Case study: tracing fraud proceeds through Switzerland – offshore & corporate

Assets routed through Switzerland can look, at first glance, like a closed door. A numbered account, a nominee director, a holding company with no visible beneficial owner – each layer is designed to create that impression. In our experience, the impression rarely survives a structured investigation.

This case study describes how Axiom Trace traced fraud proceeds through a Swiss-linked offshore structure, identified the beneficial owner behind nominee arrangements, and coordinated the legal steps – with admitted local counsel in Switzerland – that ultimately positioned the client to pursue the frozen assets. No outcome is guaranteed. What this matter illustrates is that the structural complexity of a Swiss route is a feature of the fraud, not an obstacle to tracing.

The account below follows four stages: Situation, Strategy, Process, and Transferable Lessons.

Situation: a corporate payment trail that disappeared into a Swiss holding company

A mid-sized European trading company discovered, in the autumn of 2024, that a senior employee had authorised a series of payments to a supplier that did not exist. The funds – in the high six figures – had been routed from the company's operating account in one jurisdiction to a Swiss-registered holding vehicle, and from there onward. The company had a name, a registration number, and nothing else. The nominee director was a Swiss trust and administration company. The ultimate shareholder was listed as another offshore vehicle, registered in a jurisdiction that does not maintain a publicly searchable beneficial ownership register.

By the time the client came to us, the money had been moving for several weeks. That delay mattered. But it did not make the matter untraceable.

Strategy: what the structure told us before we asked anyone

The structure of a fraud is itself evidence. A Swiss holding company with a nominee director, an undisclosed beneficial owner, and outgoing transfers to a second jurisdiction tells a practitioner a great deal before any formal process begins.

The first analytical step was mapping the corporate architecture. We identified the Swiss vehicle's registration details, its nominee director's disclosed client base, and the receiving account's correspondent banking path. On-chain components were absent here – this was a fiat-payment matter – but the banking trail showed the same choke-point logic that applies to crypto flows: money passes through institutions that have records.

We recommended two parallel tracks. The first was a disclosure application in the client's home jurisdiction – a Bankers Trust order directed at the correspondent bank – to obtain account records for the Swiss vehicle. The second was engagement with admitted local counsel in Switzerland, because Swiss banking secrecy and the rules governing access to account information require proceedings to be initiated within the Swiss legal system, not merely by foreign court order.

This is the defining feature of Switzerland as a recovery jurisdiction: Swiss procedure governs how account information is accessed, and foreign orders do not automatically displace it. Acting through local counsel is not optional – it is the mechanism by which the investigation advances.

Process: layers removed one by one

Working with local counsel in Switzerland, the team applied through the appropriate Swiss channels to compel the Swiss trustee company to identify the beneficial owner of the holding vehicle. The application relied on the principles underlying beneficial ownership disclosure – Switzerland maintains a register of beneficial owners for companies formed there, accessible under defined legal conditions – and on the civil-procedure tools available to a claimant with evidence of fraud.

In parallel, the Bankers Trust-type order obtained in the client's home jurisdiction provided account movement records for the period of the fraud. Those records showed outgoing transfers in two tranches: one to a second European jurisdiction, one to a Gulf state. Each tranche required its own local coordination.

The sham-trust analysis of the beneficial ownership documentation – once the Swiss trustee company was compelled to produce it – confirmed that the disclosed "beneficial owner" of the Swiss vehicle was itself a nominee. The actual controller was identified through corporate filings in a third jurisdiction, cross-referenced against the payment authorisation records the client had preserved internally. Asset tracing, in a matter like this, is not a single act. It is a sequence of smaller disclosures, each narrowing the field.

A proprietary injunction was then sought in the jurisdiction where the controller was identified as resident, covering assets held in that person's name and in the name of connected vehicles. Coordinating that application, the Swiss disclosure process, and the client's home-jurisdiction proceedings simultaneously is the operational core of a cross-border matter. No single court sees the whole picture; the recovery team has to hold it together.

If you are assessing a matter with a similar structure, the Axiom Trace Switzerland jurisdiction guide sets out the procedural environment in more detail.

Transferable Lessons: what this matter teaches about Swiss-route fraud

Several patterns from this matter recur across the offshore and corporate recovery work we conduct.

First, nominee structures are an obstacle to speed, not to identification. A nominee director is a disclosed fact – the trustee company's name is public. That name is the starting point for a UBO register application, a disclosure order, or a regulatory complaint. The myth that an offshore structure makes assets legally untouchable does not survive contact with a jurisdiction that maintains beneficial ownership records and has functioning civil courts.

Second, Swiss banking secrecy is a legal regime, not a permanent seal. It has defined exceptions for fraud and for civil proceedings supported by evidence. Those exceptions are the route in. They require admitted local counsel and properly constituted process – but they are available.

Third, the correspondent banking path is often the fastest source of early intelligence. Fiat payments cross correspondent banks. Correspondent banks have records. A Bankers Trust order, or its functional equivalent in the client's home jurisdiction, can produce those records without alerting the defendant, provided the application is made without notice.

Fourth, delay is the defendant's best defence. Every week that passes after the fraud is a week in which assets can be moved again, or dissipated. The decision to act – or to wait and see – is itself a strategic decision with consequences.

For a related perspective on receiver appointments to investigate stripped assets, see our analysis of appointing a liquidator to trace assets in Guernsey.

If proceeds from a fraud you are investigating have passed through Switzerland – through a holding company, a numbered account, or a nominee arrangement – a confidential case review will tell you whether the structure is as impenetrable as it looks. Contact us at info@axiomtracel.com.

About Axiom Trace

Axiom Trace is an independent boutique focused on cross-border and crypto asset recovery. We trace assets that have moved across borders or on-chain and coordinate their freezing and recovery – working with defrauded principals, insolvency practitioners, and the lawyers and funders who refer them. We coordinate closely with admitted local counsel in Switzerland; local procedure governs the filing and the conduct of proceedings there. We work lawfully and within applicable sanctions regimes. In our experience, the structures used to conceal fraud proceeds are rarely as permanent as they are designed to appear. To discuss a matter, contact info@axiomtracel.com.

Disclaimer: This publication is for general information only and is not legal advice, nor a promise or prediction of recovery. No outcome is guaranteed. Asset recovery depends on the specific facts and on the law and procedure of each relevant jurisdiction, where local admitted counsel must act. Axiom Trace coordinates closely with admitted local counsel in Switzerland; local procedure governs the filing. Axiom Trace assumes no liability for actions taken or not taken based on this material. For advice on your situation, contact info@axiomtracel.com.