Questione giuridica chiave
Whether the appeal against the Federal Criminal Court decision on the account freeze was admissible
Decisione estratta
The appeal was admissible because the measure was a coercive measure under the SGG/VStrR framework and the applicant was entitled to challenge it as account holder.
Motivazione estratta
Bank freezes and confiscation-like seizures in special tax investigations qualify as coercive measures; the appellant suffered a legally relevant disadvantage and filed within time.