In the first installment of this series, I shared how BlockDivers became involved in the FX Winning investigation and how what began as a forensic blockchain tracing assignment evolved into a complex international investigation spanning multiple jurisdictions.
One of the most common questions I receive after speaking with attorneys, victims, and financial professionals is surprisingly simple:
“Once you’ve traced the cryptocurrency, what happens next?”
The answer is that tracing the cryptocurrency is often only the beginning.
The same is true for litigation.
Many people assume that once a court enters judgment against a defendant, the case is effectively over. In reality, particularly in international fraud matters, obtaining a judgment is frequently the point at which the most difficult work begins.
That lesson became abundantly clear during the FX Winning investigation.
A Judgment Is a Legal Victory—Not Necessarily a Financial One
By early 2025, the United States District Court for the Southern District of Florida had entered judgments exceeding $85 million against David Merino and other defendants connected to the FX Winning matter.
For the victims, these judgments represented an important legal milestone.
But they also raised an entirely new question:
How do you enforce a U.S. judgment against a defendant who is no longer in the United States, whose assets may exist as digital currency, and whose activities span multiple jurisdictions?
Traditional judgment enforcement has long operated within centralized financial systems. Investigators locate bank accounts, identify real property, garnish wages, or attach assets held within a court’s jurisdiction.
Cryptocurrency fundamentally changes that equation.
Digital assets do not reside inside a traditional bank. They move across decentralized blockchain networks, are often transferred through multiple jurisdictions, and may ultimately be held by custodians or exchanges subject to entirely different legal systems.
The challenge is no longer simply finding the assets.
The challenge is determining how those assets can be lawfully reached.
Why Speed Matters
One of the most important lessons we’ve learned through numerous cryptocurrency investigations is that time can be one of the most valuable assets in a recovery effort.
When digital assets move onto a regulated domestic exchange, there may be a limited opportunity for attorneys and law enforcement to pursue appropriate legal remedies, depending on the facts of the case and the applicable jurisdiction.
Those opportunities can disappear quickly.
Once assets move beyond domestic jurisdiction—or continue flowing through multiple exchanges and jurisdictions—the legal and investigative landscape becomes substantially more complex.
That is why blockchain monitoring, real-time intelligence, and rapid coordination between investigators, counsel, and authorities can be just as important as the original forensic tracing itself.
In cryptocurrency investigations, knowing where the money went yesterday is valuable.
Knowing where it is today—and where it may move tomorrow—is often even more important.
International Recovery Is Different
International cryptocurrency recovery requires a different mindset than traditional asset recovery.
The blockchain itself has no borders.
Courts do.
That distinction changes everything.
Rather than asking only, “Where did the money go?” investigators must also answer questions such as:
- Who controls these assets?
- Which jurisdictions have legal authority over the people or institutions involved?
- Which exchanges may be able to assist?
- Which legal remedies are available in each country?
- How can investigative intelligence be transformed into enforceable legal action?
These questions rarely have simple answers.
Each jurisdiction has its own laws, procedures, evidentiary requirements, and level of experience dealing with digital assets.
Unlike traditional financial litigation, there is still no universal roadmap for recovering cryptocurrency across international borders.
Taking the Case International
As the investigation progressed, it became clear that meaningful recovery efforts would require action outside the United States.
Before the U.S. judgments could even be presented overseas, they first had to undergo a series of authentication and legalization procedures in the United States to ensure they would be recognized by foreign authorities.
Only after completing those legal formalities could the judgments become part of a broader international enforcement effort.
Our team then traveled overseas to meet with multiple legal professionals experienced in complex cross-border litigation.
One reality became immediately apparent.
While many firms possessed exceptional litigation experience, international cryptocurrency enforcement remains an emerging area of law. There were relatively few established examples demonstrating how a case of this scale should be approached.
Rather than relying upon a single legal avenue, the investigation evolved into a coordinated international strategy involving multiple legal and investigative disciplines working toward a common objective.
Building an International Strategy
The first component focused on civil enforcement.
After completing the necessary legal procedures, the U.S. judgments were successfully recognized by the appropriate court in the foreign jurisdiction, allowing enforcement efforts to proceed under local law.
That recognition represented far more than an administrative step.
It transformed a judgment entered by a U.S. federal court into one capable of supporting meaningful legal remedies abroad.
As the proceedings advanced, additional judicial measures were obtained to preserve the integrity of the case and strengthen enforcement efforts.
At the same time, separate criminal proceedings were initiated through local counsel under the applicable laws of that jurisdiction.
Each legal track served a distinct purpose within the broader international enforcement effort.
While the proceedings were independent, together they reflected an important lesson: successful cross-border cryptocurrency recovery often requires multiple coordinated legal, investigative, and intelligence efforts operating simultaneously.
There is rarely a single action that resolves a complex international fraud matter.
Beyond the Blockchain
One of the biggest misconceptions surrounding cryptocurrency investigations is that the blockchain report is the finished product.
In our experience, it is often the starting point.
A forensic report can identify wallet activity, trace transactions, and reveal patterns of fund movement.
It cannot, by itself, recover assets.
Successful recovery frequently requires investigators, attorneys, forensic specialists, local professionals, regulators, law enforcement agencies, and trusted international partners working together across multiple jurisdictions.
The blockchain provides intelligence.
Recovery requires execution.
The Broader Lesson
The FX Winning investigation reinforced something we have long believed at BlockDivers.
Cryptocurrency recovery is not simply a technical exercise.
It is an international investigative discipline.
Technology identifies opportunities.
Relationships help transform those opportunities into action.
Over the years, BlockDivers has built a global network of trusted attorneys, investigators, forensic specialists, former government officials, and other professionals across numerous jurisdictions. That network allows us to move beyond technical blockchain analysis and coordinate the legal, investigative, and operational efforts that complex international matters often require.
Every jurisdiction presents different legal frameworks, different procedural requirements, and different practical challenges. There is no universal playbook for international cryptocurrency recovery, which is why local knowledge, trusted relationships, and coordinated execution are often just as important as technical expertise.
The blockchain may show where digital assets have been.
A court judgment may establish legal rights.
But neither, standing alone, recovers cryptocurrency, or the FIAT assets once the crypto has been off-ramped.
Successful recovery happens when technology, legal strategy, international coordination, and experienced investigators work together toward a common objective.
That is the lesson we carried forward from FX Winning—and one that continues to shape how we approach every international cryptocurrency investigation today.
Coming Next
In the final installment of this series, we’ll take readers inside what happens after an international arrest is made. We’ll examine why an arrest is not the end of a cryptocurrency investigation, how recovery efforts continue long after the headlines fade, and the ongoing challenges of transforming investigative success into meaningful financial recovery for victims.
