Migom Bank’s Path to Payouts: Where Funds Are and What Happens Next

Migom Bank
Written By:
IndustryTrends
Published on

After a long stretch of anxious refreshes and rumor-mill updates, there’s finally structured progress in the Migom Bank story. The statutory administration has completed a comprehensive evidence review, regulators in Dominica have set out next steps, and the process is now pointed toward appointing a liquidator and, ultimately, returning money to verified customers.

What’s new: the administrators’ update at a glance

Dominica’s Financial Services Unit (FSU) issued a “cease business” directive to Migom Bank on February 29, 2024, and then appointed a statutory administrator on March 18, 2024, transferring day-to-day control to an independent UK law-and-accounting team. Those two official steps created the legal footing for the investigation and recovery work that followed.

In August 2024, the administrators submitted their findings to the FSU, supported by more than 14,000 pages of documentation and summarized in a 153-page cover letter. 

Recent coverage describes this file as the blueprint for tracing historical transactions and organizing the recovery phase. Media updates through spring and summer 2025 indicate that the regulator now intends to appoint an internationally recognized liquidator to pursue asset recoveries and manage distributions to eligible account holders.

How the picture got clearer

According to multiple reports, the administrators’ dossier reconstructs the movement of funds over several years across a handful of related corporate entities in Luxembourg, the UAE, Austria, Ghana, Canada, and the United States. 

The reviews also highlight a pattern of transfers executed without the usual board approvals or regulator sign-off. These details now guide where recovery efforts focus. Crucially, the reporting frames these points as findings from the administrators’ review rather than legal conclusions about liability.

For customers, that mapping becomes a practical playbook for the liquidator. It secures recognition where needed, requesting restraints where permitted, and coordinating with correspondent institutions to bring assets back. That’s the nuts-and-bolts work between today’s “we found it” and tomorrow’s “we paid it.”

Where funds have been traced so far

Recent coverage consistently points to funds identified in the Baltics with roughly €26 million in total across Latvia and Lithuania, and additional smaller amounts noted in other jurisdictions. In Latvia, the sources refer to approximately €21 million associated with Baltic International Bank SE, a lender whose license the European Central Bank withdrew in March 2023 (context confirmed independently by Latvia’s central bank and local media). 

In Lithuania, around €5 million is described as remaining under control following the 2023 revocation of Transactive Systems UAB’s e-money license by the Bank of Lithuania. While these figures come from press reporting on the administrators’ work, the regulatory background on both institutions is a matter of public record.

The takeaway: the bigger pieces of the puzzle have known locations and well-documented regulatory histories, which are helpful ingredients when a liquidator seeks court recognition and cooperation to repatriate assets.

Some readers will remember a securities class-action complaint filed in New York on August 30, 2024. Docket records show that the plaintiffs voluntarily dismissed that case on March 12, 2025. Recent reporting notes that stakeholders may seek to incorporate the administrators’ work into any future filings, but, to be clear, there is no active class action on the docket today.

What customers can expect next

With the groundwork finally in place, the story shifts from uncertainty to execution. The administrators’ structured roadmap and recent coverage point to a practical next phase in which the process is carried out methodically rather than argued in headlines, a change of pace that signals real momentum. 

For customers, that simply means staying ready for official communications and letting the machinery do its work. The most valuable update today is confidence: there is a clear sequence ahead, supported by documentation and regulatory oversight, and it is geared toward converting mapped balances into orderly distributions. It’s not hype, but a disciplined path forward.

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