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Sachs v Snape & Ors [2025] EWHC 1746 (Comm) (04 April 2025)

Source: Open mirrored case · Original bailii.org

Sanctions — Geo ✓

Executive Summary

  • The case involves Mr. Frederik Sachs (claimant) seeking proprietary and Mareva-type freezing injunctions against Mr. Haydn Ross Snape and others (respondents) over alleged misappropriation of cryptocurrency investments.
  • Sachs, an Italian entrepreneur, invested approximately £1.3 million via Snape and associated entities, including UK-based Renaissance Digital Holdings Ltd and Miami-based Dig Miami LLC.
  • The claim alleges fraud, breach of fiduciary duty, deceit, and breach of contract, with Snape acknowledging liability but failing to repay.
  • The Court considered established legal principles for cryptocurrency as property and granted injunctions to preserve assets pending trial.
  • The judgment was delivered privately to protect the anonymity of involved parties and prevent asset dissipation.

Sanctions Highlights

  • — No sanctions implications identified in the case text.

Emerging Risks

  • Increasing complexity in enforcing judgments involving cryptocurrency assets held across multiple jurisdictions (UK, Italy, USA).
  • Difficulty in identifying and serving unknown cryptocurrency wallet holders ("persons unknown") complicates asset recovery.
  • Risk of asset dissipation by defendants aware of freezing orders, necessitating urgent and private court interventions.
  • Potential for evolving legal standards on cryptocurrency ownership and enforcement of proprietary claims.

Geopolitical Impact

  • UK jurisdiction plays a central role, with Renaissance Digital Holdings Ltd incorporated in the UK and the Commercial Court in Manchester exercising authority.
  • Cross-border elements: claimant based in Italy, Miami-based company involved, highlighting challenges in international enforcement.
  • The case underscores the UK’s position as a key forum for complex cryptocurrency disputes involving multinational parties.
  • Reflects ongoing UK judicial adaptation to digital asset litigation, influencing international legal norms.

Economic Intelligence

  • The disputed investment amount is approximately £1.3 million, reflecting significant financial exposure in cryptocurrency ventures.
  • The case illustrates risks for investors in crypto markets, including reliance on intermediaries and potential for fraud.
  • Highlights the economic impact of cryptocurrency disputes on private investors and corporate entities.
  • Enforcement of freezing injunctions may preserve assets, mitigating financial losses pending final judgment.

Strategic Recommendations

  • Litigants should ensure robust contractual protections and clear jurisdictional clauses in cryptocurrency investments.
  • Early legal action with freezing injunctions is critical to prevent asset dissipation in crypto-related disputes.
  • Courts and practitioners must continue developing expertise in cryptocurrency asset tracing and cross-jurisdictional enforcement.
  • Parties should consider confidentiality and privacy measures in sensitive crypto litigation to avoid tipping off defendants.
  • Monitoring evolving UK legal frameworks and model orders for interim remedies is essential for effective litigation strategy.

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Source Notes: *Sanctions Intelligence Digest*, [https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1746.html](https://empyreanprotocol.com/litigation/view/www.bailii.org/ew/cases/EWHC/Comm/2025/1746.html)

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