Commentary: The Fate of £5 Billion in Stolen Crypto Rests on U.K.-China Cooperation

On September 29, proceedings opened at London’s Southwark Crown Court in what is widely regarded as the world’s largest cryptocurrency money laundering case. The trial took an unexpected turn on the first day when defendant Qian Zhimin pled guilty. This plea rendered a jury trial unnecessary and shifted the focus to sentencing, which will follow U.K. guidelines. Qian's admission to the charges was welcomed as a “landmark victory” by U.K. authorities, who had seized over 61,000 bitcoins — valued at more than £5 billion, or roughly 47 billion yuan — from Qian. This sum exceeded the funds lost in the underlying fraud committed in China, the Tianjin Lantian Gerui Electronic Technology Co. Ltd. investment scam, which occurred from 2014 to 2017. The trial’s early resolution was unexpected for observers, and the complex process of cross-border asset recovery now becomes the principal challenge. This next phase will require substantial cooperation between Chinese and U.K. authorities, with the quest for substantive justice continuing beyond the courtroom victory. [para. 1][para. 2][para. 3]

Qian pled guilty to acquiring, possessing, and transferring criminal property (cryptocurrency) — offenses under English law with a maximum sentence of 14 years. Notably, the broader fraud she committed in China does not fall under the English court’s jurisdiction. Her potential extradition to China remains uncertain due to the absence of a formal treaty, and would require exceptional arrangements by both governments and respective judiciaries. Nonetheless, her conviction firmly settles her status under U.K. criminal law, and her plea provides indirect validation of the Chinese fraud allegations. With sentencing on the horizon, attention now turns to civil recovery proceedings already begun at the High Court in September 2024. [para. 4][para. 5]

The U.K.’s Crown Prosecution Service (CPS) has chosen not to seek immediate criminal confiscation of the assets, instead allowing time for civil recovery processes at the High Court. The Director of Public Prosecutions (DPP) indicated that any order to vest property in civil recovery trustees will be delayed so that claimants can secure legal counsel and present claims under Section 281 of the Proceeds of Crime Act (POCA). For the nearly 130,000 Chinese victims, tracing investments to the seized bitcoins will be extremely difficult. The evidentiary and procedural barriers, compounded by unfamiliarity with U.K. legal requirements and significant institutional differences, further complicate these efforts. [para. 6][para. 7]

The case has featured “unprecedented” cooperation between British and Chinese law enforcement, with both sides acknowledging their collaborative efforts as crucial to Qian’s guilty plea. Usually, Western courts have resisted admitting Chinese evidence out of concern for human rights, but this case proved an exception following extensive investigation and disclosure. Qian’s lawyer communicated that her plea might offer comfort to victims, who now hope to recoup their losses — an outcome made more plausible by the rise in cryptocurrency value. [para. 8][para. 9][para. 10]

China currently lacks a civil recovery regime comparable to the U.K.'s. Instead, its legal system provides for confiscation of criminal assets through criminal law — notably via special procedures for absconding suspects or those who have died. Qian’s status and the evidence now available could provide a sufficient basis for Chinese prosecutors to use this mechanism, which could dovetail with U.K. proceedings for global asset restitution if recognized and enforced in the U.K. [para. 11][para. 12][para. 13][para. 14][para. 15]

In late 2024, the U.K. government reiterated in policy papers the principle of compensating overseas victims in economic crime, providing a framework for collaborative asset recovery. Success in this case could set a precedent for future cross-border cooperation. Ultimately, Qian’s conviction is only the first step: the fulfillment of asset recovery, benefiting Chinese victims, will be the true measure of meaningful Sino-U.K. judicial collaboration. [para. 16][para. 17][para. 18]