SFO launches first major crypto investigation involving an alleged $28 million fraud

The Serious Fraud Office (“SFO”) has just issued a request for investors to come forward with any information they may have about the collapse of a $28 million cryptocurrency scheme called Basis Markets. This is the first major cryptocurrency investigation announced by the SFO.

The agency has already conducted two raids and made two arrests as part of this investigation.

In this article we explore the details of this investigation and examine the SFO’s previous crypto-related activity.

Details of the SFO investigation

It is reported that SFO investigators, supported by the Met Police and West Yorkshire police, searched two properties and made two arrests on suspicion of multiple frauds and money laundering offences.

It is alleged that Basis Markets raised approximately $28 million via two public fundraisers, including by selling non-fungible tokens and using the proceeds to create a “crypto hedge fund”. However, according to reports, in 2022, investors in the scheme were informed that due to proposed new US regulations, the project could no longer proceed.

SFO’s previous crypto-related activity

We have been tracking the SFO’s crypto-related activity for some time.

In summary, despite a slow start, the SFO has demonstrated a willingness to use its powers and, on 18 July 2025, secured its first Crypto Wallet Freezing Order (“CWFrO”).

How much have the Serious Fraud Office (SFO) and HM Revenue and Customs (HMRC) used Crypto Wallet Freezing and Forfeiture Orders since their April 2024 introduction?

Serious Fraud Office secures first Crypto Wallet Freezing Order

What is a Crypto Wallet Freezing Order?

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 Crypto Wallet Freezing Order (“CWFrO”) and Crypto Wallet Forfeiture Order (“CWFO”). Both became active in April 2024.

The CWFrO and CWFO are tools designed to assist authorities in conducting investigations, including those involving crypto assets. They are intended to work broadly in the same way as the Account Freezing Order but addressing the unique features of the technology underpinning cryptoassets. We have explored the CWFrO in more detail in one of our recent articles.

It is currently unclear whether the SFO has sought any Crypto Wallet Freezing Orders in its most recent investigation. However, it is encouraging to see that the SFO continues to publicly investigate crypto-related allegations.

What is an Account Freezing Order and Account Forfeiture Order?

In previous articles, we have provided a detailed overview of the Account Freezing Order and the Account Forfeiture Order.

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.

NAVIGATING FINANCIAL INSTITUTION RELATED CHALLENGES

How to challenge a wrong decision to close my personal and/or business bank account(s)

To assist individuals whose accounts have been closed, Gherson’s White-collar Crime, Investigations and Regulatory team have published the following articles:

• 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 aimed at preventing 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

How to challenge a wrongfully imposed CIFAS marker

We have also been receiving a large number of enquiries from individuals complaining that a financial institution has wrongfully 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 in your name.

A strong challenge will often involve demonstrating through evidence that you have not breached the bank’s Terms and Conditions or any other rules and regulations, and that all your transactions complied fully with all applicable laws at all times.

In our previous articles, we have explored what a CIFAS marker is, and how to get it removed, and also what to do if a CIFAS marker has been wrongfully imposed.

We have also written about how to challenge a crypto-related CIFAS marker.

Adverse information on compliance databases

We are often asked for advice and assistance in circumstances where an individual suspects that incorrect and/or inaccurate data relating to them is stored in compliance databases, which negatively affects their relationship with financial institutions, resulting in issues such as bank account closures or difficulties with opening a bank account.

We have written a series of articles with a basic overview of the main functions of compliance databases such as World-Check and how to correct personal information in such databases.

How Gherson can assist

Gherson’s White-collar Crime, Investigations and Regulatory team are highly experienced in providing assistance in circumstances where a bank freezes or closes a customer’s account. This includes assisting with submitting a request under the data protection legislation, otherwise known as a Data Subject Access Request, to ascertain what information banks and other financial institutions may hold on the affected individual, and how they make their decisions, and, thereafter, 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