Dormant means ownerless

In early August, some media outlets reported that a “revived investment bank, Salomon Brothers” intended to access bitcoin addresses it deems abandoned. The company used OP_RETURN, a standard mechanism for embedding arbitrary data in transactions.

The initiative’s stated aim is to shield funds from criminals and “rogue states”, with the legal basis said to be the doctrine of abandonment. We set out to discover who stands behind the Salomon Brothers brand and what precedent this poses for the industry.

The nub

In July, BitMEX Research flagged an oddity: dust transactions were sent to long-dormant bitcoin addresses (including 1Feex, with roughly 80,000 BTC stolen from Mt. Gox). The OP_RETURN field carried the message: “NOTICE TO OWNER: see www.salomon[]bros.[]com/owner_notice”.

There appears to be an ongoing Bitcoin scam occurring. Someone is sending old 2011 era Bitcoin addresses with balances, transactions with an OP_Return output. For instance the 1Feex… address, with c80,000 BTC stolen from MtGox. The OP_Return message is as follows

“NOTICE TO… pic.twitter.com/lAT5ONPD4f

— BitMEX Research (@BitMEXResearch) July 8, 2025

The link leads to a site under the storied Salomon Brothers brand. The notice states:

“This digital wallet appears to be lost or abandoned. Our client has entered into constructive possession of it and is attempting to determine whether it has a good-faith owner.” 

The owner is given 90 days to prove control. After October 10, 2025, a failure to respond “may be presented to a court” as evidence of renunciation. The notice says that, in such a case, “no person should intrude upon the digital wallet, infringe upon rights or attempt to extract any digital asset from the digital wallet”.

BitMEX argued that the legal basis is dubious. Analysts likened the scheme to a “Calvin Ayre-style legal scam” — an allusion to past attempts by Craig Wright and allies to claim Mt. Gox coins through the courts.

Later, according to CoinDesk, the authors of the notice clarified that the self-proclaimed Satoshi Nakamoto is not their client.

On what grounds?

The campaign’s chosen legal footing is the “doctrine of abandonment”. 

In the United States, for instance, unclaimed bank deposits or safe-deposit boxes pass to state control after several years (under laws based on the Uniform Unclaimed Property Act). If a client neither transacts nor responds to bank inquiries for a set period, or fails to pay a box’s rent, the contents are seized and held by the authorities. 

Similar rules apply to insurance payouts, dormant corporate assets and more. Timeframes vary by jurisdiction and asset type, from one to 15 years. Within that window, an owner must in some way assert rights — execute a transaction, update details or respond to a notice.

Crucially, initiators can contact the owner: name, address and contact details are known. These notices are filed so a court can be satisfied that the person had an opportunity to reclaim their property. Even after the state takes control, owners or heirs can usually recover assets — sometimes decades later. 

There is, however, a catch. In orthodox practice, the state or its delegated financial institution initiates such procedures. These entities are licensed, supervised and obliged to maintain ownership records. Does the group behind the “sleeping” bitcoin-address campaign meet those standards?

Which Salomon Brothers?

Salomon Brothers, an American investment bank, was founded in 1910 by clerk Ben Levy and brothers Arthur, Herbert and Percy Salomon. It started with just $5,000 and by the 1980s had become a Wall Street icon — in 1987 it finished the year as the country’s biggest underwriter and the world’s second largest. 

Tax-law changes and a bond slump dented its lead, and by 1988 it had ceded ground to Merrill Lynch. Three years later, Salomon Brothers was at the centre of a scandal. It had broken US Treasury auction rules: in a bid to buy more than permitted, the bank submitted false bids in the names of two clients. A Treasury probe uncovered other instances. 

The bank’s reputation and finances were battered — the Department of Justice and the Securities and Exchange Commission (SEC) ordered Salomon to pay $290m in fines. In 1997 it was bought by Travelers Group, which a year later merged with Citicorp to form Citigroup. Salomon Brothers effectively disappeared as an independent brand, its investment arm folded into Salomon Smith Barney. In the early 2000s Citigroup phased out the Salomon name; by 2003 it had vanished from Wall Street. As of 2020, Citigroup did not own the Salomon Brothers trademark. 

In February 2022, news broke of a brand revival and a new company, reportedly led by former executives and staff. Around the same time, without disclosing terms, reports emerged of a trademark purchase from a third party.

Beyond director R. Adam Smith, little is known about the management. The advisory board reportedly includes — or included — Chris Simpson, Terry Connelly and Tom Ostrander, all alumni of the original Salomon Brothers. It is unclear whether they still hold those roles.

The site’s legal disclaimers state that “references to Salomon Brothers on this website are historical, unless otherwise noted”. They also say Salomon Brothers Inc. is not regulated by the SEC or any supervisory agency — meaning it lacks the status and powers of a classic investment bank.

Securities business is conducted via a subsidiary registered with New York State’s Investor Protection Bureau as a broker-dealer. The site “does not offer the services of this affiliate and serves only as a notice that such services may be provided through a registered affiliate”. 

Leveraging the storied brand conveys continuity, but legally and operationally this is a different organisation, operating under a lighter regulatory regime. Accordingly, we will refrain from calling Salomon Brothers an “investment bank”. 

Neither public sources nor the wallet-owner notice indicate that the company using the Salomon Brothers brand has been appointed by any state or authority to run unclaimed-property procedures. As it is neither a bank nor a licensed custodian, and is not SEC-regulated as a broker-dealer, it has in effect self-appointed as a “steward” of supposedly ownerless coins. 

A splendid plan, Salomon

According to a press release from the company using the Salomon Brothers brand, “around 5% of digital wallets” are left by owners who lost their private keys. It cites the Wall Street Journal as saying “up to 20% of bitcoin and other digital assets” sit at those addresses, and dubs its initiative a “protection process”:

“Rogue states and criminal organisations with significant resources present a real threat to hacking assets stored in abandoned digital wallets.”

Yet in cryptocurrencies the notion of an “abandoned” or “ownerless” wallet is highly subjective. Years without transactions do not prove lost access: an owner may be holding long-term or for personal reasons.

To prove ownership the company suggests making a transaction or filling out a web form. Users must provide an email address and answer, among other things:

• whether you are an individual or represent a legal entity;
• where you live — which country/state;
• whether you, or the party you represent, have the private key.

Such collection of personal data — by a questionable outfit — is itself troubling. It also creates risks of leaks or misuse.

Another contentious point is the method of notice. As noted, the company using the Salomon Brothers brand relied on OP_RETURN to “notify” supposed owners of “abandoned” bitcoin addresses. 

Legally, this is unlikely to compare with official unclaimed-property notifications: receipt is unacknowledged, and owners are generally unidentifiable. Will a court accept such a record as proof of proper notice? And how do the campaign’s backers plan to access funds even if a wallet were declared ownerless?

Even with these caveats, there is a risk others may copy the practice, undermining a bedrock crypto principle: control rests with whoever holds the private key. Community concern is therefore understandable. 

Reaction and repercussions

This attempt to collar “whale” addresses unsettled industry participants. It may even have played into the July ‘awakenings’ of dormant wallets — owners could simply be hedging, since being tagged “potentially ownerless” at the very least invites unwanted attention.  

Naoris Protocol CEO David Carvalho linked the initiative to the risk of quantum hacks and added that some experts had earlier called this threat to cryptocurrencies overstated. 

Web3 researcher Vladimir Menaskop, speaking to ForkLog, said that trying to assert jurisdiction over an anonymous owner strikes at the core principles of decentralisation and anonymity. Any verification, he said, forces a user to unmask themselves. He also deemed OP_RETURN notices legally void. 

Ignat Likhunov, founder of the law agency Cartesius, told ForkLog that applying the doctrine to cryptocurrencies is problematic. Moreover, a wallet owner has no duty to be active. 

“Any attempt to deem such an address abandoned, rather than under long-term storage, is contestable,” Likhunov added.

Andrey Tugarin, founder of GMT Legal, agreed. Even if bitcoin is treated as property under US law, the key challenge is proving title — especially when obfuscation tools are used.

Both problems — how to prove abandonment, and how to assert jurisdiction over an anonymous owner — cast the initiative into doubt. According to Tugarin, ownership could conceivably be proven via a centralised platform where the user passed KYC. But the company using the Salomon Brothers brand targeted anonymous on-chain addresses.

Jurisdiction might theoretically be based on citizenship, but it is unclear who should do this and on what authority. Likhunov added that forced deanonymisation is a law-enforcement tool applied by court order during investigations. A private company’s attempt to unmask a wallet owner could itself be unlawful.

Experts are unanimous: an OP_RETURN notice has no legal force.

“Proper notice means delivery to the addressee by methods that record receipt. The blockchain is not an officially recognised system of electronic document exchange,” Likhunov explained.

Economist-libertarian Yevgeny Romanenko sees in Salomon Brothers’ actions an attempt to test the US court system and “apply the rules of the old world to the new”. Even if a court were to recognise the company’s right to the bitcoins, he argues, it would be a mere paper claim, as private keys would remain with the real owners.

On X, some users called the initiative an attempt to crack addresses via social engineering. 

Chat is this a legitimate notice or some elaborate social engineering / phishing attempt?https://t.co/Z1Dc6qX8Yb

Messages about proving ownership seem to have begun on 30th June asking for an “an on-chain transaction using private key by Sept 30”. Then on July 4th, there is a… pic.twitter.com/KxofFPZRnx

— CryptoNoddy (@Crypto_Noddy) July 4, 2025

Analyst @0xZilayo likewise suspected phishing. He noted that Salomon Brothers Inc. has not existed for over 25 years, and that for the past 15 years “a serial trademark cybersquatter has been active (or remains active), targeting a number of financial institutions”.

A brief investigation into the 80k BTC whale, and the “Salomon Bros” notices sent via OP_RETURN prior to the movements (TLDR at the bottom).

Salomon Bros was a HUGE investment bank with nearly a 100 year history before being acquired by Citibank in the early 2000s.

They revived… https://t.co/5htS17oTM0 pic.twitter.com/q5qz9j8amA

— Zilayo (@0xZilayo) July 7, 2025

“The most likely explanation for these messages is that someone purchased or hacked the Salomon Bros. domain (and its contents) from this cybersquatter and is now attempting to target wealthy clients’ crypto wallets.

Their site has pages for crypto-wallet recovery that are access-controlled and require authorisation, which only reinforces the impression that this is a phishing resource.

GoDaddy metadata left on the site uses the regional setting ‘en-IN’, indicating that the current site owner is likely in India,” the analyst noted.

The OP_RETURN notices from the outfit using the Salomon Brothers brand amount to an incursion into a zone the crypto community has long treated as sacrosanct. Repurposing a legal doctrine never designed for digital assets creates a risky precedent: anyone could declare someone else’s address ownerless. If a court embraces that logic, later interactions with funds on a “tagged” wallet could land the owner in litigation — and possession of contact details would ease attempts to wrest control.

If such practice goes unchallenged, the crypto community may face a fresh threat to the industry’s core principles.

Text: Alisa Ditz