Dear Clients,

In our previous newsletter, we shared details regarding our recent visit to Zagreb aimed at supplementing our criminal report. We find it valuable to inform you of the modifications we have made, which pertain to updated information regarding both the suspects and the victims.

In the text below, we have refrained from disclosing the identities of the suspects, only presenting their initials. This is in line with the principle that every individual is presumed innocent until proven guilty, or until a verdict is reached and becomes legally binding.

Below is a portion of the criminal report that we have submitted:

County Attorney’s Office of
Republic of Croatia
Criminal Department
Savska cesta 41, 4th floor, Zagreb

Based on Article 205 (NN 145/13, 70/17) paragraph 1 of the Criminal Procedure Act of the Republic of Croatia, the lawyer representing the victims submits a

C R I M I N A L     R E P O R T
Against the suspects:

T.J., B.L., L.L., M.E., M.N., J.W., N.T., A.B., P.U., M.B., C.S., K.H., S.S.P., F.R.A., F.R., D.H., and K. – a total of 17 individuals.

  •  Excel table containing photographs and information on the suspects. Attachment 1


Between 2018 and 2021, the suspects engaged in a scheme to defraud citizens from various countries, including the European Union, South Korea, the United Kingdom, the United States, Australia, Japan, Russia, and others. They intentionally established fake websites, conducted presentations through the ZOOM platform, and arranged personal meetings across the globe. Through these actions, the suspects intentionally misrepresented and concealed information about their businesses and operations, duping victims by falsely promising substantial profits through investing in their electronic software for financial arbitration services.

Regrettably, these assertions were false, and the suspects retained all of the funds they acquired. According to the criminal complaint submitted on behalf of the victims, attorney Zoran Miljaković approximates that the suspects illicitly obtained over $4 billion, which inflicted massive losses on the victims of this fraudulent activity.

The attorney represents 2,231 victims, including nine Croatian citizens. The total amount for which the clients we represent were defrauded is 257,438,701.47 USD. This case represents a clear manipulation and abuse of the trust of investors by the suspects who offered investment opportunities, leading to significant losses suffered by individuals who believed in their promises.
The total illicit financial gain obtained at the expense of citizens of the Republic of Croatia amounts to 334,956.03 USD.

  • Evidence: excel table of the victims who are Croatian nationals. Attachment 2

The total illicit financial gain obtained at the expense of all victims amounts to 257,438,701.47 USD.

  • Evidence: excel table of all victims. Attachment 3

The suspects committed the following criminal offenses through their actions:

  1. Continued criminal offense of Fraud (conspiracy to defraud) under Article 236, paragraph 2 of the Criminal Code of the Republic of Croatia.
  2. Continued criminal offense of Market Abuse under Article 260, paragraph 2, in conjunction with paragraph 1, points 2 and 3 of the Criminal Code of Croatia.
  3. Continued criminal offense of Money Laundering under Article 265, paragraph 4 of the Criminal Code of Croatia.

These criminal acts are stipulated in all European legislations. Therefore, an equivalent example of these offenses in German legislation are:

  1. Fraud: “Betrug” (§ 263 StGB)
  2. Market manipulation: “Marktmanipulation” (§ 38 WpHG)
  3. Money laundering: “Geldwäsche” (§ 261 StGB)

Although the specifics of these criminal offenses may vary from country to country, their basic objective is the same across all European countries and most countries worldwide – to prevent the commission of illegal activities that may include fraud, theft, embezzlement, and the like.

To be continued …

Zoran Miljakovic
Attorney at Law