New York Crypto Investment Scam Recovery Demand Letters

[Date] Legal and Compliance Department [Exchange Name] [Address] Re: Fraud Report and Account Freeze Request - NY Resident Scammer Wallet: [Wallet Address] Total Loss: $[Amount] in [BTC/ETH/USDT] NYDFS Complaint: [Complaint Number] NY AG Complaint: [Complaint Number] Dear Compliance Team: I represent [Victim Name], a New York resident who lost $[Amount] to a cryptocurrency investment fraud scheme. Blockchain analysis confirms that stolen funds were deposited to an account at your exchange. As a NYDFS BitLicense holder, I am writing to demand immediate account freeze and preservation of records pursuant to your regulatory obligations under 23 NYCRR Part 200. FRAUD SUMMARY Between [Start Date] and [End Date], my client was targeted by a "pig butchering" investment scam. The perpetrator, using the identity "[Scammer Name/Alias]" on [Platform - e.g., WhatsApp, dating app], cultivated a relationship with my client before directing investments to a fraudulent trading platform at [Fake Platform URL]. My client, a New York resident, transferred the following amounts: - [Date]: [Amount] [Currency] - TX Hash: [Hash] - [Date]: [Amount] [Currency] - TX Hash: [Hash] - [Date]: [Amount] [Currency] - TX Hash: [Hash] BLOCKCHAIN TRACING On-chain analysis traces funds through the following path: [Client Wallet] → [Intermediary Wallet(s)] → [Your Exchange Deposit Address] The deposit address [Address] is associated with an account at your exchange. Transaction records are attached as Exhibit A. NEW YORK REGULATORY AND LAW ENFORCEMENT STATUS This fraud has been reported to: - NYDFS Virtual Currency Unit: Complaint #[Number] - NY Attorney General Investor Protection Bureau: Complaint #[Number] - FBI Internet Crime Complaint Center (IC3): Complaint #[Number] - FTC Consumer Sentinel Network: Report #[Number] The NY Attorney General's office may contact you regarding potential Martin Act violations related to this fraud scheme. DEMANDS PURSUANT TO BITLICENSE OBLIGATIONS As a NYDFS BitLicense holder under 23 NYCRR Part 200, your exchange has obligations to maintain anti-money laundering programs, report suspicious activity, and protect consumers. I request: 1. Immediate freeze of any account(s) associated with deposit address [Address] and wallet [Scammer Wallet]; 2. Preservation of all records related to the account holder, including KYC documents, transaction history, IP logs, and linked accounts; 3. Confirmation within seven (7) days that the freeze is in place; 4. Filing of any required SARs related to this fraudulent activity; 5. Cooperation with NYDFS, NY AG, and law enforcement investigations. LEGAL NOTICE Failure to take appropriate action in response to credible fraud reports may expose your exchange to regulatory action by NYDFS, including license review under 23 NYCRR 200.15. Additionally, exchanges that receive specific fraud reports and fail to act may face civil liability under New York common law. This matter involves a New York resident victim and likely constitutes securities fraud under the New York Martin Act (N.Y. Gen. Bus. Law Article 23-A), which applies broadly to fraudulent practices in connection with securities and does not require proof of scienter. Please direct all communications to owner@terms.law. My client is prepared to provide additional documentation and to coordinate with your compliance team and regulators. Sincerely, Sergei Tokmakov Attorney for [Victim Name] Enclosures: - Exhibit A: Blockchain Transaction Analysis - Exhibit B: NYDFS and NY AG Complaint Confirmations - Exhibit C: Communication Screenshots