The Law Firm That Can Freeze Your Stablecoins — and Doesn't Have to Explain Why

Imagine your stablecoins have been frozen. You learn it was by order of a U.S. court, but there are no details — the case is sealed. You go to the token issuer, and they wave you off: "Direct all inquiries to walletinquiries@willkie.com." A quick search reveals this is the email of a New York law firm called Willkie Farr & Gallagher. But why you’ve been sent there and what lawyers have to do with any of this remains a mystery.

This is not a mistake. In 2026, Willkie Farr & Gallagher became the de facto "sheriff" of the stablecoin market. The BitOK editorial team investigated how this happened and who is behind the firm.

On the night of March 23, 2026, USDC issuer Circle froze 16 wallets belonging to various businesses. Some of the affected parties, as on-chain investigator ZachXBT’s research showed, had no connection whatsoever to the case Circle cited when blocking the addresses.

None of the victims were warned in advance — they discovered the freeze after it had already happened. Companies simply found that withdrawals and payments had stopped working. When they contacted Circle, they were told: the freeze was carried out by order of the U.S. District Court for the Southern District of New York, case number 26-cv-2327. For details, contact Willkie Farr & Gallagher.

The problem is that case 26-cv-2327 is sealed — all materials are classified. On PACER and CourtListener, where victims of such freezes typically go for details on court decisions, there is no plaintiff name, no judge name, and no complaint text. In other words, the affected party has no idea who froze their funds or why.

A few days later, a wallet holding 130,966 USDC was unfrozen. Several more addresses were subsequently released. Some stablecoins remain frozen to this day.

This incident drew the crypto community’s attention to Willkie Farr & Gallagher and their mysterious email address. Numerous questions arose: What is this company? Who is behind it? Why does a major stablecoin issuer redirect freeze victims to their email? Let’s find out.

Willkie Farr & Gallagher is one of New York’s oldest law firms and is considered one of the largest in its category. A brief overview:

In 2022, the firm established a crypto division — Willkie Digital Works. It was headed by J. Christopher Giancarlo, former Chairman of the Commodity Futures Trading Commission (CFTC), known in the industry as "CryptoDad." Among his deputies is Christina Littman, former head of the SEC’s crypto unit.

In December 2025, Willkie alumnus Michael Selig became the 16th Chairman of the CFTC. Giancarlo himself announced his departure from the firm in April 2026 — practically concurrent with the freeze scandal.

Willkie Digital Works has an "official facade" and a "shadow" specialization:

Put simply: the storefront advertises legal consulting, but the arsenal includes tools of "digital enforcement agents" who help freeze assets. They don’t boast about the latter, since the reputation of an "executioner" has never been good for business in the crypto industry.

Willkie Farr & Gallagher’s architecture rests on three pillars. Let’s examine each.

In 1999, the U.S. Supreme Court ruled 5–4 in Grupo Mexicano v. Alliance Bond Fund that federal courts cannot freeze a defendant's assets before judgment if the plaintiff is simply seeking monetary damages.

However, the precedent left a loophole: a freeze is permissible if the plaintiff asserts a so-called "equitable claim" to specific property. In simpler terms — if you can show the court: "These specific tokens at this specific address were stolen from me, and I can trace them on the blockchain."

Crypto assets fit this loophole perfectly.

Blockchain analysis through services like BitOK's Graph allows tracing the path of tokens from the victim to a specific wallet. 

The plaintiff tells the court: this is my property; it's just sitting at a different address — and obtains a freeze order.

Courts typically require that the defendant be notified of a lawsuit. But notifying the anonymous owner of a crypto wallet without knowing their physical address is impossible.

Rule 4(f)(3) of the Federal Rules of Civil Procedure permits "other means" of serving foreign defendants — at the court's discretion. In 2022, in LCX AG v. John Doe, a court for the first time authorized service via an NFT sent to the defendant's blockchain address.

In practice, this means: the defendant learns about the freeze only after it has occurred. A token arrives in their wallet — and this is considered proper notice. Meanwhile, they still have no access to the sealed case materials.

Signed into law by President Trump on July 18, 2025, this federal statute explicitly requires stablecoin issuers to maintain the technical capability to "seize, freeze, or burn" their tokens upon lawful demand — that is, pursuant to a court order specifying particular stablecoins and addresses.

Before GENIUS, freezing was a right of the issuer, stipulated in their terms of service. Now it is a statutory obligation.

And for those who need details — there’s a direct path to the firm’s email.

When the owner of a blocked wallet contacts Tether or Circle, they are redirected to walletinquiries@willkie.com. Sammis Law Firm shed light on what happens next. According to their information, Willkie Farr & Gallagher asks the inquiring party to answer nine questions:

Below the request is a disclaimer: "We represent only the plaintiffs in this matter. We are not your attorneys and cannot provide you with legal advice."

In this way, the firm compels you to provide KYC-level documentation, including your passport. Attorney-client privilege does not cover such materials — they are available to the plaintiff and can be forwarded to law enforcement.

What concerns the crypto community is not the mere involvement of a third party like Willkie Farr & Gallagher, but the unfairness of the system. The chosen scheme is convenient for stablecoin issuers, but freeze victims face a tough road. Here is how the situation looks from both sides:

For comparison: in a standard bank account seizure, the debtor receives notice and full access to case materials. They can challenge the measure within a few days. With stablecoin freezes through Willkie Farr & Gallagher, no such protections exist.

A comparison with English law underscores the imbalance between plaintiff and defendant. Mareva injunctions (the common-law equivalent of asset freezes) allow blocking assets worldwide, but only under three strict conditions:

The Willkie Farr & Gallagher team adopted the outcome — the asset freeze — without implementing any of the protective mechanisms.

There is also an important distinction from government confiscation: prosecutors are accountable to the Department of Justice and bound by strict standards. A private law firm operating in a sealed proceeding answers only to its client and the judge. Very convenient if you are a major stablecoin issuer concerned solely with protecting your own interests.

Willkie Farr & Gallagher has transformed into a private control center for stablecoins. Their advantage lies in their ability to exploit loopholes: circumventing bans on prejudgment asset freezes, sealing proceedings, and obtaining permission for service via NFT. The firm has effectively supplanted the state, performing its functions for commercial gain.

The crypto community has a chance to overcome the unfairness imposed by Willkie Farr & Gallagher. Here are three potential paths to resolution:

For now, none of these scenarios is working, and the inbox at walletinquiries@willkie.com continues to accept inquiries.

Track cryptocurrency movements through BitOK’s Graph. Even Willkie Farr & Gallagher’s shadow schemes can’t hide from the company’s tools.