UK Court Rules Chinese Law Governs $5 Billion Bitcoin Claim

More than 61,000 bitcoin seized in Britain will be argued over under Chinese law, not English law. The High Court in London ruled on Monday 12 October that Chinese law governs the property claims of people defrauded by Zhimin Qian.

The coins are worth about $5 billion at a bitcoin price of around $83,200, and the decision improves the UK government's chances of keeping most of them. It does not say who owns the bitcoin. It settles which country's law a judge should use to work that out.

What the High Court Was Asked to Decide

The judgment was narrow by design. Justice Mark Turner put the question this way: whether the law of England, China or a combination of the two "will later fall to be applied to resolve the substantive legal issues to which the victims' claims give rise."

Thousands of alleged victims have applied under section 281 of the Proceeds of Crime Act 2002 to have parts of the bitcoin declared theirs. To win, each has to show a proprietary interest in the coins, meaning a recognised legal right over them. Turner noted the Act creates no broader compensation scheme for people who lost money to crime, so a general claim to have been defrauded is not enough on its own.

The Director of Public Prosecutions argued that Chinese law applies on any analysis, and the litigation receivers backed that position. The judge agreed. The fraud happened in China, the investors were Chinese nationals resident there when they paid in, and most are believed to still live there. He said he reached the same conclusion under each of the legal routes he considered.

"The relevant damage occurred in China. The Applicants parted with their money in China."

Why the Choice of Law Comes Before Ownership

It looks like a technicality until you follow the logic. Whether a victim still holds a right over specific coins is itself a question answered by whichever law applies. Pick English law and the answer may be one thing. Pick Chinese law and it may be another.

The applicants wanted English law to apply by default until Chinese law is pleaded and proved in court. Turner rejected that. "The fact that the content of Chinese law has not yet been pleaded or proved does not provide a basis for treating English law as the governing law," he wrote, adding that the choice of law question comes logically before any inquiry into the content of that law.

He also dealt with tracing, the process of following coins through the blockchain to show they are the same ones taken. Because the bitcoin was bought in China, he said, tracing coins in England cannot revive property rights the victims lost under Chinese law at the moment of that purchase. In other words, the chain records where the coins went, not which law decides who has a claim on them.

How the Bitcoin Got There

Qian, a Chinese national born in 1978, set up Tianjin Lantian Gerui Electronic Technology around 31 March 2014 and designed roughly ten purported investment schemes over the next three years, mostly Ponzi schemes. An audit by the Zhongyi CPAS Tianjin Office found at least 128,409 investment contracts were entered into.

The sums involved are large. Funds received from victims totalled about RMB 40,228,350,969, roughly £4.1 billion, between 2014 and 2017, while approximately RMB 34.1 billion, about £3.4 billion, was repaid to some victims and not others.

The bitcoin was accumulated while Qian was still in China. More than 100,000 BTC were bought through a Huobi account opened in June 2014 in the name of an associate, Mr Ren, between mid-June 2014 and 7 June 2017. Further coins came through over-the-counter deals in China between January and June 2017 arranged through Hua Chen, a former Huobi employee. The judgment records that all the victim funds converted into bitcoin had been converted before Qian left China in July 2017.

She crossed into Myanmar to evade arrest that July and reached London on or around 16 September 2017 on a St Kitts & Nevis passport in the name Yadi Zhang. The Metropolitan Police seized more than 61,000 BTC in searches on 31 October and 1 November 2018 and at her arrest in April 2024. Qian was sentenced in November 2025 to more than 11 years after pleading guilty to fraud and money laundering.

The seized property is already under court control. It is subject to a freezing order made on 21 December 2023, a management receivership order made on 4 June 2025, and a judgment and declaration made on 21 January 2026.

What Comes Next

Fieldfisher, the firm representing the claimants, says it is pursuing an appeal. The Crown Prosecution Service says a further hearing will determine how the law applies and whether any victim can establish an interest in the bitcoin.

No evidence has been put before the court yet on the content of Chinese law, or on the precise evidential basis of each claim. The parties used a statement of agreed assumed facts instead. Turner left questions about the content, effect or proof of Chinese law to a later stage, and said he will hear counsel on the precise form of order.

No date has been published for that hearing or for the appeal. If the ruling holds, the case continues in London, where expert evidence on Chinese law will be tested. The next milestone is not another price move. It is the point where Chinese law stops being a principle and starts being evidence.