In April 2026, Switzerland's Federal Supreme Court settled a question crypto compliance teams have been quietly nervous about for years: how much do you actually need to know before you're allowed, or required, to freeze a client's crypto assets over a sanctions concern?
The Court's answer: suspicion that the wallet is owned by a sanctioned body is enough to freeze the entity.
That changes what "enough" means for every crypto asset service provider operating under Swiss sanctions law, and for their counterparts elsewhere running the same calculation.
The case
A Liechtenstein-based investment vehicle held crypto assets with a Zurich crypto asset service provider. The vehicle's initial controller was the nephew of Suleiman Kerimov, a Russian businessman under US sanctions since 2018 and later sanctioned by the EU and UK as well. In November 2022, the US designated the nephew himself, citing his ties to his uncle.
The Zurich provider froze the account, reported the freeze to SECO, the Swiss government office that administers and enforces sanctions in Switzerland (roughly Switzerland's equivalent of the US Treasury's OFAC), and declined to release the assets despite repeated requests. The client sued, first in a Zurich court, then on appeal to the Federal Supreme Court. Both courts sided with the provider.
The Court's reasoning is the part worth focusing on. It held that a provider does not need proof that a sanctioned person actually controls the assets in question. A reasonable suspicion that the assets may be tied to a sanctioned person, directly or through someone close to them, is sufficient to justify a freeze. Nor can a provider wait for government confirmation before acting: if the evidence is strong enough to warrant a report to SECO, it is strong enough to justify freezing the assets at the same time. Otherwise, funds could be moved before any regulator has the chance to weigh in.
The problem this creates
A ruling of this kind places compliance teams in a difficult position. If a name or familiar family connection is revealed, it may raise suspicion that it is associated with a sanction entity. The client in question could be entirely unconnected, sharing a surname and nothing more. Or the concern could be legitimate: a spouse, a business partner, or a shell company established by someone who is, in fact, sanctioned.
The cost of an incorrect assessment runs in both directions. Freezing a legitimate client's assets on a thin or unfounded suspicion invites legal action, reputational harm, and the loss of that client. Releasing assets that later prove connected to a sanctioned person invites a very different conversation with a regulator.
What the Kerimov case makes clear is that uncertainty no longer provides cover. The only durable position is having already done the work required to resolve it.
Where Nominis comes in
This is the point at which Nominis intelligence can assist: converting a vague suspicion into a clear determination, in either direction.
- Wallet attribution and entity clustering trace a wallet back to the real person or organization behind it, allowing a name-based flag to either be substantiated as a genuine connection or dismissed as a false positive.
- Geointelligence, as part of Nominis's broader intelligence layer, adds real-world location and jurisdictional context to a wallet or entity, showing where activity is actually taking place rather than where it is claimed to occur, which is often as significant as the question of control itself.
- Off-chain intelligence connects on-chain clusters to the real-world detail required to resolve a suspicion: corporate ownership records, family and associate ties, the same kind of connections central to the Kerimov case.
- Ongoing monitoring ensures that a client who appeared unconnected at onboarding, but later develops a genuine link, such as a new designation involving a relative or business partner, is surfaced automatically, rather than going unnoticed until a regulator raises the question.
Taken together, this is less about flagging risk and more about resolving it: giving a compliance team the ability to state, with confidence, that a suspicion is unfounded and the client can be cleared, or that it is legitimate and the freeze is warranted. Either conclusion is defensible. An unresolved guess is not.
The Takeaway
Reasonable suspicion is now a legal trigger with consequences in either direction: freezing too late risks complicity in a sanctions breach, while freezing without adequate grounds risks liability to the client. The providers best positioned, regardless of outcome, are those equipped to determine which situation they are actually facing, and to demonstrate how they reached that conclusion.
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