Citadel Securities (Europe) Limited & Anor v Leonard Lancia & Anor

A standard cross-undertaking in damages supporting a freezing order should not be removed merely because the underlying award has become a judgment and remains unpaid. The relevant question is whether the respondent’s conduct and the surrounding arrangements justify treating continuing restraint as self-induced. A materially different position arises where the respondent is taking steps to provide security and is participating in a timetable for evidence addressing that security.

A court should not require applicants to direct a third party to lift an account restriction where the freezing order may properly apply to the assets concerned. The applicants may instead be required to clarify the order’s scope and invite the third party to raise any questions promptly.

This was the return date for a worldwide freezing order granted by Bright J on 12 February 2026. The order had initially been made while an award was outstanding; in the meantime, the award had been converted into a judgment. The parties agreed amendments and a timetable for a further return date, but disagreed about the first cross-undertaking in damages and the treatment of a cryptocurrency exchange that continued to block assets.

The claimants sought removal of the undertaking, relying on the judgment debt and the defendant’s failure to pay. The defendants sought an order requiring the claimants to instruct Crypto.com to lift its block. The issues were whether the undertaking should remain and what clarification, if any, should be required in relation to Crypto.com.

1. The first cross-undertaking remained in force. The court rejected the claimants’ reliance on VB Football Assets v Blackpool Football Club (Properties) Ltd [2017] EWHC 2767 (Ch). That case involved an unpaid judgment debt, an apparent absence of effort to comply, and asserted assets sufficient to discharge the debt. Here, the defendant had offered security and was participating in a timetable intended to provide evidence about the value of the relevant shareholding. The circumstances were materially different, so the undertaking was retained.
2. It remained open to the claimants to seek reconsideration at the further return date, or earlier if circumstances materially changed.
3. The court refused to require the claimants to instruct Crypto.com to lift its block. Unlike Gate, Crypto.com had not raised specific questions or requested confirmation. The exchange might independently have concluded that assets responsive to the freezing order were held. Directing the claimants to require release could undermine the operative effect of paragraph 6 of the order.
4. The appropriate interim step was for Astraea Group to write again to Crypto.com, reminding it that the order applied only to assets within its terms, inviting questions or requests for information, and asking that any block be lifted if the order did not apply. The ultimate decision remained Crypto.com’s.
5. The court made no concluded determination on the later criticism concerning dissemination of the freezing order. It indicated at this stage that sending the order, accurately describing its effect, inviting questions, and suggesting independent English legal advice appeared appropriate.