Chinese investors seeking a share of 61,000 Bitcoin seized in the United Kingdom have lost a preliminary argument about which country’s law governs their ownership claims. On 12 October 2026, the High Court held that Chinese law governs whether investors have proprietary rights in the Bitcoin, while English law governs the statutory recovery process. The ruling does not decide whether any individual investor owns any of the coins or will receive money.
What the High Court decided
The case is Director of Public Prosecutions v Qian and others, a civil recovery proceeding concerning cryptoassets held in England. The investors wanted the court to apply English law, or a combination of legal systems, to the substance of their claims. Their arguments included the possibility that unwinding investment contracts induced by fraud could create a constructive trust and allow them to trace their money into Bitcoin.
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The judge concluded that Chinese law governs the substantive questions about investors’ rights under the principles in Rome I, Rome II and common-law conflict rules. English law still governs the court process under Part 5 of the Proceeds of Crime Act 2002 (POCA). The decision is a preliminary choice-of-law ruling, not a finding about the outcome of any investor’s claim. A case summary of the ruling says evidence of Chinese law had not yet been heard.
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The ruling settles which legal system will be used to assess the underlying rights; it does not establish what those rights are. The applicants will still need to show, under Chinese law, that they have a proprietary interest in the assets. The assumed facts placed the investments and the conversion of funds into Bitcoin in China, a central reason the court selected Chinese law for the substantive issues.
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That distinction matters because investors’ losses do not automatically give them ownership of assets later recovered from the scheme. A personal claim that someone owes a claimant money is different from a proprietary claim asserting that particular property belongs to that claimant. The High Court has not ruled on whether any named investor can meet that test, and the share of applicants who may ultimately do so is unknown.
What the UK recovery process allows
The Director of Public Prosecutions brought the case under Part 5 of POCA, which provides for civil recovery of property. Investors have applied under section 281, which allows a person claiming an interest in property to seek a declaration from the court. That route requires a proprietary interest; it is not a general scheme for compensating everyone who lost money in the fraud.
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In practical terms, the court must distinguish claims to ownership of the recovered property from claims for repayment of money. The choice-of-law decision determines that Chinese law will govern the former question, while the English statutory procedure supplies the process for advancing it in this case. Neither the eventual amount nor the form of any recovery has been decided. The case summary describes the distinction between the substantive claims and the Part 5 process.
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The Bitcoin were recovered in the UK and remain part of the civil recovery proceedings. The Crown Prosecution Service (CPS) reported a seizure-time valuation of £300 million for the 61,000 Bitcoin. That is a historical figure from the time of seizure, not a current valuation: Bitcoin prices change, and the figure should not be treated as the value of the assets today. The court has not ordered that the coins be divided among investors.
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The CPS says that Qian’s schemes ran from 2014 to 2017 and that most were implemented in the name of Tianjin Lantian Gerui Electronic Technology Co Limited. About £20.2 million of illegally obtained money was converted to Bitcoin, according to the CPS’s 2025 account. Its 2026 reporting says more than 128,000 people in China fell victim to the scheme and suffered losses of around £600 million. These figures describe the scale of the alleged fraud and its laundering; they do not establish which victims have ownership rights in the recovered Bitcoin.
The civil claims are separate from the criminal sentences
Criminal proceedings have already resulted in sentences, but those outcomes do not decide ownership of the Bitcoin. The CPS reports that Qian was sentenced to 11 years and eight months in November 2025 after pleading guilty to two offences. Seng Hok Ling received four years and 11 months, while Jian Wen had earlier been sentenced to six years and eight months. Those sentences concern the defendants’ criminal conduct, not the investors’ civil claims to the assets.
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The Metropolitan Police says its investigation involved evidence and cooperation with Chinese law enforcement. The Met’s account of the investigation provides that context, but criminal convictions and cooperation do not themselves determine whether a particular investor owns any part of the recovered property.
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What investors should watch for next
The next consequential questions are whether applicants can establish proprietary rights under Chinese law and how the English court will handle those claims within the POCA process. The 12 October decision does not answer either question. A March 2026 High Court order identifies the proceedings as KB-2024-003157 and lists 2,594 other applicants in that procedural order; that number is not a count of every eventual claimant and says nothing about how many will succeed. The Judiciary’s March order records that procedural detail.
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For now, investors should not interpret the ruling as either an order to return the Bitcoin or a final rejection of their claims. It resolves a legal question that must be answered before the individual ownership arguments can be determined.
Quick Recap
Sources
- Case summary of the High Court choice-of-law decision
- Crown Prosecution Service: scheme victims and seizure reporting
- Crown Prosecution Service: convictions, sentences and laundering
- Metropolitan Police: investigation account
- Judiciary: March 2026 procedural order
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