UK court applies Chinese law to 61,000 seized bitcoin as Beijing files its own claim

The High Court in London ruled on 12 October 2026 that Chinese law, not English law, will decide whether Chinese fraud victims own any of the roughly 61,000 bitcoin seized in the UK from Zhimin Qian. Mr Justice Turner gave the judgment in the civil recovery case brought by the Director of Public Prosecutions. The coins were worth about $5.01 billion (£3.76 billion) at Coinbase rates at 08:27 UTC on 16 October. It is the largest crypto seizure ever made by UK law enforcement, according to the Metropolitan Police.

The ruling does not say who keeps the bitcoin. That question is still open, and the judge left the decisive part, what Chinese law actually provides, for a later hearing.

What it does is narrow the route the victims hoped to take. Under English law, many of them argued, they could claim the coins themselves as owners, and so share in the rise of bitcoin since they handed over their money between 2014 and 2017. Under Chinese law they may only be able to recover what they paid in, as creditors. According to the Financial Times, as relayed by The Block, the decision improves the British state’s chances of keeping most of the haul. Fieldfisher, the law firm leading the individual claimants, plans to appeal, the FT reported.

A day later, a second front opened. On 13 October a court in Tianjin announced that it had accepted, on 28 September, a prosecution application to confiscate 61,896.41552945 BTC tied to Qian, along with other assets. Beijing is now formally claiming the same coins that sit under the control of a court in London.

What the High Court decided on 12 October

The case is Director of Public Prosecutions v Zhimin Qian & Anor [2026] EWHC 2509 (KB). It was heard over three days, 7 to 9 July 2026, with further written submissions on 20 July. The DPP is pursuing civil recovery under Part 5 of the Proceeds of Crime Act 2002, which lets the state ask a court to hand over property obtained through crime, without the state having to wait for a criminal conviction (paragraph 15 of the judgment).

Inside that case, victims applied under section 281 of the Act for declarations that the property belongs to them. The judgment describes “many thousands of individual Applicants”. Each has to prove a proprietary interest in the bitcoin, because section 281 “does not create any broader compensation scheme”, in the judge’s words (paragraph 19). A victim who can only show that money is owed to them, rather than that the coins are theirs, gets nothing out of section 281.

Turner J held that “the applicable law is Chinese law” (paragraph 243), and that the answer was the same whether he applied the EU-derived Rome I and Rome II rules or the common law. The connecting facts all pointed east. “The relevant damage occurred in China. The Applicants parted with their money in China,” he wrote (paragraph 164). He also rejected the idea that English tracing rules could revive rights that Chinese law had already extinguished (paragraph 137).

Nobody disputed that the bitcoin is property, the judge noted (paragraph 25), citing earlier common-law cases, and he discussed the Property (Digital Assets etc) Act 2025, which came into force on 2 December 2025. The fight was about which country’s rules apply to the victims’ claims.

Several things are left for later. Any issues about the “content, effect or proof” of Chinese law are “matters for a later stage” (paragraph 246). The judge will hear counsel on the form of the order (paragraph 247). The Crown Prosecution Service said “there will be a further hearing to determine the application of the law”, as quoted by Decrypt.

Jackson Ng of Duan & Duan UK LLP put it this way, in comments quoted by The Block: “The Court has held that whether victims retain rights in the frozen bitcoin is to be decided under Chinese law.”

Why Chinese law could cap what victims recover

The difference between the two legal systems comes down to one distinction: owner or creditor.

An owner of property can follow it into whatever it became. If English law had applied, and if a victim could show that their yuan were traced into the bitcoin Qian bought, that victim could argue the coins, or a share of them, were theirs. Bitcoin bought in 2014 to 2017 cost between a few hundred and a few thousand dollars. A proprietary claim would therefore carry the gain on top of the original stake.

A creditor is owed a sum. If Chinese law treats the victims as having lost their ownership when they handed over the money, they are left with a claim for repayment, measured in what they paid in. Whatever the coins are worth above that would not belong to them.

The judgment’s assumed facts, as reported by Decrypt, put the money paid in by investors at about RMB 40.2 billion (around £4.1 billion), of which about RMB 34.1 billion had already been paid back to some investors, which is how a Ponzi scheme keeps going: early investors are paid out of later deposits. Prosecutors in Tianjin put the net losses above CNY 19.9 billion. If victims end up as creditors for what they lost, anything the coins fetch above those claims is where money for the state could come from, and at today’s price the coins alone are worth about £3.76 billion.

Prosecutors have said victims could be compensated through a redress scheme run from China, according to Decrypt. Victims challenged that route in March 2026, arguing it could leave British authorities with the gains, Cointelegraph reported. The law firm Candey represented about 5,700 victims at that stage. The Block, citing Caixin, puts the number of Chinese victims who have joined the UK proceedings at about 16,000.

Tianjin court opens its own case to confiscate 61,896 BTC

China’s move came through the Tianjin No. 2 Intermediate People’s Court. According to Yicai Global, the court accepted on 28 September a prosecution application to confiscate more than $5 billion in alleged illicit proceeds linked to Qian, and announced it on 13 October. The assets listed include nearly 62,000 BTC, other crypto, cash, jewellery and financial assets. Among the assets already seized in the UK, Yicai lists more than 61,800 BTC, more than 72,700 bitcoin cash and more than 3.6 million XRP.

PANews, relayed by Phemex, gave the exact figure of 61,896.41552945 BTC and the legal basis: Article 299 of China’s Criminal Procedure Law, part of the special procedure for confiscating illegal gains when a suspect has fled. Investors may join the case as interested parties, and those who do not keep their right to compensation from recovered assets, Yicai reported. Prosecutors are not asking to confiscate sums already returned to investors.

Chinese prosecutors describe a scheme that ran from April 2014 to August 2017 through Tianjin Lantian Gerui Electronic Technology, raising nearly CNY 40.4 billion ($6 billion) from more than 102,000 investors, with losses above CNY 19.9 billion ($2.9 billion). Joint litigation receivers acting for that company also took part in the London case, although the judge left open whether they have a valid claim (paragraph 7).

How the Tianjin filing will interact with the UK proceedings is not known. For now the coins remain subject to the London proceedings, and no source we read describes a request from Beijing to the UK. We found no UK government reaction to the Tianjin announcement.

Bitcoin seized in the UK: 61,000, 61,245 or 61,896 BTC?

Readers will see three numbers for the same stash this week. They come from different sources measuring in different ways, and none of the sources we read reconciles them.

About 61,000 BTC is the rounded figure in the judgment’s assumed facts, which say the seized property “includes more than 61,000 Bitcoin”. It is a floor, not a count.

61,245 BTC is an on-chain estimate. Blockchain analytics firm Arkham tracks addresses it attributes to the UK government, and Bitcoin Treasuries uses that figure to rank the UK third among governments, behind the US (328,372 BTC) and China (190,000 BTC), as The Block reported. It depends on which wallets Arkham has identified, and it covers UK government holdings as tracked by a third party, not a figure published by the Met or the court.

61,896.41552945 BTC is the exact amount written into the Chinese prosecution’s confiscation application, as reported by PANews. It is the highest of the three. None of the reports we read explains how it was reached, and Yicai’s own summary rounds the UK-seized amount to “more than 61,800”.

The spread is about 900 BTC, roughly $74 million at 08:27 UTC on 16 October. Until the UK authorities publish an exact figure, Coindaro uses “about 61,000 BTC”.

The bitcoin price used here was $82,058 (£61,643, €73,000) at 08:27 UTC on 16 October, on Coinbase reference rates. The live price is on our bitcoin page.

From a Tianjin investment scheme to a London courtroom

Qian, also known as Yadi Zhang, designed around ten investment schemes between 2014 and July 2017, most of them run in the name of Tianjin Lantian Gerui, according to the judgment’s assumed facts. At least 128,409 investment contracts were signed. Chinese police tried to arrest her at a promotional event on 12 July 2017; she escaped, crossed into Myanmar around 26 July and reached London around 16 September 2017 on a St Kitts and Nevis passport in the name of Yadi Zhang. Yicai adds that she left with a computer holding a bitcoin wallet. Back in Tianjin, the Hedong District procuratorate approved her arrest in January 2018, and Interpol issued a Red Notice the following month.

In London, the money proved harder to spend than to move. Attempts in 2018 to buy London property worth £40.5 million were blocked by know-your-customer checks, the CPS said, as quoted by Al Jazeera. On 31 October and 1 November 2018 the Metropolitan Police searched a London property and a safe deposit box and seized devices and the “keys” to some of the bitcoin, the judgment records. The High Court froze the property on 21 December 2023, and more assets were seized when Qian was arrested in April 2024.

Jian Wen, the second defendant in the civil case, met Qian in London and was convicted in 2024 of laundering offences. Qian pleaded guilty in September 2025 to acquiring and possessing criminal property, and on 11 November 2025 at Southwark Crown Court she was sentenced to 11 years and 8 months, and her associate Seng Hok Ling to 4 years and 11 months. Will Lyne of the Met’s Economic and Cybercrime Command called it “one of the largest and most complex economic crime investigations ever undertaken by the Met”, Al Jazeera reported.

The civil case ran in parallel. A management receivership order followed on 4 June 2025 and a further High Court judgment and declaration on 21 January 2026, according to the judgment. Then came the victims’ challenge in March and the July hearing on the governing law.

For anyone tempted by promises like those Lantian Gerui made, our guide to avoiding crypto scams lists the warning signs of a Ponzi scheme, starting with promised returns that do not depend on any real business.

The Treasury says seized bitcoin is not a reserve

If the state does end up with a surplus, the government has said it would not treat the coins as a strategic holding. In written parliamentary answers relayed by CryptoSlate, the Treasury said in September 2025 that it had no plans to change the frameworks for seized assets or reserves, or to review bitcoin as a reserve asset. On 2 March 2026 it said neither the Treasury nor central government held any cryptoassets, because the coins are seized criminal property subject to court proceedings.

UK asset-recovery guidance describes seizure as “a temporary step while proceedings continue”, CryptoSlate noted. Once a court makes its order, assets can be sold to compensate victims, or the proceeds go to the public purse and to economic-crime enforcement. Holding them as a reserve would need explicit authority.

The idea of selling has been floated before. In July 2025 The Telegraph reported, and Decrypt relayed, that Rachel Reeves, then Chancellor, was exploring a sale of the holding, at the time worth about $7.2 billion. The Home Office was working on a system to store and sell seized crypto. Reeves has since left the Treasury: John Healey has been Chancellor since 20 July 2026, according to gov.uk. We found no statement from him on the bitcoin.

On the opposition side, Reform UK leader Nigel Farage pledged in May 2025, at the Bitcoin 2025 conference in Las Vegas, to create a “bitcoin digital reserve” at the Bank of England and to cut capital gains tax on crypto from 24% to 10%. He was blunt on central bank digital currencies: “there’ll be a CBDC over my dead body,” he said, as reported by The Block. The US went further in March 2025, when an executive order set up a Strategic Bitcoin Reserve built from forfeited coins.

Custody is the quieter question. Whoever holds the private keys controls the coins, which is why seized bitcoin is normally kept offline in a cold wallet. The UK has already had one insider theft. In July 2025 a former National Crime Agency officer, Paul Chowles, was jailed at Liverpool Crown Court for five and a half years after stealing 50 of the 97 bitcoin the NCA had seized in its Silk Road 2.0 investigation, the CPS said.

What comes next: appeal, Chinese-law evidence and Tianjin

Nothing in the coming weeks is likely to settle ownership. The next steps, as far as they are known:

• A consequential hearing on the form of the High Court’s order (paragraph 247). No date has been published.
• Fieldfisher’s application for permission to appeal to the Court of Appeal, reported by the FT. No filing date or hearing date is public.
• A later stage on the content of Chinese law, with expert evidence, to decide whether any applicant has a proprietary interest under it.
• The Tianjin No. 2 Intermediate People’s Court confiscation proceedings. No hearing date has been announced.
• The Budget on 28 October 2026, Healey’s first, as confirmed in his letter to the Treasury Committee. No official statement so far links the seized bitcoin to it.

The case also lands as the UK prepares to license crypto firms: the FCA says its new cryptoasset regime is expected to come into force on 25 October 2027. Readers new to the asset at the centre of the dispute can start with our beginner’s guide to bitcoin.

Civil recovery and section 281 in brief

Under Part 5 of the Proceeds of Crime Act 2002, if the High Court is satisfied that property is recoverable, it must make a recovery order vesting it in a trustee for civil recovery (section 266). The trustee sells non-cash assets for the benefit of the enforcement authority, here the DPP (section 267). Whether the underlying conduct happened is decided on the balance of probabilities (section 241). Section 281 is the victims’ route: a person deprived of property by unlawful conduct who shows that the property they claim belongs to them can obtain a declaration, and property covered by it is no longer recoverable. That is why the governing-law question matters so much. If no victim can show ownership under Chinese law, section 281 offers them nothing, and any compensation would have to come through a separate scheme.