Jubilee Ace/ Jenco/ GTR / 3Key – Lyra Newsletter No. 212

Dear Clients,

In complex cases such as Jubilee Group, one of the key questions that often arises is who actually stands behind the system and makes the key decisions, particularly in situations where the formally appointed directors or owners represent only part of a broader structure.

In practice, individuals who are formally registered as directors or legal representatives are not necessarily the ones who truly managed the operations. For this reason, in such proceedings particular attention is given to identifying the so-called “actual control” over the system.

This type of analysis is not limited to official registries, but rather involves a broader assessment of how the business operated in reality. It includes examining who made key decisions, who had access to financial resources, who organized communication with users, and who managed the operational aspects of the platform.

In this context, digital evidence, communication between participants, and the way funds were transferred between different accounts and entities can all play an important role.

By connecting these elements, it becomes possible to determine who exercised real influence and control, regardless of how the structure was formally presented.

Understanding the distinction between formal roles and actual control is essential for assessing how responsibility is established in practice in such cases.

Any further relevant developments will be communicated without delay.

Kind regards,
Attorney Zoran Miljaković