Asset recovery claims involving crypto-assets have proliferated in recent years as a result of rampant fraud in the crypto industry. Such claimants generally cast around for proprietary claims, given the likely futility1 of enforcing personal judgments against pseudonymous “Persons Unknown”, who more often than not lie beyond the jurisdiction of the courts. Where claimants are able to put forward evidence alleging a link between the proceeds of fraud and identifiable crypto-assets, usually in exchange-operated wallets, they have hitherto achieved favourable outcomes. With defendants generally absent from the proceedings, an initial crop of decisions seeking interlocutory injunctions2 was swiftly followed by a series of decisions obtaining summary judgment on equitable proprietary claims.3 In truth, however, these early successes belie the far from straightforward nature of proprietary claims.4 For example, the involvement of crypto-asset exchanges complicates the legal analysis and courts have become alive to the possibility of crypto-assets being “swept” into central pools and dissipated into an exchange’s general assets.5 Yet, despite suggestions that blockchain analytics is “not entirely uncontroversial”,6 the courts have so far generally accepted uncontradicted evidence from crypto forensics experts purporting to show that the exchange indeed holds assets traceable to the claimant’s property.7 What happens, however, when that evidence is contested? Can crypto forensics satisfy a court that the claimant’s crypto-assets can be traced (or followed) to a defendant’s wallet?

It turns out that the answer is “probably not”. In D’Aloia v Persons Unknown,8 the first English judgment on crypto recovery following a full trial on the merits, the court delivered a devastating blow to claimants relying on crypto analytics, not only finding that the claimant failed to show that any of his crypto-assets were traceable to the sixth defendant (an exchange called Bitkub), but comprehensively indicting the expert’s tracing methodology. The tale is as old as crypto: D’Aloia fell victim to an investment scam, transferring a total of around £2.5 million to fraudsters, who quickly dispersed the sum