A UK High Court has ruled that Chinese law, not English law, will determine whether alleged victims of a Chinese investment fraud have proprietary claims to more than 61,000 Bitcoin seized in London.
The October 12 judgment does not decide who ultimately receives the holdings. Instead, it sets the legal test the applicants must meet before the court can determine whether any of the Bitcoin, or property representing it, belongs to them under the UK’s civil-recovery regime.
Key Takeaways
- Chinese law will determine whether applicants have ownership rights in more than 61,000 seized BTC.
- The ruling resolves a preliminary legal question; it does not award the Bitcoin to victims or the UK state.
- Any final recovery, compensation or disposal decision will come only after the ownership claims are assessed.
The court decided the legal framework, not ownership
In Director of Public Prosecutions v Zhimin Qian & Anor [2026] EWHC 2509 (KB), Mr Justice Turner considered claims from people who say they lost money in investment schemes run in China between 2014 and 2017.
According to the judgment’s agreed factual background, the schemes were operated in China, the alleged victims were Chinese nationals living in China when they invested, and their payments were made through Chinese banks or in cash. Some of the proceeds were later converted into Bitcoin before Zhimin Qian left China in 2017.
London’s Metropolitan Police seized devices and keys linked to the Bitcoin in 2018. The assets now held within the UK proceedings include more than 61,000 BTC, which contemporaneous market reporting valued at roughly $5 billion.
The applicants asked the court to apply English law, or a combination of English and Chinese law, to support claims that they retained an interest in the Bitcoin. The Director of Public Prosecutions argued that Chinese law governed. The court agreed with the DPP.
Why Chinese law applies to the victims’ claims
The dispute was not about whether Bitcoin can be property under English law. The judgment says that point was not contested. The issue was which country’s law determines whether the alleged victims acquired or retained rights in the money that was later converted into Bitcoin.
Justice Turner found that the relevant connections were overwhelmingly Chinese: the alleged misrepresentations, investment arrangements, payments, parties and immediate losses were all centred there. The later movement of the Bitcoin and related assets into England did not change the law governing rights said to have arisen from the original transactions.
That matters because the applicants cannot rely simply on the fact that the Bitcoin is now within the jurisdiction of the English court. They must establish, under Chinese law, that they hold rights capable of satisfying the ownership requirement in Section 281 of the Proceeds of Crime Act.
Section 281 is not a general compensation scheme for every person harmed by criminal conduct. It allows a person to seek a declaration only where they can show that the property in question, or property it represents, belongs to them. A claim against the fraudsters for repayment alone is not enough.
What the ruling changes in the civil-recovery case
The judgment removes English law as the substantive basis for the applicants’ ownership arguments. English law will still govern the procedure through which the High Court considers those claims under the Proceeds of Crime Act, but the underlying proprietary rights must be assessed under Chinese law.
The court has not yet heard evidence on the content of Chinese law or the evidential basis of each individual claim. Those questions will determine whether any applicant can show that they retained a proprietary interest in the seized assets.
For that reason, the ruling does not settle the ultimate destination of the Bitcoin. A later stage must address the applicants’ rights before the court can decide what portion of the property, if any, falls outside the civil-recovery process.
Why seizure does not mean an immediate Bitcoin sale
The Metropolitan Police’s official announcement says Qian pleaded guilty in September 2025 to acquiring and possessing criminal property. The case also involves civil-recovery proceedings, which can continue separately from the criminal conviction.
Control of assets is only one stage of that process. The court must still resolve valid third-party claims before it can reach a final position on recovery and distribution. Only after that would any authority need to decide whether assets should be retained, used for compensation, or disposed of.
This distinction is especially relevant in crypto cases because the assets can remain under court control for years while ownership and tracing issues are litigated. As other crypto recovery cases have shown, seizure does not automatically produce a quick return of funds to victims.
Bitcoin’s price rise raises the stakes, but not the legal answer
The Bitcoin’s value has risen sharply since the underlying fraud and the 2018 seizure, making the ownership dispute far more significant in monetary terms. But a higher market value does not itself determine who has a proprietary claim to the holdings.
The next stage will turn on a narrower question: whether the applicants can prove that Chinese law gives them rights in the funds that were converted into Bitcoin, and whether those rights can support declarations under Section 281.
Until that question is resolved, the more than 61,000 BTC should be viewed as disputed assets within an ongoing legal process—not as confirmed government-owned Bitcoin awaiting sale.
What happens next
- Chinese law must be pleaded and proved: The court has said that evidence on its content has not yet been presented.
- Individual claims must be assessed: Applicants will need to establish the factual and legal basis for their asserted property rights.
- The court must determine the effect on civil recovery: That will decide whether any property is excluded from recovery because it belongs to an applicant.
- A later order would be needed for any allocation or disposal: The October 12 ruling does not make that decision.
The 61,000 BTC remain subject to unresolved claims
The High Court has answered an important preliminary question: claims to the seized Bitcoin will be assessed under Chinese law. It has not determined whether the applicants own any of the holdings, how much may be recoverable by the state, or what should eventually happen to the Bitcoin.
Those later findings, not the choice-of-law ruling alone, will determine whether the assets are returned, excluded from recovery or eventually disposed of.
This article is provided for informational purposes only and does not constitute legal, financial or investment advice. The proceedings remain ongoing, and later rulings may affect the outcome.
Alex is Editor-in-Chief of Coindoo and co-founder of Millennial Media Group, with nearly a decade of experience covering financial markets – crypto first, then everything else.
It started in 2016 with Bitcoin. Like most people at the time, he didn’t fully understand it – so he kept digging. Blockchain, tokenomics, the projects, the cycles. That curiosity never stopped, and eventually pulled him into traditional markets too: equities, commodities, macro. Not because he left crypto behind, but because you can’t properly understand one without the other.
What drives him is straightforward: he wants to know why something is happening, not just that it’s happening. Most market coverage stops at the headline – price up, price down, here’s a chart. Alex finds that kind of reporting actively unhelpful. If you walk away from an article without understanding the mechanism behind the move, what did you actually learn?
He holds a degree in Tourism from New Bulgarian University – not the most obvious path into financial markets, but markets have a way of pulling in people who are simply too curious to stay out. He has authored over 200 in-depth analyses and more than 10,000 articles across crypto and traditional finance. He still thinks every day in markets teaches him something new. That’s probably why he hasn’t stopped.
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