Jubilee Ace/ Jenco/ GTR / 3Key – Lyra Newsletter No. 233

Dear Clients,

As previously reported, the criminal complaint concerning the Jubilee matter is still being prepared and has not yet been formally submitted to the competent authorities in Sweden.

We will inform you once the filing has taken place.

In the meantime, we believe it is useful to explain what will happen after the complaint is submitted and, importantly, what the filing itself will – and will not – mean for the case.

Filing a criminal complaint is the beginning of the authorities’ assessment

Once the criminal complaint is submitted, the information and supporting documentation will be placed before the competent Swedish authorities for their consideration.

The filing will provide the authorities with the factual background, information concerning the persons and entities identified in connection with the matter, relevant transactions and the supporting material collected in preparation of the complaint.

However, the submission of a criminal complaint does not itself mean that the authorities have accepted the allegations contained in it as established facts.

It is the point at which the information is formally presented to them for assessment.

Does filing the complaint automatically mean that a criminal investigation will be opened?

Not necessarily.

After receiving a criminal complaint, the competent authorities must determine how the information should be handled and whether the legal and factual basis exists for further investigative measures.

They may assess the information provided, compare it with information already available to them and determine whether additional material is required.

The authorities may also consider questions of jurisdiction and whether the reported circumstances are connected with other information or proceedings already known to them.

For this reason, there may be a period between the filing of the complaint and a decision concerning the next procedural step.

The complaint is not expected to contain every piece of evidence that may ever become relevant

Another important point is that the evidentiary picture does not become permanently fixed on the date of filing.

The complaint will be based on the information and documentation available at the time it is submitted.

Additional evidence or information may subsequently emerge from clients, proceedings in other jurisdictions, financial records or investigative work carried out by the competent authorities.

Where relevant and procedurally possible, such information may become part of the broader assessment of the matter.

This is particularly important in an international case such as Jubilee, where the factual background extends beyond a single transaction, company or jurisdiction.

Will clients immediately receive information from the Swedish authorities?

Clients should not expect that the filing of the complaint will necessarily result in immediate individual communication from the authorities.

The first developments may concern the authorities’ internal assessment of the complaint and the accompanying material.

If further information, documentation or clarification is required from individual clients, we will explain what is needed and how it should be provided.

Until such a request arises, there is no reason to resend documentation that has already been provided.

Why is the filing nevertheless an important step?

Although filing a criminal complaint does not guarantee that an investigation will be opened or determine its eventual outcome, it represents an important procedural step.

Until the complaint is formally submitted, the material remains part of the preparation of the case.

Once submitted, the relevant facts and documentation are formally placed before the competent authorities so that they can make their own assessment and determine whether further action is warranted.

It is therefore important to distinguish between our assessment and preparation of the case and the independent assessment that will subsequently be made by the Swedish authorities.

What should clients do now?

At present, no additional action is required from you.

Please continue to preserve the original documentation concerning your investment, but you do not need to resend materials that we already have.

If you receive any new communication concerning Jubilee, Jubilee Ace, Jenco or GTR, or obtain new information directly connected with your investment, please preserve it and forward it to us.

Our immediate priority remains the completion and formal submission of the Swedish criminal complaint.

Once the complaint has been filed, we will notify you and explain the next procedural stage based on the information available at that time.

Thank you for your continued trust.

Kind regards,

Attorney Zoran Miljaković