Jul 21 2025
White Collar Crime
On 15 July 2025, Gherson’s white-collar crime team published a blog entitled:
Given that over a year has elapsed since the introduction of the Crypto Wallet Freezing Order (“CWFrO”) and Crypto Wallet Forfeiture Order (“CWFO”) in April 2024, Gherson Solicitors LLP submitted on 16 June 2025 Freedom of Information Requests (“FOIs”) to the Serious Fraud Office (“SFO”) and HM Revenue and Customs (“HMRC”) to establish the SFO and HMRC’s use of these instruments since their introduction.
In their 3 July 2025 response, the SFO confirmed that they had not sought or obtained any CWFrOs during the period April 2024 to 16 June 2025.
This, however, was about to change…
A mere three days after our 15 July blog, on 18 July 2025, the SFO announced that they had frozen the equivalent of £10,865.76 in Bitcoin and £289.30 USDC (value at the time of freezing) belonging to Richard Yeowart – a suspect in an ongoing investigation.
The SFO announced that “This is the first time the agency has used new powers that came into force last year to freeze cryptocurrency”.
The SFO further confirmed that the Westminster Magistrates’ Court had imposed the freeze for a period of nine months, and the underlying case has so far involved a raid, three arrests and a search of three properties.
Director of Operations, Emma Luxton, said:
“We are committed to using every tool at our disposal to prevent criminals from benefitting from their crimes, wherever they hide their assets. Our first Crypto Wallet Freezing Order is an important step as we build our crypto asset capability and signals our intentions as we adapt to tackle increasingly sophisticated attempts to hide criminal assets”.
In 2023, the Economic Crime and Corporate Transparency Act (the “ECCT”) amended the Proceeds of Crime Act 2002 (“POCA”) to support the recovery of cryptoassets. One specific amendment enables the introduction of a CWFrO and a CWFO. These became active in April 2024.
These are intended to work broadly in the same way as an Account Freezing Order, but also address the unique features of the technology underpinning cryptoassets.
We have explored the CWFrO in a recent blog.
In previous articles, we have discussed what AFrOs and AFOs are, as well as the Serious Fraud Office’s use of AFrOs.
What is an Account Freezing Order?
The rise and fall of the Serious Fraud Office’s Account Freezing Orders
How to Challenge an Account Freezing Order
We have also discussed what a crypto wallet freezing order is.
Additionally, we are increasingly being approached by individuals who have been “de-banked” in circumstances where they are adamant that they have always acted in full compliance with the relevant bank account’s Terms and Conditions and all other legal and applicable rules and regulations.
We have previously written about how other issues which individuals may face, including account closures, are not limited to political figures in the UK and affect many thousands of lawful individual and business customers every year. These cases have exposed the difficult balance many financial institutions and their individual and business customers must strike to gain and maintain access to basic banking services.
To assist those whose accounts have been closed, Gherson’s financial crime, investigations and regulatory team have previously written blogs entitled:
“Why has my bank account been closed?”
“Why has my business bank account been closed?”
“140,000 SMEs “de-banked” last year – why could I have been de-banked?”
“What are the proposed new laws aimed at preventing de-banking?”
“Why the proposed new laws to try and prevent de-banking do not go far enough”.
“Am I entitled to a basic bank account in the UK?”
“How to challenge crypto-related bank account closures”
We are also being increasingly approached by individuals who feel that a financial institution has wrongly imposed a CIFAS marker in their name.
If you have always acted in full compliance with the relevant bank account’s Terms and Conditions and all other applicable legal rules and regulations, then you should have a good basis to challenge the bank’s decision to implement any CIFAS markers.
A strong challenge will often involve demonstrating through evidence that you have not breached the bank’s Terms and Conditions or any rules and regulations, and that all transactions were at all times carried out in full compliance with all applicable laws and regulations.
In a previous blog, we examined what a CIFAS marker is and how to try and get it removed, as well as what you can do if a CIFAS marker has been wrongly imposed.
We have also recently examined Challenging a crypto-related CIFAS Marker: what you can do.
We also being increasingly approached by individuals who feel that incorrect and/or inaccurate data about them stored in compliance databases is having an adverse effect on their relationship with financial institutions and are facing subsequent issues, such as bank account closures and difficulties in opening a bank account.
We have also written a series of blogs with basic overviews of the main functions of compliance databases like World-Check and how you can correct information about yourself on such databases.
Gherson’s regulatory, white-collar and investigations team are highly experienced in providing assistance on what you can do if your bank freezes or closes your account. This includes assisting you with submitting a request under data protection legislation, otherwise known as a Data Subject Access Request, to ascertain what information banks and other financial institutions may be holding on you and their decision making, and then analysing the response and assisting with any appropriate challenge.
If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail, or, alternatively, follow us on X, Facebook, Instagram, or LinkedIn to stay-up-to-date.
The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.
©Gherson 2025
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