After months of uncertainty, the statutory administration of Migom Bank has reached a turning point. A recent report submitted to the Dominican financial authorities reveals a clearer picture of events — and outlines the road ahead toward fund recovery and future resolution.
A Comprehensive Review Brings New Transparency
In August 2024, the statutory administrator of Migom Bank — a joint venture between UK legal and accounting professionals — submitted a detailed report to Dominica’s Financial Services Unit (FSU). This report follows an extensive forensic investigation into the Bank’s operations to clarify past fund flows and support the recovery of client and institutional assets.
The administrator’s findings were backed by over 14,000 pages of supporting documents and summarized in a 153-page cover letter authored by the lead UK barrister. The evidence provided a detailed look into the historical activity of the Bank’s former leadership and outlined a path for future remediation.
Importantly, the report helped demystify many of the fund movements that had concerned depositors and regulators since early 2023. It traced specific transactions, accounts, and third-party entities linked to outgoing transfers — all of which will inform the next phase of administrative action.
Entities and Fund Movements Identified
One of the administrator’s key objectives was to establish where former client funds were routed. The report identified several companies, located across multiple jurisdictions, that were historically associated with Migom Bank’s former leadership. These included entities registered in Luxembourg, the UAE, Austria, Ghana, the United States, and Canada.
By mapping these connections, the administrator created a reliable foundation for tracing fund locations and initiating formal recovery mechanisms.
Notably, the report confirmed that transfers involving both fiat and digital assets had occurred outside the standard frameworks for client consent and regulatory authorization.
Government Responds with Next Steps
Following its review of the administrator’s report, the Government of the Commonwealth of Dominica has initiated a coordinated recovery and resolution plan. As part of this process, an internationally recognized liquidator will be appointed to lead the next phase of asset retrieval and distribution.
The liquidator’s mandate will be to pursue recoverable funds — including those previously deposited with correspondent institutions — and ensure fair, orderly reimbursement to verified account holders.
Two important developments support this next phase. First, €21 million was previously traced to an investment made by the Bank’s former leadership into a European institution that has since ceased operations.
Second, an additional amount close to €5 million is held with a former payment processor in Lithuania. These findings help narrow the recovery scope and give regulators and the forthcoming liquidator a strong starting point for enforcement.
A Pause, Then Forward Motion
For Migom Bank stakeholders, the road to this point has not been easy. Over the past year, banking services were paused, and questions about the security of deposits loomed large.
However, the administrator’s report brings new clarity — and a shift toward resolution rather than uncertainty.
While the findings acknowledge the challenges created by historical fund management, they also chart a forward-looking path that places account holders at the center. Clients who completed their Know Your Customer (KYC) documentation during the administration period will be prioritized for reimbursements once the liquidation process is underway.
In parallel, insights gathered from earlier legal filings — some of which were voluntarily withdrawn by the plaintiffs in 2025 — may be reintroduced in a revised and more comprehensive form.
These developments reflect the broader shift from speculation toward evidence-based resolution and international cooperation.
Institutional Cooperation and Global Engagement
The administrator’s process has highlighted the importance of cross-border coordination in the financial sector. With fund flows and digital assets often spanning multiple countries, the support of institutions in Europe, the Caribbean, and North America has been essential in progressing toward recovery.
The forthcoming liquidator will work closely with banking partners, compliance teams, and local authorities to ensure that recovery efforts continue in a lawful and structured manner. This coordinated strategy reflects broader trends in financial oversight, particularly in high-growth digital banking sectors.
Importantly, the administration has emphasized transparency and regular communication with stakeholders throughout. This approach has helped rebuild trust and set expectations for what the final recovery and resolution process will deliver.
A Message to Account Holders
For depositors and clients, the key takeaway is that the administration process has now entered a more actionable phase. Funds have been traced, and recovery steps are in motion. Account holders who have provided the necessary documentation will have the opportunity to reclaim their balances once the liquidator is appointed and procedures are formally underway.
Further updates will be shared as the liquidation and reimbursement efforts progress. While the timeline for full resolution may vary depending on international coordination, the direction is now clear — and the efforts underway are rooted in formal evidence and active cooperation among stakeholders.
Looking Ahead
Migom Bank’s statutory administration has uncovered essential information, aligned international parties, and created a framework for the return of client assets. While challenges remain, especially across international legal and financial systems, this is a pivotal step toward final resolution.
For those following the situation closely, this latest update is a turning point in the Migom Bank saga. It affirms that meaningful progress is being made and that the recovery process is firmly underway, guided by fact, documentation, and transparency.
