How Zondacrypto’s Victims Became Suspects
On the people who decided not to be victims, and on the one office that never doubted them. Robert Nogacki, 11 August 2026
Investigators have pulled the exchange’s entire database out of the cloud: every zondacrypto client, every transaction, back to 2017. And the database has yielded a curious result. There are nearly twice as many victims as there are complaints on file. Over three and a half thousand people have come forward; roughly the same number decided not to be victims. A tax official explained this to journalists politely and anonymously (anonymity being the only institution in this affair with an unblemished record): these people are afraid of being asked where they got the money for their crypto.
And here the state deserves some credit. No police force in the world has ever cut crime in half with a single question. Ours has managed it. Nobody had to be caught; it was enough to let it be known that the one who might get caught is the one who shows up. A victim who does not report does not figure in the records. Statistically, he is a happy man.
Let us examine this happiness up close. Citizen N. belongs to the silent half. He kept his savings on the exchange; in April the exchange stopped paying out; the balance stayed on the screen, correct to the penny, precise to eight decimal places. Eight decimal places look like the truth. N. gazes at it every morning, the way one gazes at a photograph of someone who has gone away.
N. filed no complaint. He considered it, but first he went to see his neighbor, who had. The neighbor was sitting over a ring binder. They took everything, he said, and then they asked where the money had come from. So now he documents: the sale of grandmother’s plot of land in 2011, his daughter’s wedding (the envelopes, the guest list), a bonus from a company that no longer exists, which means tracking down its former payroll clerk. Grandmother is still outstanding; he will have to establish where grandmother got the plot. A man once traced his nobility: coats of arms, ancestors at Grunwald. Today he traces his cash, and the book of heraldry has given way to the bank statement. N. inspected the binder, said thank you, and went home a statistically happy man. His money was already lost. His life story he preferred to keep.
There is just one snag in this happiness. N. did not report to the state, but the state has N. in the cloud. In the database the investigators pulled, N. figures in his entirety: every transfer, every trade, nine years of financial life. N. keeps silent, but the cloud testifies on his behalf. The cloud testifies for everyone: no summons, no caution, no right to remain silent. N. was afraid of the question “where from”, while the database answers the question “how much”, and does so with the same eight decimal places of precision that N. was so fond of, back when they worked for him.
And the question “how much” is awaited by the second office, the one that never doubted N. The prosecutor wonders whether N.’s money really existed and whether it was respectable. The tax office has no such misgivings: it knows the money existed, knows how much, and takes the view that, at bottom, it still does. The proof is on the screen; the balance glows. N. sold his bitcoins for zlotys inside the exchange panel, the zlotys were credited on the screen, and whatever is credited on the screen counts, under settled administrative practice, as income. That nobody ever paid the zlotys out to N., and nobody now will: a detail. The tax office taxes events, not disappointments.
I have written about this elsewhere, coolly and with footnotes. For thirty-five years the statute has known the cash-basis method: income is what has been received or placed at the taxpayer’s disposal, and a number in the app of an exchange that does not pay out is neither the one nor the other. Three administrative courts, in Kraków, Warsaw and Poznań, said the same thing in three judgments. A single general ruling from the Minister of Finance would suffice. The Minister keeps silent. Silence, for tax purposes, is neutral anyway: it has been neither received nor placed at anyone’s disposal.
Such is the state of two faiths. One institution distrusts the money that truly existed; the other believes fervently in the money that does not exist at all. The same zloty is either suspect or taxable, depending on the counter window. Between the windows stands N.: a man suspected of his own misfortune.
The method, incidentally, has a future, and it is a wonder nobody has patented it. All it takes is to ask every victim a question. Your flat was burgled? And where did you get so many possessions. Your car was stolen? Kindly produce six years of fuel receipts. The statistics will fall wherever the victim has anything to explain, and the victim always has something to explain, because he has lived. Perpetrators, for now, remain outside the method: a perpetrator does not come forward, so there is nothing to ask him.
In the evening N. sits down over his return. In this country a man who has been robbed has two declarations at his disposal: one at the prosecutor’s office, voluntary, after which one may become a suspect, and one at the tax office, mandatory, after which one certainly becomes a taxpayer. N. files only the second; he has learned by now that, around here, exercising one’s rights can be riskier than performing one’s duties. He enters in the box an income he will never see, on assets that may never have existed, and out comes a tax: the only entirely real thing in this story.
And the moral? There will be no moral. A moral would first have to show where it came from.
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.
