Citadel Securities (Europe) Ltd & Anor v Lancia & Anor [2026] EWHC 880 (Comm) (13 March 2026)
The cross-undertaking in damages should remain in place because the circumstances differ materially from those in VB Football Assets; there is an agreed timetable for the provision of security evidence and ongoing efforts to comply. The court will not require the claimants to instruct Crypto.com to lift the block, as there has been no request from Crypto.com and it is for the exchange to determine the applicability of the freezing order to the assets in question.
- Citation
- [2026] EWHC 880 (Comm)
- Parties
- Claimant: Citadel Securities (Europe) Limited; Claimant: Citadel Management (Europe) II Limited; Defendant: Leonard Lancia; Defendant: Portofino Technologies
- Jurisdiction
- England and Wales
- Judgment Date
- 13 March 2026
- Procedural Posture
- Commercial Court Proceedings (freezing Order) / Return Date Hearing on World Wide Freezing Order
- Outcome
- Interim orders continued with modifications; cross-undertaking in damages to remain; no order requiring claimants to instruct Crypto.com to lift block.
- Legal Topics
- Freezing Orders, Post Judgment Relief, Cross Undertakings in Damages, Third Party Asset Blocking
Case Brief
Summary, issues, holding and outcome
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Parties
Citadel Securities (Europe) Limited
Claimant
Citadel Management (Europe) II Limited
Claimant
Leonard Lancia
Defendant
Portofino Technologies
Defendant
Procedural Posture
Commercial Court Proceedings (freezing Order) / Return Date Hearing on World Wide Freezing Order
Legal Issues
- 1 Whether the cross-undertaking in damages should be removed from the freezing order post-judgment
- 2 Whether the claimants should be required to instruct Crypto.com to lift an asset block
Ratio Decidendi
The cross-undertaking in damages should remain in place because the circumstances differ materially from those in VB Football Assets; there is an agreed timetable for the provision of security evidence and ongoing efforts to comply. The court will not require the claimants to instruct Crypto.com to lift the block, as there has been no request from Crypto.com and it is for the exchange to determine the applicability of the freezing order to the assets in question.
Court Disposition
Interim orders continued with modifications; cross-undertaking in damages to remain; no order requiring claimants to instruct Crypto.com to lift block.
Orders
- Cross-undertaking in damages in schedule B to remain in the freezing order.
- Astraea Group to send a clarifying email to Crypto.com, inviting queries and setting a deadline for response, but not instructing the block to be lifted.
Full Case Text
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