A worldwide freezing order (WFO) is a court order that stops a defendant from dealing with or dissipating assets anywhere in the world, pending the outcome of a claim. In crypto recovery it is the centrepiece: obtained urgently and often against "persons unknown", it freezes wallets and exchange accounts before stolen assets can be layered away. The English courts grant WFOs over digital assets, treating crypto as property since AA v Persons Unknown [2019].
What the law says now
English law treats crypto-assets as property capable of being frozen and traced. AA v Persons Unknown [2019] established that a cryptocurrency can be the subject of a proprietary injunction; Osbourne v Persons Unknown [2022] applied the same reasoning to NFTs. The Property (Digital Assets etc) Act 2025, which received Royal Assent on 2 December 2025, puts this on a statutory footing by confirming that a digital asset can be a "third category" of personal property.
That property characterisation is what makes the freezing toolkit work. Alongside the WFO, claimants use proprietary injunctions to ring-fence specific assets, and disclosure orders — Norwich Pharmacal and Bankers Trust orders — to compel exchanges and intermediaries to reveal who holds an account and where funds moved.
How it works in practice
The order is only the legal half. Recovery runs on two tracks at once.
- Trace first. On-chain forensics map the flow of funds to an off-ramp — usually a centralised exchange or a freezable stablecoin — and produce the evidence the court and the intermediaries will require.
- Apply urgently. WFO applications are typically made without notice, supported by full and frank disclosure, a cross-undertaking in damages, and evidence of a real risk of dissipation.
- Serve and disclose. The order is served on the defendant and on the exchanges holding the assets; disclosure orders convert "persons unknown" into named respondents.
- Police the freeze. Once assets are held, the order is maintained and enforced until the claim resolves by judgment or settlement.
Because a stablecoin issuer can blacklist an address on a court order, the freezing application and the issuer request are prepared together — the operational window is hours, so a WFO that arrives after the funds have moved is of little use.
Risks and forks
- The cross-undertaking. A claimant must usually undertake to compensate the defendant if the order turns out to be wrongly granted; the court will want evidence the undertaking is worth something.
- Full and frank disclosure. Because the application is made without notice, failing to disclose adverse facts can see the order discharged.
- Forum fit. A freezing order is only as good as the willingness of the exchange holding the assets to respect it — the forum must match where the assets and intermediaries are. The DIFC, Hong Kong and Singapore courts all grant comparable relief; we choose to fit the facts.
For the wider playbook, see our Disputes & Asset Recovery practice and the England & Wales forum guide, or weigh recovery forums in the Jurisdiction Navigator.
Cost, funding and proportionality
A worldwide freezing order is powerful but not cheap, and the court expects it to be proportionate to what is at stake. The main cost drivers are the urgency of the without-notice application, the forensic tracing that underpins it, and the cross-undertaking in damages the claimant must be able to support. For business-scale losses these costs are usually justified; for smaller sums, a targeted disclosure order or an issuer-level freeze alone may be the proportionate response.
We price recovery transparently — a retainer from $15,000 plus a success fee of 15–30% on amounts recovered — and we say at the outset whether the likely recovery justifies the freezing route. Where a defendant has assets but is hard to identify, the sequence is often a disclosure order first to name them, then a freezing order once there is a target the court can bind. The aim is to spend on the steps that move the recovery, not on a freeze for its own sake.
FAQ
Can a freezing order be obtained against unknown defendants?
Yes. English courts grant freezing and proprietary orders against "persons unknown", which is common in crypto theft where the wallet holder is not yet identified; disclosure orders then help to name them.
How quickly can a WFO be obtained?
Urgently — often within days, sometimes faster on a without-notice basis. The constraint is usually assembling the tracing evidence, which is why forensics and counsel should start together.
Does a WFO recover the assets by itself?
No. It preserves assets so they cannot be dissipated; recovery follows through judgment, settlement or an insolvency process, then enforcement.
If digital assets have been misappropriated, tell us what happened — the first call is free and under NDA, and we will set out whether a freeze is still achievable and what it would take.