When it comes to tackling fraudulent investment schemes, victims often feel that they have little hope of ever recovering what is rightfully theirs, especially when the fraudsters hide behind complex cross-border structures and anonymous cryptocurrency wallets.
But the recent decision in Frederik Ali Florian Detlev Sachs v Haydn Ross Snape & Ors [2025] EWHC 1746 (Comm) shows that, with the right legal team, justice can prevail.
In a powerful judgment handed down by His Honour Judge Pearce in the Business and Property Courts in Manchester, Giambrone & Partners LLP secured extensive proprietary and Mareva-type freezing orders for the Applicant/Claimant against Mr Haydn Ross Snape, his brother, associated companies and even persons unknown holding crypto wallets.
Represented by Mr Brad Pomfret KC and Mr Kartik Sharma, instructed by Giambrone and Partners' experienced civil fraud lawyers, Joanna Bailey and Demetri Bezaintes, this success is more than just a court win. It is a vital demonstration that Giambrone and Partners leave no stone unturned in pursuing our clients stolen assets, wherever they are hidden!
The Judge praised the quality and efficiency of the work undertaken by the Applicant's legal team:
"I am grateful to [Mr Pomfret KC and Mr Sharma] for
their written submissions and to Mr Pomfret KC for his oral
submissions, which have enabled this case to be dealt with
efficiently."
(Paragraph 3)
Background: How Haydn Ross Snape Defrauded a Sophisticated Investor
As the judgment reveals, the Applicant/Claimant, a successful entrepreneur, was persuaded by Mr Haydn Ross Snape in September 2023 to invest significant sums (over £1.3 million) in cryptocurrencies and related projects (see Paragraphs 4–6). Despite repeated promises, Mr Snape failed to return any funds and, worse still, took steps to hide them.
The Judge noted Mr Snape's "evasiveness" (Paragraph 20) and found clear evidence that there was "a real risk of dissipation" of assets if the freezing orders were not granted.
Bringing Fraudsters to Justice in the Cryptocurrency Era
This case further develops the law on protecting victims of fraud in the digital age.
The Court expressly relied on modern authorities — a sign that Giambrone and Partners continues to shape and strengthen the framework for recovering stolen assets:
- Tulip Trading Limited v Wladimir Van Der Laan [2023] EWCA Civ 83 — confirming that cryptocurrency can be treated as property for the purpose of proprietary injunctions (Paragraph 17).
- Dos Santos v Unitel S.A. [2024] EWCA Civ 1109 — clarifying that the test for a freezing injunction is a "good arguable case" and a real risk of asset dissipation (Paragraph 18).
- Commercial Bank of Dubai PSC v Al Sari [2024] EWHC 3304 (Comm) — relied on by the Court to confirm that complex cross-border service can succeed under Gateway 3 of the CPR, enabling victims to pursue assets in multiple jurisdictions (Paragraph 28).
Key Court Findings: Proprietary & Mareva Freezing Relief
The Court found that the Applicant/Claimant had an arguable proprietary claim over funds that were "obtained under fraud or breach of trust", justifying a powerful freezing injunction extending to all known respondents and persons unknown (Paragraphs 16–21).
Following the Applicant's submissions, the Court allowed service out of the jurisdiction on the US-based company DIG MIAMI LLC, showing how fraudsters cannot evade accountability by moving money abroad (Paragraphs 8 & 28). The Judge also accepted innovative arguments for using the new CPR model orders, further demonstrating that Giambrone stays ahead of procedural changes to protect victims fast (Paragraph 12). Finally, the Court agreed that no guarantee was needed beyond the Applicant's cross-undertaking in damages (Paragraph 30).
Criminals Can Run but They Can't Hide
This case should serve as a warning to fraudsters like Mr Haydn Ross Snape: "If you defraud investors, your assets can and will be frozen, even if they are hidden in complex offshore structures or pseudonymous crypto wallets."
As HHJ Pearce concluded, the balance of convenience is firmly on the side of victims:
"It would be harsh to deprive him [Mr Sachs] of a
remedy which I otherwise would have granted simply on the grounds
of delay... I am satisfied... an order is appropriate on the facts
of this case."
(Paragraphs 22–26)
Giambrone's Fraud & Asset Recovery Team is recognised for:
- Acting immediately to secure freezing injunctions worldwide.
- Working seamlessly with leading KC counsel, digital forensics, and crypto-tracing experts.
- Pioneering the development of case law for victims of fraud — whether involving digital assets, offshore companies, or hidden bank accounts.
- Enforcing judgments relentlessly — ensuring criminals are held accountable wherever they hide.
When other firms might say recovery is impossible, Giambrone and Partners prove that it is not.
Giambrone and Partners has extensive success in assisting victims of financial fraud to recover their funds lost to fraud. Our highly experienced fraud litigation lawyers can advise and guide you through the entire process.
Demetri Bezaintes is an associate based in the London office within the Financial Services and Crypto Litigation Department. He is a solicitor in England & Wales and also a qualified Greek Lawyer (dikigoros).Demetri has a thorough knowledge of investment fraud and fund tracing. He works tenaciously for our clients, advising on cryptocurrency, Forex trading disputes and regulatory investigations. He draws his expertise in investment law from his experience in the banking sector and his experience in banking and financial services regulation. Prior to joining Giambrone & Partners Demetri worked at an international bank, where his main focus was the enforcement of freezing orders and third-party debt orders.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
