Crypto Wallet Freezing and Forfeiture Orders: what do the numbers say?

In April 2024, the UK introduced two new enforcement tools – Crypto Wallet Freezing Orders (CWFrOs) and Crypto Wallet Forfeiture Orders (CWFOs), aimed at targeting criminal proceeds held in cryptoassets.

To evaluate how these powers have been used in practice, Gherson Solicitors LLP submitted Freedom of Information (FOI) requests to the Serious Fraud Office (SFO) and HM Revenue and Customs (HMRC).

In response, HMRC confirmed that as of 3 July 2025 it had used fewer than five CWFrOs and CWFOs since their introduction. Due to the low number of cases, exact figures were withheld to avoid the risk of identifying the individuals involved.

By contrast, the SFO reported that it had not sought or obtained any CWFrOs or CWFOs in the period from April 2024 to 3 July 2025.

Commenting on the findings, Thomas Cattee, Partner and Head of the White-Collar Crime Team at Gherson Solicitors LLP, explained:

“We had previously noted that by its nature the SFO only investigates a few large and complex cases. This could be one of the reasons that the number of CWFrOs and CWFOs used by the SFO [was] nil. HMRC, on the other hand, conducts many more small and domestic investigations, which could be the reason for its slightly increased use”.

On 18 July 2025, however, the SFO confirmed that it had now obtained its first Crypto Wallet Freezing Order.

Commenting further, Thomas Cattee, Partner and Head of Gherson’s White-Collar Crime Team said that:

“It is great to see the SFO finally using these new powers to attempt to freeze and seize the alleged proceeds of crime stored in novel ways. 

Whilst these new powers will of course not be suitable for every investigation, it is clear from countless examples that fraudsters are turning to new and novel ways to hide the alleged proceeds of their crimes, including by way of cryptoassets, so it is very encouraging to see the UK’s premier fraud-fighting agency demonstrating that it can keep pace and demonstrably act in accordance with its business plan”. 

These early figures suggest that whilst the powers are available, their use remains limited – most likely due to the complexity of the cases or the novelty of the legal instruments themselves. However, their mere existence sends a clear signal of the UK authorities’ intention to keep pace with the evolving landscape of financial crime.

If you are affected by these developments or require advice relating to cryptoasset enforcement and investigations, Gherson’s experienced White-Collar Crime Team is here to help. Please contact us for confidential legal advice.

This commentary first appeared in:

• Taxation Magazine – Use of crypto wallet freezing and forfeiture orders | Taxation
• International Accounting Bulletin – SFO freezes crypto assets linked to Arena TV investigation
• GRIP – SFO uses new powers to freeze Arena TV CEO’s £10k in crypto assets