ProCap Newsletter No. 50

Dear Clients,

In cases such as ProCap, one of the frequently raised questions concerns situations where the financial trail leads to jurisdictions that do not actively participate in international legal cooperation or where access to financial data is limited.

In practice, such situations are not uncommon. Parts of these schemes are often intentionally structured through jurisdictions where obtaining information about accounts, ownership, or transactions is more difficult, precisely in order to complicate further investigation.

However, this does not mean that the process comes to a halt. Even when direct access to data is not immediately available, the analysis continues through other elements—such as preceding and subsequent fund flows, connections with other accounts, and information that can be obtained through institutions in cooperating jurisdictions.

In certain cases, competent authorities may also rely on additional mechanisms of international cooperation, including indirect requests or coordination between multiple institutions, in order to obtain relevant information.

It is important to understand that such circumstances may affect the duration of the proceedings and require more detailed analysis, but they do not in themselves prevent further progress.

In complex international cases, it is often precisely the combination of data from multiple sources that allows a broader reconstruction of financial flows, even in the presence of certain limitations.

As always, we will inform you promptly of any relevant developments.

Kind regards,
Attorney Zoran Miljaković