UK Court Rules Chinese Law Governs Claims to 61,000 Seized Bitcoin

A $5 Billion Bitcoin Fight Takes a Sharp Turn

Victims of one of Britain’s largest crypto frauds have lost a key round in their fight over 61,000 seized Bitcoin.

London’s High Court ruled that Chinese law, not English law, will decide whether the victims have any ownership rights over the coins. The stash is worth more than $5 billion at current prices, according to Cointelegraph, citing CoinGecko data.

The decision does not settle who gets the Bitcoin. It does, however, change the legal ground on which that battle will be fought.

How 61,000 Bitcoin Ended Up in British Hands

The coins trace back to an investment scheme Zhimin Qian ran in China between 2014 and 2017. More than 128,000 people invested in it.

Part of the proceeds was moved into Bitcoin. Her activity came to light in 2018, when she tried to buy London properties worth £40.5 million and failed the “know your customer” checks that buyers must pass. She was arrested in 2024.

In November 2025, Southwark Crown Court sentenced Qian to 11 years and eight months in prison for money laundering offences. Police described the seizure of 61,000 Bitcoin as a UK record.

What the Judge Decided

Mr Justice Turner delivered the ruling in Director of Public Prosecutions v Zhimin Qian, and the full judgment is now public.

The victims, represented by law firm Fieldfisher, had argued that English law, or a blend of English and Chinese law, should govern their claims. The prosecution argued that Chinese law applied on any analysis.

The judge sided with the prosecution. He found that the claims “do not engage English law as the governing law of the rights upon which they rely.” His reasoning was simple: the victims handed over their money in China, the contracts were made in China, and the harm happened in China.

Why “Owner” and “Creditor” Are Worth Billions Apart

To see why this matters, it helps to understand the difference between owning an asset and being owed money.

An owner has a claim to the actual thing. If the victims could show the seized Bitcoin, or part of it, belonged to them, they would be entitled to the coins themselves. That includes all growth since the fraud.

A creditor only has a claim for a sum of money. A creditor is usually repaid what they lost, measured at the time of the loss. They do not share in later gains.

That gap is enormous here. The money was taken in the mid-2010s, when Bitcoin traded for a tiny fraction of today’s BTC price. Victims pushed for English law because it could open a route to direct ownership claims rather than creditor-style compensation.

Who Keeps the Gains?

This question has hung over the case since March. Earlier this year, victims challenged a proposed compensation plan involving a Chinese redress scheme, arguing it could leave British authorities with much of the gain from Bitcoin’s rise.

The ruling does not decide that issue either. Under the UK’s Proceeds of Crime Act, each victim must now show that rights they gained under Chinese law mean the property “belongs to” them. If they cannot, the coins may remain within the state’s civil recovery process.

Prosecutors have argued that some claims could let a smaller group of victims and litigation funders recover more than they actually lost. A separate firm, Candey, represents around 5,700 victims, according to earlier reporting.

What Happens Next

The case stays in London rather than moving to a Chinese court. The next stage will involve expert evidence on what Chinese law actually says, because the court has not yet heard such evidence. The judge noted that “any issues concerning the content, effect or proof of that law are matters for a later stage.”

Fieldfisher is appealing the ruling, according to the Financial Times. If the appeal fails, the outcome may turn on how Chinese courts and experts treat property rights in money handed over to a fraudster.

Seized government Bitcoin is a growing theme worldwide. In the US, authorities recently moved $1.01 billion in seized Bitfinex Bitcoin without any sign of a sale. Traders watch these stockpiles because a decision to sell could add supply to the market, although no sale has been announced in the UK case.

A Test Case for Crypto Justice Across Borders

The bigger lesson is that crypto’s borderless nature does not make the law borderless. Bitcoin can move from China to a laptop in London in minutes, but the rights of the people who lost money stay tied to where the loss happened.

For fraud victims, that is a sobering message. Recovering stolen crypto is only half the battle. Proving who it belongs to, under which country’s law, can take years and decide whether victims see their original losses or a share of a $5 billion windfall.

For courts, the case may become a reference point. As more seized crypto sits in government wallets, the question of who benefits when its value soars is unlikely to stay confined to one London courtroom.