A High Court judge in London has ruled that Chinese law, not English law, will decide whether Chinese fraud victims hold property rights over more than 61,000 Bitcoin (BTC) seized by British police. The decision narrows the main legal route victims hoped to use to claim the coins and strengthens the UK government’s position in the largest cryptocurrency seizure in British history.
The ruling settles only which country’s law applies. It does not decide who owns the Bitcoin or how much any victim will recover.
What the Court Decided
In Director of Public Prosecutions v Zhimin Qian & Anor [2026] EWHC 2509 (KB), a judgment dated October 12, 2026, Mr Justice Turner of the King’s Bench Division (KB) held that the victims’ claims must be assessed under Chinese law.
The victims brought their claims under section 281 of the Proceeds of Crime Act 2002 (POCA), the UK law that lets authorities recover assets linked to crime. Section 281 allows a person to ask the court to declare that seized property belongs to them, which removes it from the state’s recovery claim. The judge noted that each applicant must prove a proprietary interest, meaning an ownership right in the property itself. He also noted that the section does not create a broader compensation scheme for people who lost money to crime.
The Director of Public Prosecutions (DPP), who heads the Crown Prosecution Service (CPS), argued that Chinese law applied “on any analysis.” Court-appointed litigation receivers for Qian’s former company supported that position. The individual applicants argued that English law should apply, or a mix of English and Chinese law, because the Bitcoin is now held in England. Fieldfisher LLP was instructed as lead counsel.
Mr Justice Turner rejected that argument. He applied Rome I, the European Union (EU) regulation on contract law that remains part of UK law after Brexit. He found that the contracts, the payments and the Bitcoin purchases all took place in China. He held that the location of the coins in England does not justify applying English law retrospectively to events that occurred in China.
The judge also addressed tracing, the legal process for following assets as they change form. He said that if victims lost their property rights under Chinese law when the Bitcoin was bought, a tracing claim in England cannot revive those rights.
The parties did not dispute that Bitcoin is property under English law. The judgment linked that position to case law and to the Property (Digital Assets etc) Act 2025, which came into force on December 2, 2025.
Background of the Fraud
According to the agreed facts set out in the judgment, Zhimin Qian established Tianjin Lantian Gerui Electronic Technology Co Ltd in China on or around March 31, 2014. Between 2014 and July 2017, she designed around ten Ponzi schemes. A Ponzi scheme pays earlier investors with money taken from newer ones.
An audit found at least 128,409 investment contracts linked to the fraud. The court noted it is not yet known whether that figure reflects the number of victims or the number of contracts. Funds received totalled about RMB 40.23 billion (Chinese yuan), roughly £4.1 billion, according to a September 13, 2021 judgment of the Tianjin Hedong District People’s Court that convicted her associate Jiangtao Ren. About RMB 34.1 billion was paid back to some investors over the same period.
Part of the money was converted into Bitcoin through three routes:
- a Huobi exchange account opened in June 2014 in Ren’s name and controlled by Qian
- over-the-counter (OTC) trades
- mining machines in China
More than 100,000 BTC were bought through the Huobi account between mid-June 2014 and June 7, 2017.
Qian fled to Myanmar around July 26, 2017. She arrived in London around September 16, 2017, using a St Kitts and Nevis passport in the name of Yadi Zhang. On October 31 and November 1, 2018, London’s Metropolitan Police searched a property and safe deposit box she rented. Officers seized devices used to access the Bitcoin.
On November 11, 2025, Southwark Crown Court sentenced Qian to 11 years and eight months for possessing and transferring criminal property under POCA. The Metropolitan Police described the case as the world’s largest confirmed cryptocurrency seizure.
What It Means for Victims
The choice of law matters because it shapes what victims can recover. Business outlet Caixin reported in July that about 16,000 Chinese victims are pursuing claims. Under English law, they could have claimed the Bitcoin itself and its rise in value. Under Chinese law, they could be limited to their original principal and interest.
The court has not yet tested that question. Mr Justice Turner said no evidence has yet been heard on the content of Chinese law, and he declined to speculate on how it would apply. The Financial Times has valued the seized holdings at about £3.8 billion ($5 billion).
What Comes Next
The case continues in the High Court. The parties will now need to present evidence on Chinese law and on each applicant’s individual claim. According to the Financial Times, lawyers for the victims have indicated they intend to appeal the choice of law ruling.
Until those steps are complete, the fate of the 61,000 Bitcoin remains undecided. The UK could retain it, victims could receive it in full or in part, or the case could end in another outcome.
Also Read: Fairshake-Linked PACs Report $2.7M in US House Campaign Spending
