Mintlayer Legal Record: Alberto De Luigi and Andreas Kohl Allegations

Executive summary

• The parties. RBB S.R.L. is the San Marino company that develops Mintlayer; it was founded by Enrico Rubboli in May 2019. The 2022 allegations were made by two former external collaborators: Alberto De Luigi, a copywriting and documentation contractor at HTLC Consulting FZC LLC, and Andreas Kohl, a former business developer.
• The allegations (2022). Alberto De Luigi alleged that he was the true inventor of Mintlayer and that investor funds had been misappropriated, and filed criminal complaints alleging fraud, criminal mismanagement, irregular token issuance and money laundering. RBB S.R.L. disputes all of these allegations.
• San Marino criminal outcome. The San Marino Commissarial Court dismissed and archived all criminal complaints on 28 November 2023 (case numbers 427/2022, 447/2022, 520/2022, 559/2022, 691/2022 R.N.R., presiding commissioner Roberto Battaglino). No criminal conduct was found.
• Italian criminal outcome. The Public Prosecutor’s Office at the Court of Ravenna dismissed and archived the same complaints on 30 January 2024 (case number 3350/22 R.G.N.R., dott.ssa Silvia Ziniti).
• Domain arbitration (2022). A UDRP panel accepted RBB S.r.l.’s complaint over mintlayerfoundation.org: the panel found that Alberto De Luigi had no rights or legitimate interests in the domain, that it was registered and used in bad faith, and it ordered the domain transferred to RBB S.r.l. (Case No. 104604, 27 June 2022).
• Andjelic civil judgment (2026). Stefan Andjelic, a SAFT holder, sued RBB S.r.l. alleging fraudulent inducement, missing token-issuance authorization, misuse of funds, roadmap and team changes, and unfair contractual clauses. On 22 June 2026 the San Marino Tribunal rejected all claims. The court did not find evidence of fraud at contract formation, held that the SAFT was a high-risk contract over future assets, and noted that the tokens were ultimately delivered. Each party bears its own costs.
• Andreas Kohl. According to RBB S.R.L.’s records, Kohl demanded a multi-million-dollar payout after his departure and, with De Luigi, publicly threatened a class action. No class action was ever filed.
• Allegation versus established fact. The 2022 statements are allegations, disputed by RBB S.R.L. and not upheld in the proceedings they produced. What courts and the arbitration panel have documented is limited to the outcomes listed above; this page keeps that distinction explicit throughout.

Mintlayer legal proceedings and outcomes

Four proceedings are documented on this page: the San Marino criminal complaints, the parallel Italian criminal proceedings, a UDRP domain arbitration, and the Andjelic civil action. Their jurisdictions, case identifiers, dates, and outcomes follow. This page uses the terminology of the decisions themselves: criminal complaints were dismissed and archived, the civil claims were rejected, and the domain complaint was accepted.

San Marino criminal proceedings

The criminal complaints filed by Alberto De Luigi against Enrico Rubboli and RBB S.R.L. were dismissed and archived by the San Marino Commissarial Court on 28 November 2023, after a full investigation, with no criminal conduct found.

Italian criminal proceedings

The same criminal complaints, filed independently in Italy, were dismissed and archived by the Public Prosecutor’s Office at the Court of Ravenna on 30 January 2024. A second independent authority in a second jurisdiction therefore reached the same conclusion as the San Marino court: no criminal conduct was found.

Mintlayerfoundation.org domain arbitration

Separately from the criminal proceedings, a UDRP arbitration before the On-line ADR Center of the Czech Arbitration Court ruled against Alberto De Luigi in relation to mintlayerfoundation.org, a domain he had registered without authorization. The panel accepted RBB S.r.l.’s complaint in full and ordered the domain transferred.

The chat record further shows the disputed domain in active use as the campaign’s collection address: on 13 June 2022, De Luigi instructed SAFT holders to send their SAFT documentation to [email protected] (msg #1155), and Kohl’s 15 June 2022 announcement to SAFT holders confirms emails were sent from that address (msg #1215; published excerpts).

Stefan Andjelic civil case

Separately from the De Luigi and Kohl matters, a SAFT holder, Stefan Andjelic, brought a civil action against RBB S.r.l. seeking to undo his SAFT and recover his payment. The action was filed on 9 February 2023, roughly a year into the public campaign against Mintlayer waged from 2022 by Alberto De Luigi and Andreas Kohl. Andjelic’s connection to the campaigners appears on the face of his own pleading, which records that his first contact with the project, on 30 March 2021, came through team members including Andreas Kohl. The Tribunal rejected his claims in full on 22 June 2026.

What the plaintiff alleged:

• that RBB S.r.l. obtained his consent to the SAFT of 1 April 2021 through fraud, warranting nullity and repayment of USD 20,000;
• that RBB lacked token-issuance authorization when the SAFT was signed;
• that funds raised were misused or diverted, including through a real estate subsidiary, a property, a vehicle and other corporate interests;
• that the project roadmap was not followed and the presented team was replaced;
• that Articles 4.4, 9.2, 9.3 and 11.1 of the SAFT were manifestly unfair.

What the court concluded:

• the SAFT is an atypical contract over future assets carrying inherent entrepreneurial and regulatory risk; failure to meet roadmap projections, delays, team changes and regulatory setbacks do not in themselves evidence fraud;
• the burden of proving fraudulent misrepresentation at contract formation rested on the plaintiff and was not discharged; the court did not find evidence that RBB obtained Andjelic’s consent through fraud;
• the court considered the authorization issue but did not conclude that the absence of authorization on the date of the SAFT made the contract void;
• the court considered the use-of-funds allegations, which were partly documented and admitted, but did not find evidence that RBB had, at the time of contracting, planned to divert the funds for purposes radically incompatible with the project presented;
• the contested clauses were upheld as typical risk-allocation clauses in a knowingly speculative transaction to which consumer-protection reasoning did not apply;
• uncontradicted expert evidence established that the tokens were delivered, albeit later than planned, and subsequently increased in value;
• all claims were rejected, and the court ordered full compensation of litigation costs between the parties, meaning each side bears its own costs.

What this does and does not establish: the SAFT remains valid as between the parties, and the fraud allegations were rejected to the civil standard of proof. The judgment is specific to this SAFT and this plaintiff: it did not concern Alberto De Luigi, it does not adjudicate the criminal complaints, and it does not certify that every pre-contractual projection was accurate. The court expressly documented delays, organizational changes and regulatory difficulties, treating them as inherent risk rather than fraud.

RBB S.r.l. further states, on the basis of documentary evidence in its legal file, that Andjelic had been promised Sequentia tokens, the venture De Luigi and Kohl went on to launch, in exchange for pursuing the action against the company. The broader scheme, in which SEQ-token allocations were conditioned on refund requests and participation in the lawsuit, is documented in a Telegram group of SAFT holders (published excerpts); the claim relating to Andjelic specifically is supported by evidence retained by the company and was not addressed in the Tribunal’s judgment. The campaign’s legal logistics were organized through a San Marino law firm: in the group, on 28 May 2022, Kohl stated that the office of the president of the San Marino Bar Association “has agreed to assist the Mintlayer community” (msg #673; firm name withheld from publication), and the judgment in Case No. 31 of 2023 records Andjelic as electively domiciled, for those proceedings, at the offices of that same firm.

Chronology of the Mintlayer legal dispute

Dates and case identifiers are taken from the court records and company documents referenced in Primary sources and court documents.

Who is Alberto De Luigi?

Alberto De Luigi is an Italian blogger and influencer who worked on Mintlayer-related materials from October 2021 to March 2022. Prior to that, he worked full-time at Accenture. He was employed by HTLC Consulting FZC LLC, an Emirates-registered company that held a services contract with RBB S.R.L. relating to the development of Mintlayer; his work for the project was limited to copywriting and documentation, a capacity in which he had previously written whitepapers for other projects. He held no technical or engineering role. He was never a co-founder, shareholder, director, or employee of RBB S.R.L.

Following his removal in March 2022, De Luigi became the principal source of the public allegations described on this page. His claims of authorship and fund misuse were examined in criminal proceedings in San Marino and Italy, both of which were dismissed and archived (see Legal proceedings and outcomes).

Who is Andreas Kohl?

Andreas Kohl is a former business developer who collaborated with the Mintlayer project through his own company, rather than as an employee of RBB S.R.L. According to the company’s records, after his departure Kohl sent a message to Luca Viviani demanding a multi-million-dollar payout, warning that otherwise he would “end up being a problem for you sooner or later”. The message is published in full, unedited (bold added for emphasis). It asks for “at least a break and a couple million dollars to invest in myself”, describes a path of “self-destruction, intoxication, loss of self-control, and ultimately vengeance”, and states that this “would eventually become a serious liability for you. It’s not even a threat, just logic”. Kohl was removed from the project and the matter was reported to the authorities. He subsequently joined De Luigi in publicly threatening a class action against Mintlayer and RBB S.R.L. No class action has ever been filed, and RBB S.R.L. is not aware of any court proceedings initiated by Kohl.

De Luigi and Kohl went on to launch Sequentia (sequentia.io), a project self-described as “a Bitcoin sidechain network dedicated to tokenized assets such as stablecoins and stock tokens”. On 15 June 2022, in a Telegram group of SAFT holders, Kohl announced “Mintlayer is rebranded to Sequentia” and stated that holders must both request a refund from RBB and join the lawsuit to be eligible for SEQ tokens (published excerpts). RBB S.r.l. has further stated, citing the chat record and other documentary evidence in its possession, that Stefan Andjelic was promised Sequentia tokens in exchange for his lawsuit against the company. In RBB S.r.l.’s assessment, Sequentia is de-facto an attempt to copy Mintlayer, replicating the Bitcoin-sidechain, token-issuance concept Mintlayer has developed and published since 2019.

What was alleged against Mintlayer?

The following allegations were made publicly by Alberto De Luigi, and, in the case of the class-action threat, jointly with Andreas Kohl, from 2022 onward, in public posts and articles and in criminal complaints filed in San Marino and Italy. They are set out here for transparency and completeness. Each item is an allegation by a private individual; each was examined by the authorities identified below; and each is disputed by RBB S.R.L.

Mintlayer authorship allegations

Allegation: Alberto De Luigi claimed to be the “true inventor” of Mintlayer and asserted authorship and ownership of the project. Source: De Luigi’s public posts and articles, 2022; repeated in his criminal complaints. RBB S.R.L.’s response: Mintlayer was conceived by Enrico Rubboli, whose business plan was filed with San Marino Innovation upon RBB S.R.L.’s incorporation on 16 May 2019, more than two years before De Luigi joined HTLC Consulting; De Luigi held a copywriting-only engagement; all intellectual property is solely owned by RBB S.R.L. Outcome: the San Marino Commissarial Court found no legal basis for the authorship or ownership claim in its ruling of 28 November 2023 (see above).

Investor fund allegations

Context: on 24 May 2021, Mintlayer announced a $5.2 million seed funding round to develop the protocol, with Alphabit, Moonwhale, 4SV, X21 and Iconomy Partners joining as advisors alongside other digital-asset investment firms. Development was carried out by RBB S.R.L., then operating as RBB Lab. This was Mintlayer’s principal publicly announced funding round, and the “investor funds” referenced in the allegations concern the project’s funding generally. For current tokenomics, see ML Coin; for company history, see About Mintlayer.

Allegation: that investor funds were misused through Enrico Rubboli’s acquisition of a property in San Marino and of a vehicle, presented as evidence of fund misappropriation and personal enrichment. Source: De Luigi’s 2022 public posts and criminal complaints. RBB S.R.L.’s response: the property purchase was a condition of residency required by San Marino authorities, was made by a real estate subsidiary of RBB S.R.L., was leased back at fair market rate, and was registered publicly; the vehicle was purchased with company revenues and registered as a company asset. Outcome: the San Marino court found both to be legitimate business expenses paid with funds from business activities, not misappropriation; the use-of-funds allegations were also examined and rejected in the Andjelic civil case (see above).

Fraud and money laundering allegations

Allegation: that the Mintlayer project was fraudulent, that company funds were criminally mismanaged, and that the project involved money laundering. Source: De Luigi’s criminal complaints in San Marino and Italy, and his public posts. RBB S.R.L.’s response: the company placed its full factual record before the authorities in both jurisdictions and denied any fraud or mismanagement. Outcome: the San Marino court found no fraudulent intent behind the Mintlayer project, no criminal elements in the management of company funds, and identified no money-laundering concerns; the Ravenna Public Prosecutor’s Office likewise dismissed and archived the same complaints (see above).

Token issuance and regulatory allegations

Allegation: that token issuance was irregular, that delays evidenced misconduct, and that the project lacked required regulatory authorizations. Source: De Luigi’s criminal complaints, and the Andjelic civil pleading which argued that RBB lacked token-issuance authorization when the SAFT was signed. RBB S.R.L.’s response: token issuance followed the applicable process, with delays attributable to administrative and regulatory factors; the authorization timeline is a matter of judicial record. Outcome: the San Marino court found that token issuance occurred regularly; in the Andjelic civil case, the Tribunal considered the authorization issue but did not conclude that the absence of authorization on the date of the SAFT made the contract void (see above).

Class action allegations

What was threatened: a class action against Mintlayer and RBB S.R.L., publicly threatened by Alberto De Luigi and Andreas Kohl from 2022. Status: no class action was ever initiated. The proceedings that were actually filed, the criminal complaints in San Marino and Italy, were dismissed and archived in 2023 and 2024.

De Luigi’s and Kohl’s original publications are third-party content outside Mintlayer’s control. They are identified, not removed, in Primary sources and court documents, so that researchers can consult the allegations alongside the company’s response and the judicial outcomes.

Mintlayer and RBB S.R.L.’s response

Yes. RBB S.R.L. and Enrico Rubboli dispute all of the allegations. The company responded in writing at the time, placed its full factual record before the authorities in both jurisdictions, and publishes the underlying facts on this page. Where a court or arbitration panel has since addressed an allegation, the outcome is linked rather than repeated.

The authorship claim

Mintlayer was conceived and developed by Enrico Rubboli. The business plan was submitted to San Marino Innovation immediately upon RBB S.R.L.’s incorporation on 16 May 2019. De Luigi first became involved through HTLC Consulting in October 2021, in a copywriting and documentation capacity, with no technical background or engineering role. He was never a co-founder, shareholder, or director of RBB S.R.L., and never held an employment contract or equity stake in the company; he was offered a direct role at RBB S.R.L. and declined it. All intellectual property of the Mintlayer project is the sole property of RBB S.R.L. Outcome: the San Marino court found no legal basis for the authorship claim (San Marino criminal proceedings).

The circumstances of the removal

De Luigi was removed for cause, not to suppress him. RBB S.R.L. sent a formal letter to HTLC Consulting on 25 February 2022 citing: repeated interference with technical decisions made by qualified senior engineers (including a CTO with a PhD in Cryptography from Cambridge and a Development Lead with a PhD in Physics from ETH Zurich); failure to deliver assigned tasks, including a Token Generation Event task with a critical deadline; and the commissioning and attempted publication of technically incorrect articles over the explicit objection of the lead engineering team, damaging the project’s reputation and industry relationships. De Luigi’s access was revoked on 7 March 2022. The San Marino court reviewed this record and made no adverse findings against RBB S.R.L. or Enrico Rubboli in relation to the removal.

The fund-management allegations

The property acquisition at the centre of the accusations was a legitimate business investment: San Marino authorities required Enrico Rubboli to purchase real estate and commit to employing a minimum number of people in San Marino as a condition of obtaining residency, which was necessary to manage the company he had founded there. The property was acquired by a real estate subsidiary of RBB S.R.L., leased back to Rubboli at fair market rate, and registered publicly in full. The vehicle acquisition was made using company revenues and registered as a company asset. Outcome: the court found both to be legitimate business expenses paid with funds from business activities, not misappropriation, and found no fraudulent intent, no criminal elements in fund management, and no money-laundering concerns (San Marino criminal proceedings).

Independent accounting due diligence (December 2022)

Separately from the proceedings, RBB S.r.l. also commissioned an independent examination of its own books: on 6 October 2022 the company engaged Dott. Stefano Giulianelli, commercialista e revisore contabile (San Marino, Albo No. 118), to carry out an accounting due diligence of the company’s records from incorporation (16 May 2019) to 31 August 2022. His report of 1 December 2022 (redacted public copy) concluded that the 2019, 2020 and 2021 financial statements and the interim accounts at 31 August 2022 were substantially compliant with the applicable civil and tax rules and drawn up under correct accounting principles, and recorded no findings in any area examined.

The matters examined include those at the centre of the public allegations. All purchase invoices and depreciation computations for fixed assets were verified, including a vehicle purchased and registered as a company asset. The report documents that the San Marino property was acquired by AGI S.r.l., a wholly-owned RBB subsidiary, funded by a shareholder loan of EUR 900,000; that the property, together with an employment plan, constituted a necessary condition for Enrico Rubboli’s San Marino residency; and that the registered lease of the property to Mr. Rubboli falls within the market range for comparable units, as assessed by the reviewer. Token-sale proceeds were carried as client advances, i.e. as liabilities of the company; client wallet deposits were held off balance-sheet and, following anti-money-laundering verification of the sums received — conducted by an external specialized firm under the company’s AML policy — were brought onto the company’s balance sheet in full by 31 August 2022. The file includes certifications of the absence of tax liabilities (18 November 2022), of regular social-security contributions (11 July 2022) and of no pending tax-collection proceedings (28 June 2022), with clear certificates as to protests, civil cases, pending charges and criminal records. The report also documents the token-authorization timeline — the renewal application of 2 June 2022, San Marino Innovation’s reply of 20 July 2022 requesting a new application without stated reasons, and the re-filing of 22 July 2022 — and records that the project remained technically unchanged, the delay being of the kind explicitly contemplated by the SAFTs.

Per the report itself, the engagement was a due-diligence review of the accounting records; it was not a statutory audit (revisione contabile) or a business valuation. The published copy is redacted (client, counterparty, custody and banking details; forward-looking assessments) and omits the annexed financial statements, which are retained in the company’s legal file. The document is in Italian; the original prevails.

The Andreas Kohl payout demand

Following his departure, Kohl sent a message to Luca Viviani demanding a multi-million-dollar payout, warning that otherwise he would “end up being a problem for you sooner or later”. The company treated this as unacceptable, removed Kohl, and reported the matter to the authorities (see Who is Andreas Kohl?).

Corporate standing and compliance

RBB S.r.l. was certified as a Level 1 Technological Start-Up under Delegated Decree No. 101/2019 and obtained recognition under San Marino’s blockchain-entity framework under Delegated Decree No. 86/2019. Its token-issuance authorization timeline, application of 9 April 2021, initial authorization of 27 July 2021, and the later proceedings recorded in Case No. 31 of 2023, is a matter of judicial record. For the corporate and technical record, see About Mintlayer, ML Coin, and the official Mintlayer documentation.

Current status of the Mintlayer legal dispute

As of June 2026, the publicly documented proceedings described on this page include the dismissed and archived criminal proceedings, the 2022 domain arbitration decision, and the June 2026 San Marino civil judgment in Andjelic v. RBB S.r.l., in which the civil court rejected Andjelic’s claims against RBB S.r.l.

Specifically: the mintlayerfoundation.org domain was transferred to RBB S.r.l. under the UDRP decision of 27 June 2022 (Case No. 104604); both sets of criminal complaints were dismissed and archived (San Marino, 28 November 2023; Ravenna, 30 January 2024); the civil SAFT action was rejected in full (San Marino Tribunal, 22 June 2026), with each party bearing its own costs; in a separate transaction in 2025, Enrico Rubboli bought from RBB S.r.l. the real estate subsidiary holding the San Marino property, using his own funds, so the company no longer holds the asset referenced in the fund-use allegations; and, as of September 2026, RBB S.r.l. has no outstanding legal proceedings related to the matters described on this page, per its records. The underlying public allegations have not been withdrawn by the individuals who made them, and RBB S.R.L. continues to dispute them. This section describes the legal record as documented above and in the company’s records; it does not constitute an exhaustive statement of every possible proceeding. This page will be updated if the legal position changes.

Primary sources and court documents

Every material assertion on this page rests on the sources below, listed in order of authority.

Court judgments and prosecutorial records

• San Marino Commissarial Court ruling dated 28 November 2023, case numbers 427/2022, 447/2022, 520/2022, 559/2022, 691/2022 R.N.R., presiding commissioner Roberto Battaglino. Findings summarized on this page; certified copies are obtainable from the San Marino judicial registry.
• Dismissal and archiving by the Public Prosecutor’s Office at the Court of Ravenna dated 30 January 2024, case number 3350/22 R.G.N.R., dott.ssa Silvia Ziniti; obtainable from the Ravenna prosecutor’s registry.
• San Marino Tribunal judgment dated 22 June 2026, Civil Case No. 31 of 2023 (Stefan Andjelic v. RBB S.r.l.), Commissioner of Law Giovanni Belluzzi: claims rejected in full; obtainable from the San Marino judicial registry.

Domain arbitration decision

• UDRP Panel Decision, On-line ADR Center of the Czech Arbitration Court (CAC), Case No. 104604, mintlayerfoundation.org: filed 25 May 2022, decided 27 June 2022 by panelist Dr. Fabrizio Bedarida; complainant RBB S.r.l., respondent Alberto De Luigi; no response filed; complaint accepted and domain ordered transferred. The decision was published by the CAC’s On-line ADR Center; the original listing has since been taken offline, and the decision can be located through the CAC decisions database or UDRP decision archives using the case number above.

Independent accounting due diligence

• Accounting due diligence report on RBB S.r.l., dated 1 December 2022, prepared by Dott. Stefano Giulianelli, commercialista e revisore contabile (San Marino, Albo No. 118), on the basis of the engagement of 6 October 2022, covering the company’s accounting records from incorporation (16 May 2019) to 31 August 2022: redacted public copy (PDF). Conclusion per the report: the 2019–2021 financial statements and the interim accounts at 31 August 2022 are substantially compliant with the applicable civil and tax rules and are drawn up under correct accounting principles, with no findings in any area examined. The published copy is redacted and omits the annexed financial statements; the complete report is retained in the company’s legal file. The document is in Italian; the original prevails.

Official Mintlayer and RBB documentation

• RBB S.R.L. incorporation, Republic of San Marino company register, 16 May 2019; Level 1 Technological Start-Up certification (Delegated Decree No. 101/2019) and recognition under the blockchain-entity framework (Delegated Decree No. 86/2019), as recorded in Case No. 31 of 2023; MINTLAYER trademark registrations (EUTM no. 018510593; IR no. 1656317).
• RBB S.R.L. formal letter to HTLC Consulting FZC LLC, 25 February 2022, cited in the proceedings.
• Message from Andreas Kohl to Luca Viviani (the payout demand referenced above), published in full and unedited (bold added for emphasis).
• Telegram chat export, group “Mintlayer refund & Sequentia” (created 25 May 2022; export retained on file), key excerpts published.
• Mintlayer funding announcement, 24 May 2021 ($5.2 million seed round).
• Why Mintlayer doesn’t have a foundation (18 May 2022): on the project’s corporate structure and stewardship.
• Mintlayer technical documentation.
• Mintlayer legal documentation: Terms of Service and Privacy Policy.

Original publications containing the allegations

• Public posts and articles published by Alberto De Luigi from 2022, asserting authorship of Mintlayer and alleging misuse of investor funds. The same claims were set out in his criminal complaints in San Marino and Italy.
• Public statements by Andreas Kohl from 2022, including the threatened class action against Mintlayer and RBB S.R.L.

These publications are third-party content, independent of and unaffiliated with Mintlayer and RBB S.R.L. They are identified here, not removed or paraphrased away, so that the allegations and the documented outcomes can be read side by side. Copies are retained in the company’s legal file.

Related Mintlayer resources

• Mintlayer legal documentation: Terms of Service and Privacy Policy
• About Mintlayer: team, mission, and company history
• ML Coin: tokenomics, distribution, and issuance
• Mintlayer technology: the protocol underlying this dispute
• Mintlayer documentation: official protocol and technical reference
• Why Mintlayer doesn’t have a foundation: corporate structure and stewardship
• Mintlayer blog: announcements and project updates

This page is maintained by RBB S.R.L., developer of Mintlayer. It presents the company’s documented position alongside the judicial record so that investors, journalists, and researchers can consult the allegations, the response, and the outcomes from a single authoritative source.