Sixteen volatile months after Dominica's Financial Services Unit (FSU) told Migom Bank to shut its doors, investigators have traced roughly €26 million to accounts in Latvia and Lithuania, secured restraint orders in several other jurisdictions, and cleared the way for an internationally recognized liquidator to start reimbursing eligible customers. The development marks the most concrete progress since thousands of account holders saw their log-ins freeze early last year, replacing guesswork with a step-by-step recovery timetable.
From Rapid Rise to Regulatory Red Line
Migom vaulted onto the fintech radar in May 2020, when Nevada-based Migom Global Corp. paid the seller in stock to acquire the Dominican institution, promising to blend classic banking with fast crypto rails. Corporate treasuries from Europe to Africa soon parked funds in Roseau, lured by multi-currency settlement and a multilingual sales pitch.
Momentum faltered as 2023 opened: correspondent bank links collapsed, support desks went dark, and complaints about stalled withdrawals flooded social forums. On 29 February 2024, the FSU issued a "cease business" directive and removed sole director Thomas Adrian Schätti. Nineteen days later, on 18 March 2024, the regulator appointed a joint UK law-and-accountancy team as statutory administrator, handing them full operational control.
Inside the Administrator's Evidence Trove
Working from secure rooms in London and Roseau, the team assembled more than 14,000 pages of statements, emails, and blockchain logs, distilled into a 153-page cover letter filed with the FSU in August 2024. Their analysis shows that funds left Migom through at least seven related vehicles, including Migom Investments SA (Luxembourg), Migom Investment FZE (UAE), Migom Verwaltungs GmbH (Austria), Migom Ltd (Ghana), Spectrum Payments Inc. (Canada), and two U.S. entities without board approval or regulator sign-off. Administrators say these unapproved transfers affected both customer deposits and regulatory capital, depriving even the Dominican treasury of tax and license payments.
Where the Money Landed
Latvia. Roughly €21 million was channeled into Baltic International Bank SE shortly before the European Central Bank withdrew that lender's license on 10 March 2023.
Lithuania. Reportedly, about another €5 million remains under court control after the Bank of Lithuania fined and simultaneously revoked Transactive Systems UAB's e-money permit on 2 June 2023 for serious AML breaches.
Smaller sums held in Vienna, Dubai, Accra, Montreal, and New York are now subject to restraint orders, giving investigators a documented trail for every major jurisdiction cited in the report.
The administrator paired traditional subpoenas with blockchain analytics dashboards to match on-chain movements against fiat ledgers, collapsing months of detective work into weeks and enabling near-real-time account freezes abroad. Dominica's own success rate with mutual-legal-assistance (MLA) requests proved crucial once evidence packets were ready.
What Happens Next: Liquidator, Claims Window, Dividends
The FSU is short-listing an internationally recognized liquidator and expects to announce the appointment in the coming weeks, handing over day-to-day recovery and distribution tasks. Verified creditors—those who already submitted updated KYC packs during administration—will be pre-approved; others will have 90 days to file once the liquidator publishes notice. If Latvian and Lithuanian courts authorize early outbound transfers, a first interim dividend could reach compliant customers during Q1 2026, with final payouts following asset sales and any residual litigation.
A securities class action filed in New York on 30 August 2024 was voluntarily dismissed on 12 March 2025 so plaintiffs could fold the administrator's findings into a broader claim; no action is active today. The pause removes near-term courtroom noise while the recovery track proceeds, though observers expect a refiling once discovery is complete.
A Realistic Roadmap at Last
For Migom's global client base, the question has shifted from where the money went to when it comes home. Funds are identified and immobilized, and a seasoned liquidator is imminent. The journey is far from over, but the goal—real money in real accounts—has never felt closer.
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