International Experience in Tracing Digital Assets (the U.S. Example)

International practice has developed several approaches to locating and seizing cryptoassets, which could be useful for adoption in Ukraine.

United States: Enforcement and Technology Instead of Special Laws

In the United States, cryptocurrencies are classified as a type of property. Despite the absence of a single comprehensive law on cryptoassets, U.S. courts and agencies actively apply existing legal mechanisms to control and seize digital assets. The trend can be described as “regulation through enforcement”: while Congress has not yet adopted new rules, various agencies (SEC, IRS, DOJ) are adapting current laws to cryptocurrency realities.

Court-Ordered Disclosure and Freezing

In both civil and especially criminal cases, U.S. courts do not hesitate to compel a defendant to provide access to cryptoassets. A 2025 precedent: a federal judge in Texas ordered a man convicted of tax evasion to hand over to investigators all private keys to his cryptocurrency wallets — involving about $124 million in bitcoin subject to forfeiture to pay $1 million in restitution. This is an unprecedented step demonstrating the authorities’ determination: essentially, the person was ordered to unlock his crypto fortune, under threat of punishment for contempt of court (civil contempt or additional criminal penalties). This approach is possible when the debtor has already been held liable (for example, convicted) and the court has leverage. In civil cases (e.g., bankruptcy or debt collection), similar rulings also occur: if a debtor refuses to disclose assets, they can be jailed for contempt until they provide the required information or access.

Investigations and Transaction Tracing

The U.S. has a well-developed sector of companies specializing in crypto analytics — Chainalysis, Elliptic, CipherTrace, and others. These companies often work with the government (through contracts with the DOJ, IRS, etc.) and also serve private clients. Modern algorithms can process massive amounts of blockchain data and identify links between wallets and real individuals. Experts estimate that it is now possible to trace up to about 70% of cryptocurrency wallets and transactions, decrypting their history and potentially tying them to owners.

The myth of total cryptocurrency anonymity is fading — it has long been clear that the blockchain records the entire history of funds movement; one simply needs to know how to read it.

U.S. digital forensics specialists skillfully combine blockchain analysis with traditional evidence gathering: they use subpoenas to obtain exchange data (IP addresses, customer KYC information), monitor social media, and scour darknet forums where the debtor may have “exposed” their wallets. In high-profile cases, this is exactly how cryptoassets were found: for example, in the Bitcoin Fog hacker case, NSA analysts tracked coins through dozens of transactions and linked them to a real person. In debt collection, private creditors can hire such firms to “hunt” for hidden assets — often justified when the debt is large and there are suspicions that the debtor has significant crypto holdings.

Cooperation with Exchanges

In the U.S., most major cryptocurrency exchanges (Coinbase, Kraken, etc.) are registered as entities obligated to comply with the law and enforce court orders. This means that, at the request of a court or law enforcement, an exchange will freeze a debtor’s account and disclose its balances. There have been cases where platforms proactively helped identify fraudulent assets or return funds to victims under court rulings. For a creditor, having the debtor’s assets on a regulated U.S. exchange is a stroke of luck, as the recovery mechanism will be almost identical to that for a bank account. In some legal disputes, parties have gone so far that courts allowed serving a summons or order directly via the debtor’s blockchain wallet (in one case, a New York court permitted service to an unknown defendant by sending an NFT token to their Ethereum address).

This illustrates the U.S. judiciary’s willingness to experiment to address new technologies.

In the U.S., there is an active discussion about improving laws governing digital assets.

As part of updates to the Uniform Commercial Code (UCC), proposed amendments define “control” over digital assets, simplifying their transfer to creditors as collateral or during enforcement. Some states (Wyoming, Texas) have adopted laws recognizing cryptocurrency as property and outlining sheriff procedures for digital wallets. At the federal level, there is already a rule requiring exchanges and brokers to report large cryptocurrency transactions to the IRS — aimed in part at detecting potential tax and debt evasion. Thus, the U.S. is forming an approach of “you can’t hide behind crypto.”

Even without a special crypto law, a debtor is not protected: authorities will find a way to access a digital wallet, if necessary through a court order or enforcement pressure.

A telling example is the aforementioned case of Richard Allgren in Texas. After being convicted of tax evasion, the judge went beyond merely stating the repayment amount — issuing a detailed order to disclose all private keys, list all devices storing cryptocurrency, and ban any transactions without court permission. Essentially, the defendant was placed under full financial supervision to ensure that the ~$1 million debt would be paid from his cryptocurrency portfolio.

This sets a precedent and a kind of “action plan” for other enforcement cases: if a debtor in the U.S. holds significant cryptoassets, the court can side with the creditor and forcibly ensure access to them.