ZURICH. A Swiss victim of a fake trading platform usually ends up in two places. The first is a cantonal police station, where a criminal complaint opens a file. The second is a law firm that knows what a blockchain explorer is, where a race begins. Stolen coins move in minutes. Swiss mutual legal assistance moves in months.
Few Swiss firms trace anything themselves. The specialist work, following transactions across public ledgers, clustering addresses, spotting the moment funds touch a regulated exchange, is commissioned from analytics providers abroad. A growing share of that work is now done in Hong Kong, and the reasons are practical rather than romantic.
Hong Kong is a common law jurisdiction that conducts proceedings in English. Its courts grant freezing injunctions and disclosure orders against exchanges, remedies a Swiss lawyer can explain to a Swiss client without translation. Since June 2023, the city’s trading platforms operate under a Securities and Futures Commission licence, which means customer records exist in a form a court order can reach. And the local forensics sector was hardened by Hong Kong’s own fraud wave, above all the JPEX collapse, which left behind a dense market of tracing specialists and lawyers who have handled crypto evidence before.
There is also the clock. An instruction sent from Zurich at four in the afternoon is on a desk in Hong Kong before Asian markets open. Cases that would lose a day per exchange of letters lose only a night.
What the Hong Kong partner actually delivers is a report. It cannot freeze a single coin. Only three kinds of actor can do that. The exchange holding the account can block withdrawals. The issuer of a stablecoin can act at contract level: Tether maintains a blacklist for USDT and says it applies it on court orders and law enforcement requests. And courts can issue the injunctions that give the other two legal cover. English courts confirmed in 2024 that USDT counts as property that can be frozen, a ruling Hong Kong practitioners cite often.
The realistic sequence looks like this. Trace the funds to a cash-out point. Obtain a court order or a police request that the exchange will honour. Freeze. Then litigate or wait for confiscation, and accept that what returns may be worth less in francs than what was lost, because the market does not pause for proceedings.
The limits deserve the same honesty as the methods. Mainland China banned crypto trading in 2021. A Hong Kong judgment can in principle be presented for enforcement on the mainland under the reciprocal arrangement in force since January 2024, but mainland courts retain wide discretion to refuse crypto-related claims, and in practice funds that settle there are close to unreachable. Several Western governments suspended extradition and parts of their legal assistance arrangements with Hong Kong after 2020. Swiss requests travel through the Federal Office of Justice and are examined case by case; practitioners describe routine fraud cooperation at police level as still functioning, only slower. Russia and the sanctioned jurisdictions are dead ends, and no BRICS framework changes that.
The recoveries that succeed tend to share one feature. The stolen funds touched a licensed exchange in a cooperative jurisdiction before dispersing. Everything else is a report that ends with an honest no.
Victims briefing a firm in either city should expect the boring version. A written mandate. Fees invoiced in fiat, never requested in crypto or gift cards. No demand for seed phrases or remote access software. A written tracing report that can be handed to the police. Timelines measured in months, and a real possibility of refusal. A provider that guarantees a percentage is not the remedy for the first scam. It is the second one.
The Swiss-Hong Kong route works, when it works, because each side supplies what the other lacks: Swiss procedural weight at one end, Hong Kong speed and venue at the other. It does not work often enough to promise anything, and the industry’s credible practitioners are the ones who say so.