London’s High Court has ruled that Chinese law, rather than English law, will decide whether thousands of fraud victims hold property rights over more than 61,000 Bitcoin seized by the Metropolitan Police, a haul worth about $5 billion at current prices. The judgment, handed down by Mr Justice Mark Turner on October 12, resolves only the choice-of-law question, not who ultimately keeps the coins.
The ruling arises from civil recovery proceedings brought by the Director of Public Prosecutions against Zhimin Qian, who pleaded guilty to money laundering and was sentenced to 11 years and eight months in November 2025. Qian ran Ponzi schemes between 2014 and 2017 through Tianjin Lantian Gerui Electronic Technology and a second purported entity, collecting roughly RMB 40.2 billion (about £4.1 billion) through at least 128,409 investment contracts before converting part of the proceeds into Bitcoin and moving to London.
What the ruling decides and does not decide
Thousands of victims have applied under section 281 of the Proceeds of Crime Act 2002, which lets a person ask the court to declare that seized property belongs to them. Turner found that the fraud, the payments and the contracts all took place in China, and that the Bitcoin itself was bought there through the Huobi exchange and over-the-counter trades. “The relevant damage occurred in China. The applicants parted with their money in China,” he wrote, concluding that “the applicable law is Chinese law.”
The decision is a threshold ruling, not a merits decision. The judge left open the content of Chinese law, how it must be proved and how it applies to each individual claim. Victims must now show that Chinese law recognises the ownership rights they assert, and that those rights attach to the specific coins seized in England.
Why the choice of law matters for the victims
The stakes turn on what each legal system would give the claimants. Under English law, victims argued they could trace their money into the Bitcoin and claim the coins themselves, capturing their appreciation — the difference between the roughly £4.1 billion lost in principal and the roughly $5 billion the coins are worth today. Under Chinese law, claims are expected to be limited to the original principal and accrued interest, which would leave UK authorities holding much of the appreciation. Bitcoin has traded near $83,000 this week, which is what pushes the seized coins’ value to about $5 billion.
What happens next
The case will remain in the High Court, where the next stage involves expert evidence on Chinese law and each applicant’s individual claim. The law firm Fieldfisher, which represents the claimants, has indicated it will appeal the choice-of-law ruling. The dispute also fits a wider pattern of courts and authorities recovering digital assets from fraud schemes, including the CFTC’s $31 million default judgment against Fundsz in a digital-asset fraud this month. Even if the ruling stands, the court has not decided that the victims recover nothing — it has narrowed the legal route available to them, and the question of ownership remains open.
