Halcyon investors keep asking the same question in their groups and forums: where did the money go, and can anyone reach it? Reports circulate of villas in Saint Lucia, property in Montenegro, a Halcyon-branded development in Florida. Investors fear that, whatever happens in France, the money sits beyond the reach of any court.
That fear is understandable. It is not the end of the story. A French criminal investigation does not stop at the border, and the Bordeaux investigation into Halcyon is conducted by the part of the French justice system built precisely for cross-border financial crime.
This article explains what the French judge can seize, where, through which channels, and who gets paid from the proceeds. One rule dominates everything else: only investors who are civil parties in the French criminal case can ask to be paid from confiscated assets through the French asset recovery agency.
Can the French judge seize Halcyon assets outside France? The short answer
Yes, a French investigating judge can order the seizure of assets wherever they are located, including property held abroad or in another person’s name (arts 706-141 et seq. French Code of Criminal Procedure). Within the European Union, the order is recognised and executed by the other state (Regulation (EU) 2018/1805). Elsewhere, it is executed through mutual legal assistance. After a conviction, civil parties can ask to be paid in priority from those assets (art. 706-164 French Code of Criminal Procedure).
Who is investigating Halcyon, and why that matters
The Halcyon investigation is conducted in Bordeaux by a JIRS (juridiction interrégionale spécialisée), one of the French courts dedicated to organised crime and complex financial crime (art. 706-75 French Code of Criminal Procedure). The offences under investigation are organised fraud and money laundering.
This matters for two reasons. A JIRS handles cases that are complex because of their scale or their international dimension. And the offences investigated carry the widest confiscation powers of French criminal law.
The cooperation has already been visible. The Château de la Cazine was searched in March 2025 with the assistance of Europol. Robin Barrasford was arrested in Spain in May 2026, and France requested his surrender (Insolvency & Law, timeline published on 15 May 2026). He was then placed under formal investigation (mis en examen) in France, according to reports published in July 2026 (National Fraud Helpline, Halcyon Retreat update, 27 July 2026). He is presumed innocent, as is every person concerned, until a court rules otherwise.
A common mistake is to translate mis en examen as « charged » or « indicted ». It is a step of the French judicial investigation, taken where there is serious or corroborating evidence of possible involvement (art. 80-1 French Code of Criminal Procedure). It is neither a conviction nor a decision to send the person to trial. Another common mistake is to date the arrest to April 2026: the reports available place it in May 2026.
A French criminal investigation is not confined to France. The judge in Bordeaux can follow the money wherever it went.
What French criminal law allows the judge to take
Seizure during the investigation
During the investigation, the judge can order the seizure of any asset that could later be confiscated (arts 706-141 et seq. French Code of Criminal Procedure). The difference between the two measures is explained, in French, in an article on saisie pénale et confiscation. This includes real estate, bank accounts, shares and receivables. The seizure can target assets registered in the name of a third party when the suspect has free disposal of them (art. 131-21 French Criminal Code).
The seizure can also be made « by value » (saisie en valeur): when the proceeds of the offence cannot be found, the judge can seize other assets of equivalent value (art. 706-141-1 French Code of Criminal Procedure). The money does not need to be traced euro by euro into a specific villa.
Confiscation after conviction
For money laundering, French law allows confiscation of all or part of the convicted person’s assets, whatever their nature and wherever they come from (art. 324-7 French Criminal Code). Confiscation by value is also available when the proceeds themselves have disappeared (art. 131-21 French Criminal Code).
This is the broadest form of confiscation in French law. It does not require proof that a given property was bought with investors’ money. It targets the wealth of the person convicted. Its limits are discussed, in French, in an article on how far confiscation of the proceeds of an offence can go.
How a French seizure is enforced abroad
Within the European Union
Since 19 December 2020, a French freezing or confiscation order is recognised and executed directly by the other member states, using a standard certificate (Regulation (EU) 2018/1805 of 14 November 2018). Spain and Greece are member states. The other country’s authorities execute the order and may refuse only on the limited grounds listed by the Regulation (arts 8 and 19); they do not re-examine the French case.
In the United Kingdom
Since Brexit, freezing and confiscation between France and the United Kingdom are governed by the EU-UK Trade and Cooperation Agreement of 30 December 2020, which contains a dedicated title on freezing and confiscation. The British authorities remain able to execute French requests.
Elsewhere in the world
Outside Europe, execution rests on mutual legal assistance: bilateral treaties and multilateral conventions. The main one is the United Nations Convention against Transnational Organized Crime of 15 November 2000, whose articles 12 and 13 require states parties to cooperate in identifying, freezing and confiscating proceeds of crime. France and the United States are both parties.
The honest limit is this: outside the European Union, enforcement depends on the cooperation of the country concerned and takes time. A French request to a Caribbean island is never as fast as a French order executed in Spain.
What the reports on overseas assets are worth
In investor groups, reports circulate of a villa in Saint Lucia and properties in Montenegro. A Halcyon-branded fractional ownership project in Kissimmee, Florida, « Halcyon Palms », is documented in public sources (Insolvency & Law, timeline published on 15 May 2026). None of these reports has been confirmed by a court, and the ownership of each asset remains to be established.
This is where investors can play a real role. Information about assets abroad (addresses, company names, estate agents, dates) is useful to the investigation. Given through a lawyer to the investigating judge, it can support a request for an asset investigation.
Why civil-party status decides who gets paid
Only civil parties are paid from confiscated assets
Once a criminal judgment has become final, a civil party who was awarded damages and has not been paid has a specific remedy. It can ask the French asset recovery agency, the AGRASC, to pay it in priority from the confiscated assets of the person convicted (art. 706-164 French Code of Criminal Procedure). The request must be made within six months of the decision becoming final, instead of two months before Law No. 2024-582 of 24 June 2024. The same law extended the mechanism to seized assets transferred to the State, even without a confiscation order.
An investor who is not a civil party has no access to this mechanism. A proof of claim in the liquidation of SAS Halcyon Retreat does not give access to it either: the liquidation covers the company’s assets, while confiscation targets the assets of the persons convicted.
The liquidation deals with what is left in the company. The criminal case deals with what the people behind it kept.
A civil party can act during the investigation
A civil party is not a spectator. Through a lawyer, a civil party can consult the case file and ask the investigating judge to carry out any step it considers useful to establish the truth (art. 82-1 French Code of Criminal Procedure). That includes asking for asset investigations abroad, supported by the information investors have gathered. The judge decides, but must give a reasoned order within one month if the request is refused (art. 82-1 French Code of Criminal Procedure).
Joining the existing investigation takes a filing with the investigating judge (art. 87 French Code of Criminal Procedure); the steps are set out, in French, in an article on how to become a civil party. An investor living abroad must give an address in France, usually the office of their French lawyer (art. 89 French Code of Criminal Procedure).
Timing
Civil-party status can be obtained at any point until the investigation is closed, but the investor who joins early has more influence on its course. The investor who joins late may find the requests for asset tracing already made, or never made.
What to do now
- File as a civil party in the Bordeaux investigation. This is the only way to be paid from confiscated assets, and the only way to influence the search for them.
- Gather what you know about assets abroad and pass it on through your lawyer, never through social media, where it alerts the people concerned.
- File your proof of claim in the liquidation of SAS Halcyon Retreat by 9 November 2026 if you live outside metropolitan France. The two routes are complementary, not alternative. If the deadline has passed, see the article on relief from forfeiture in the Halcyon liquidation.
- Keep every document: contracts, proof of payment, emails, investor updates, promises of repayment.
How the English and French routes fit together is set out in a dedicated article on Halcyon claims in England and in France. The French proceedings themselves are set out in a separate guide.
Invested in the Halcyon Retreat resort in France? Where your claim really stands
The mechanism of payment by the AGRASC is explained in detail, in French, in a dedicated article: paiement des dommages-intérêts par l’AGRASC sur les biens confisqués.
Your case, not the general rule
Whether assets can be reached, and whether you will be paid from them, depends on facts no general article can settle: which person you are claiming against, what is known about the assets, and where the investigation stands. The facts count as much as the law, and that is where a lawyer’s work begins.
Valentin Simonnet is a member of the Paris Bar (avocat au Barreau de Paris). He practises in business litigation and white-collar criminal defence.
