Jubilee Ace/ Jenco/ GTR / 3Key – Lyra Newsletter No. 240

Dear Clients,

Last week, we informed you that we had submitted a criminal complaint concerning Jubilee Group to the Swedish Police, together with supporting evidence and documentation collected on behalf of affected investors.

Following this important step, we would like to address another question that is particularly relevant in international investment fraud cases:

How can authorities in different countries cooperate to identify those responsible and establish what happened to investors’ money?

Investment fraud schemes rarely operate within the borders of a single country. Investors may live in one jurisdiction, communicate with representatives in another, and transfer their funds through accounts or companies located elsewhere.

This international dimension can make investigations more complex, but it also creates opportunities for cooperation between law enforcement authorities.

Why might evidence from several countries be important?

In cases involving international investment platforms, individual investors often possess only part of the overall picture.

One investor may have communicated with a particular representative, another may have transferred money to a different company, while others may have received payment instructions or contractual documents identifying additional individuals or entities.

Viewed separately, these details may appear unrelated.

However, when information from multiple sources is examined together, it may help reveal connections between individuals, companies, financial transactions and the organisation of the reported activities.

Such connections can be important when determining who exercised actual control over particular operations and whether there are grounds for establishing legal responsibility.

How can Swedish authorities cooperate with authorities abroad?

Sweden has access to various mechanisms for international cooperation in criminal matters, particularly within the European Union.

Depending on the circumstances and applicable legal requirements, these mechanisms may allow competent authorities to request evidence, obtain relevant information, coordinate investigative activities or seek assistance from authorities in other countries.

Cooperation may also involve organisations such as Europol or Eurojust where their involvement is appropriate.

For example, if relevant bank records, witnesses or companies are located outside Sweden, international legal cooperation may provide a means of obtaining information that would otherwise be difficult to access.

However, such cooperation is not automatic. The competent authorities must determine whether particular measures are necessary, legally justified and appropriate for the investigation.

Why is this relevant to Jubilee Group?

The circumstances reported by affected Jubilee Group investors involve an international dimension, making it important to consider the potential relationships between different individuals, companies and financial transactions.

The criminal complaint submitted to the Swedish Police, together with the supporting documentation, is intended to provide the authorities with information that may assist them in examining these relationships.

Evidence collected from individual investors may also help identify similarities in the way the platform operated, including communications with investors, payment arrangements and representations made about the investments.

Where relevant information is located in different jurisdictions, international cooperation may become important in establishing a more complete understanding of the reported activities.

At this stage, however, we cannot confirm that the Swedish authorities have initiated specific international investigative measures in connection with our submission. Any such steps will depend on their assessment of the complaint and the available evidence.

Can international cooperation also help victims recover their money?

Potentially, yes.

Establishing connections between individuals, companies and financial transactions may be relevant not only to determining responsibility but also to identifying assets that could potentially be pursued through appropriate legal procedures.

In international investment fraud cases, assets may be held in different countries or registered in the names of different individuals or entities.

Depending on the applicable legal framework, cooperation between authorities may assist in tracing, preserving or recovering certain assets.

Nevertheless, identifying assets does not automatically mean that they will be available to compensate victims. Any potential recovery will depend on the relevant legal procedures, ownership rights and decisions of the competent authorities.

What happens next?

Our criminal complaint has been submitted to the Swedish Police, and the next procedural steps remain within the competence of the relevant Swedish authorities.

We will continue to monitor developments and assess any information that may be relevant to protecting the interests of Jubilee Group victims.

Although international cases can involve complex legal and practical challenges, cooperation across borders may play an important role in establishing the facts, identifying those potentially responsible and exploring possible avenues for financial recovery.

The fact that an investment scheme operated across several countries does not necessarily mean that the individuals involved or the relevant financial transactions are beyond the reach of legal proceedings.

We remain committed to pursuing the available legal avenues on behalf of affected investors and will inform you of any significant developments.

Thank you for your continued patience and trust.

Kind regards,
Attorney Zoran Miljaković