UK Court: Chinese Law Governs 61,000 Bitcoin Claims

A London High Court judge ruled on Oct. 12, 2026, that Chinese law, not English law, governs the ownership claims of thousands of Chinese fraud victims seeking a share of 61,000 Bitcoin seized by British police. A London court ruled that Chinese law governs fraud victims' claims to 61,000 bitcoin, worth about £3.8 billion, because the underlying scheme and losses occurred in China. The decision does not say who owns the Bitcoin, but it narrows victims' best chance of claiming the currency's price gains rather than just their original losses.

What the court actually 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 held that the victims' claims must be assessed under Chinese law. London's High Court ruled that Chinese law, rather than English law, should govern claims to the assets, with the judge rejecting arguments for applying English law or a combination of English and Chinese law to the victims' ownership claims.

The Director of Public Prosecutions, who heads the Crown Prosecution Service, argued that Chinese law applied "on any analysis," a position supported by court-appointed litigation receivers for Qian's former company, while 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. The ruling settles only which country's law applies; it does not decide who owns the Bitcoin or how much any victim will recover. The judge left the detailed content of Chinese property law to be established at a later hearing, so the practical payout question is still open.

Why the choice of law matters for how much victims can recover

This is a technical point with a large financial consequence. The decision could limit the roughly 16,000 Chinese victims who have joined the UK recovery proceedings to recovering their principal and interest, rather than a share of the bitcoins' gains, which are now worth about 200 times their original purchase price. In plain terms, if a victim invested money that was later converted into Bitcoin, English property law might have let them claim a proportional share of today's coin value. Chinese contract and fraud law more commonly treats defrauded investors as creditors owed their money back plus interest, not as owners of whatever asset that money later became. The court has not yet decided whether the investors hold property rights in the bitcoins under Chinese law, so that downside scenario for victims is not finalized.

Earlier reporting shows the victim count is not fully settled. The dispute involves more than 128,000 investors reportedly affected by the fraud, and in March, Cointelegraph reported that law firm Candey represented about 5,700 victims. That is a smaller figure than the roughly 16,000 Caixin Global says have since joined the UK recovery proceedings, a gap that likely reflects how many victims had formally registered claims in London at each point in time rather than a dispute over the total number harmed. Prosecutors have also argued that certain claims could let a smaller group of victims and litigation funders recover more than their actual losses, a concern that has shaped how the court is treating the ownership question.

Where the Bitcoin came from

Zhimin Qian was responsible for a massive investment fraud in China between 2014 and 2017 involving over 128,000 victims, some of whom invested their life savings and pensions, with losses of approximately £600 million. Qian converted much of the proceeds into Bitcoin before fleeing to Britain. She was found with 5 billion pounds ($6.6 billion) in Bitcoin after defrauding more than 128,000 people in China in a Ponzi scheme and was sentenced by a UK court to over 11 years in prison. Qian, who had pleaded guilty to money laundering offenses and transferring and possessing criminal property, was sentenced on Nov. 11, 2025 to 11 years and eight months at Southwark Crown Court.

The gap between the $6.6 billion value reported at Qian's November 2025 sentencing and the roughly $5 billion (£3.8 billion) figure tied to this month's ruling reflects Bitcoin's price movement over the intervening eleven months. The number of coins seized has remained 61,000 throughout.

Key figures

What is still unknown

The ruling resolves a single preliminary question, which country's law applies, and leaves the substantive ownership question open. No hearing date has yet been reported for the next stage, in which the court will examine evidence on what Chinese law actually says about the victims' property rights. Reporting from Bloomingbit indicates the victims plan to appeal the choice-of-law ruling, which would add further delay before any distribution of the Bitcoin or its proceeds. Until the ownership question is resolved, the coins remain in UK government custody, and neither the victims nor the UK government has a confirmed legal claim to them.