asking and in deadlines nobody remembered. So he begins by asking how the client got here, not what the client should have done.

He advises entrepreneurs and families from more than a dozen countries, including those whose accounts the tax office has just seized and who do not know what to do tomorrow morning. He defends them in tax audits, customs and fiscal inspections, disputes with the tax authorities, and criminal tax proceedings. He represents victims of investment fraud and Ponzi schemes. He helps families set up family foundations and plan succession, so that a life’s work outlasts a single generation.

Not every case can be won. Every case can be run so that the client knows where they stand. Since 2006 he has represented the victims in the WGI case (Warszawska Grupa Inwestycyjna, the Warsaw Investment Group), one of the longest criminal cases in the history of the Polish financial market, because some things must not be left half finished, even when they take two decades. In the case of the collapsed cryptocurrency exchange Zonda (Zondacrypto, operated by BB Trade Estonia OÜ), he represents several hundred victims in the criminal investigation conducted by Poland’s National Prosecutor’s Office and in the Estonian bankruptcy proceedings.

Kancelaria Prawna Skarbiec is listed in the rankings of Poland’s largest tax advisory firms published by Dziennik Gazeta Prawna and Rzeczpospolita, and it is a four-time recipient (2015 to 2018) of the European Medal awarded by the Business Centre Club and the European Economic and Social Committee. Robert Nogacki publishes regularly, in the press and on the firm’s website, for people who have a problem rather than a law degree, because a legal opinion the client cannot understand protects only the lawyer.

He believes that the best legal advice is the kind that means the client never has to appear in court.