Chinese investors trying to recover 61,000 Bitcoin seized in Britain have lost a court dispute over which country's law should apply. The holdings are worth about GBP 3.8 billion (USD 5 billion), far more than the unpaid losses linked to the original fraud.
On October 12, Justice Mark Turner ruled that Chinese law must govern the victims' ownership claims. The High Court has not decided who will receive the Bitcoin. Later proceedings will assess Chinese law and the claims of individual investors.
UK Court Rejects Investors' Bid to Use English Law
The investors wanted English law to apply because it could allow them to claim the Bitcoin itself. Prosecutors argued that Chinese law should determine whether the victims had any ownership rights. Turner accepted that position, noting that the fraud and related transactions occurred in China.
“The relevant damage occurred in China,” he wrote. The victims paid money in China, and the people running the schemes bought Bitcoin there. The coins' later seizure in London did not change which country's law governed those earlier dealings. The court also rejected an argument for applying a mixture of English and Chinese law.
Fraud Victims Face GBP 600 Million in Unpaid Losses
The case began with investment schemes run by Zhimin Qian between 2014 and 2017. Court records show that the schemes collected about CNY 40.23 billion (GBP 4.1 billion). Of that total, approximately CNY 34.1 billion was returned to some investors.
That leaves a difference of about CNY 6.1 billion, equivalent to roughly GBP 600 million at the court's exchange rate. An audit identified at least 128,409 investment contracts, although the judge said the number of separate investors remains unclear.
Qian used some of the money to acquire Bitcoin before leaving China in 2017. British police recovered cryptocurrency access devices during searches in London the following year. In November 2025, Qian was sentenced to 11 years and eight months in prison after pleading guilty to offenses involving criminal property.
Ownership Claims Will Be Tested Under Chinese Law
The victims filed claims under Section 281 of Britain's Proceeds of Crime Act 2002. That provision allows a person to ask a court to recognize their ownership of property targeted for recovery by the state.
However, being owed money by someone who committed fraud is not the same as owning assets bought with that money. The judge said victims must prove an ownership interest under Chinese law. The court has not yet heard expert evidence explaining how that law applies to their claims.
Appeal Planned as Britain Seeks Recovery of Bitcoin
Lawyers representing the victims are pursuing an appeal against the decision. Meanwhile, the dispute will remain before the High Court in London, where a further hearing will examine Chinese law and the evidence supporting individual claims.
The ruling leaves open several outcomes. Some victims could establish ownership of part of the holdings, while other claims may fail. Any Bitcoin that victims cannot prove belongs to them could remain subject to the government's recovery case.
No final decision on ownership or distribution has been issued. The outcome will also determine how much of the Bitcoin's rise in value could go to claimants.
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