Facts
The Swiss Confederation, the Canton of Ticino, and the Municipality of Muralto ordered three garnishment orders against X., domiciled in Monaco, for tax claims totaling more than 33 million Swiss francs. The garnishment orders targeted, in particular, the assets held by X. or the late Mrs. [Y.] with Bank [Z.] in St. Moritz. Bank [Z.] contested these garnishment orders to the extent that they covered assets of which X. and/or [Y.] were only the beneficial owners, but which formally belonged to third parties.Considerations
The Grisons Cantonal Court of Justice, as the supervisory authority in debt enforcement and bankruptcy matters, upheld Bank Z.'s appeal and lifted the execution of the garnishment orders to the extent that they covered assets held by third parties with Bank [Z.] in St. Moritz.
The Federal Tribunal dismissed the appeal of the Swiss Confederation, the Canton of Ticino, and the Municipality of Muralto. It considered that the garnishment orders were unenforceable to the extent that they did not mention the names of the third parties formally holding the debtor's…