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Other jurisdictions

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CaseCitationCourtProposition
AA v Persons Unknown[2019] EWHC 3556 (Comm)High Court of England and Wales (Bryan J)Crypto assets are property for the purposes of a proprietary injunction, adopting the UK Jurisdiction Taskforce statement.
Ion Science Ltd v Persons UnknownUnreported, 21 December 2020High Court of England and Wales (Butcher J)Lex situs of a crypto asset is the place where its owner is domiciled; Bankers Trust orders against foreign exchanges.
Wang v Darby[2021] EWHC 3054 (Comm)High Court of England and Wales (Stephen Houseman QC)No trust over tezos tokens exchanged under a bilateral arrangement; the parties' contract governed.
Tulip Trading Ltd v Van der Laan[2023] EWCA Civ 83Court of Appeal of England and WalesSerious issue to be tried whether bitcoin developers owe fiduciary duties to owners who have lost their keys.
Osbourne v Persons Unknown[2022] EWHC 1021 (Comm)High Court of England and WalesNFTs are property; injunction and disclosure orders.
Piroozzadeh v Persons Unknown[2023] EWHC 1024 (Ch)High Court of England and Wales (Trower J)Injunction against an exchange discharged; limits of proprietary relief against an exchange that has mixed deposits.
D'Aloia v Persons Unknown[2024] EWHC 2342 (Ch)High Court of England and Wales (Richard Farnhill, Deputy Judge)USDT is property capable of being traced and held on trust; claim failed on tracing through a mixed account at trial.
Ruscoe v Cryptopia Ltd (in liquidation)[2020] NZHC 728High Court of New Zealand (Gendall J)Crypto assets are property; exchange held customers' coins on express trust, one trust per coin type.
Re Gatecoin Ltd[2023] HKCFI 914Court of First Instance, Hong Kong (Linda Chan J)Crypto assets are property under Hong Kong law; whether customer assets were held on trust depended on the terms of service in force.
Nico Constantijn Antonius Samara v Stive Jean Paul Dan[2022] HKCFI 1254Court of First Instance, Hong KongBitcoin is property capable of being the subject of a Mareva-type injunction.
SEC v Ripple Labs Inc682 F. Supp. 3d 308 (S.D.N.Y. 2023)United States District Court, Southern District of New York (Torres J)Institutional sales of XRP were investment contracts; programmatic sales on exchanges were not.
SEC v Terraform Labs Pte Ltd684 F. Supp. 3d 170 (S.D.N.Y. 2023)United States District Court, Southern District of New York (Rakoff J)Terra tokens offered as investment contracts; Howey applied to a Singapore issuer.
In re Celsius Network LLC (Earn programme)Bankr. S.D.N.Y., 4 January 2023United States Bankruptcy CourtUnder the terms of use, crypto assets in Earn accounts belonged to the estate and customers were unsecured creditors.
Skatteverket v David HedqvistCase C-264/14, ECLI:EU:C:2015:718Court of Justice of the European UnionExchange of bitcoin for traditional currency is a supply of services exempt from VAT as a transaction concerning currency.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.