Dear Clients,

This week we received a notice from the District Attorney’s Office in Zagreb that our latest submission, which supplemented the criminal complaint, has been added to the case files. We must be persistent, tenacious, and patient, and with undiminished enthusiasm, give our all to bring this case to a close.

To remind you, the case of 3Key Lyra is an incredibly audacious and brazen scam. The claims that the suspects became insolvent through hacking and token theft are a science fiction story that is not supported by any evidence. Even if it were true, it does not excuse their actions. Their obligation was to protect the investments of their clients to the maximum extent possible, which they failed to do.

Extract from the criminal report:

Attachment 2

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)


Each victim signed up through their referral link, which they received from the organizer, and then physically registered and created their own user account with an appropriate password. After that, each victim invested their money in 3Key Lyra projects. The perpetrators presented themselves online as well-organized and credible through a website, Zoom meetings, and public presentations. They promised a 100% guarantee of security and further, they promised a significant return on the investment.

To be continued…

Zoran Miljakovic
Attorney at Law