UK High Court: Chinese law governs claims to 61,245 seized BTC in Qian Zhimin case

The High Court in London ruled on Monday, October 12, that Chinese law, not English law, governs claims by around 16,000 fraud victims over 61,245 BTC — about $5.1 billion at Arkham's valuation, roughly £3.8 billion by Financial Times accounting — seized from assets controlled by Qian Zhimin, also known as Yadi Zhang. The Block has the primary reporting; Decrypt's companion piece adds that English law would have been substantially more favorable to the victims. The decision raises the UK government's chances of eventually keeping or liquidating the hoard. Fieldfisher, which represents individual victim claimants, is appealing.

What the court ruled

Mr Justice Mark Turner found that the fraud, the victim payments and the underlying contracts all occurred in China and that each legal route he considered led to the same answer: Chinese law applies to the proprietary-interest question. In his framing, claimants must demonstrate a proprietary interest in the bitcoin — a personal claim to repayment as a creditor is not enough.

The practical difference between the two legal regimes, per Decrypt and The Block:

• Under English law, the victims could have argued the bitcoin remained theirs — tracing coins from fraudulent proceeds through Qian's purchases and onward holding — and taken ownership on that basis.
• Under Chinese law, as prosecutors argued, tracing the coins to a UK seizure does not revive property rights the victims lost when the bitcoin was bought in China from Huobi accounts. Victims may be limited to recovering their original investments plus interest, through a China-run redress scheme.

The ruling does not settle ownership. A further hearing will cover the content and application of Chinese law and whether any individual victim can establish an interest in the bitcoin at all.

How the seizure happened

• 2014–2017: Qian ran investment schemes in China tied to the Tianjin Lantian Gerui network. Court records cite at least 128,409 investment contracts and allege more than 100,000 BTC were bought on Huobi with investor funds.
• July 2017: Qian fled China for Myanmar and later to London.
• October–November 2018: London's Metropolitan Police seized devices used to access the bitcoin wallets in a series of searches. Further seizures followed in later years.
• November 2025: Qian pleaded guilty and was sentenced to 11 years and eight months for money laundering.
• October 12, 2026: Turner rules on the governing-law question.

Where the money sits in sovereign ranking

If the UK Treasury eventually keeps the proceeds and the seized stock is counted among state holdings, The Block cites Bitcoin Treasuries estimates:

• United States: 328,372 BTC ($27.3B)
• China: 190,000 BTC ($15.8B)
• United Kingdom: 61,245 BTC seized ($5.1B) — would rank third globally if realised in full

Prosecutors have said victims could be compensated through a China-run redress scheme regardless of who gets the coins; the UK's own route for unclaimed proceeds is confiscation, sale, and transfer to the UK Treasury's general fund.

What to watch

1. The Fieldfisher appeal. Any Court of Appeal ruling that reinstates an English-law option — even partially — reopens the ownership question for 16,000 individual claimants.
2. The content-of-Chinese-law hearing. Turner has not yet ruled on what Chinese law actually says about proprietary interest in the bitcoin, only that it governs. A pro-claimant Chinese-law reading, delivered via expert evidence, would still get victims part of the way.
3. How and when the coins move, if at all. The UK has not announced an intention to sell. A visible test transaction or an exchange deposit from the police custody addresses would be the first public signal, and would move the "US holds the biggest state stack" narrative.
4. Interaction with China's own holdings. Chinese authorities already control the ~190,000 BTC seized from PlusToken and other cases. A UK redress scheme routing proceeds through a China-side process would create the first large cross-border state-to-victim pay-out of bitcoin-origin funds.

Context

Qian's case is the largest cryptocurrency seizure a UK court has handled and the first in which the governing-law choice at scale has been litigated through to a reasoned judgment. The ruling fits a pattern in which London's attachment and civil-recovery regime proves effective at securing on-chain assets but hands the substantive distribution question back to the jurisdiction where the fraud originated. For victims this is colder comfort than an English-law carve-out would have been; for sovereign bitcoin accounting, it keeps the UK's path to ranking as the third-largest state holder open.