Mr Justice Turner held that Rome I points the victims' proprietary claims to China, where the contracts and the coin purchases happened, not to England, where the bitcoin now sits. The ruling decides only which law applies, and no evidence on what Chinese law says has been heard yet.
The High Court of England and Wales ruled on Monday that Chinese law governs the claims of fraud victims to more than 61,000 bitcoin seized by the Metropolitan Police in 2018. Mr Justice Turner, sitting in the King's Bench Division in Director of Public Prosecutions v Zhimin Qian, rejected the applicants' arguments for English law and for a mixture of the two systems. The judgment is reported as [2026] EWHC 2509 (KB) by The Crypto Times, Crypto Briefing and Bitcoin.com News; the full text was not reachable from here, so this report rests on those three independent accounts rather than on the judgment itself.
The decision settles which law applies and nothing beyond that. It does not determine who owns the bitcoin, how much any applicant recovers, or whether the United Kingdom keeps any of it. No evidence on the content of Chinese law has been heard, and the judge declined to speculate about how it would treat the claims. Those questions belong to a later stage of the civil recovery proceedings, for which no hearing date has been reported.
Turner applied Rome I, the European contract-law regulation retained in UK law, and found that the investment contracts, the payments and the bitcoin purchases all took place in China. That the coins now sit in England does not, on his reasoning, justify applying English law to events that happened elsewhere. He also held that if the victims lost their property rights under Chinese law at the moment the bitcoin was bought, an English tracing claim cannot restore them.
What turns on the choice is the appreciation. Under English law the applicants could have claimed the coins themselves and the increase in their value since 2018. Under Chinese law they may be confined to their original principal and interest, a reading both Crypto Briefing and The Crypto Times attribute to the Financial Times and Caixin, and one the judgment does not resolve either way. The scale of that difference is the reason the point was argued first rather than last.
The two figures are far apart. Zhimin Qian took about 40.23 billion yuan from investors across roughly ten schemes between 2014 and 2017 and returned about 34.1 billion yuan to some of them, leaving a net shortfall near 6.1 billion yuan on those reported inputs; Crypto Briefing put victims' losses at about 600 million pounds, which is consistent with that subtraction at recent exchange rates. The seized holding is worth far more. Arkham tracks a UK government balance of 61,245.01 bitcoin, which at the bitcoin price near 83,000 dollars that CoinDesk reported on Tuesday comes to roughly 5.1 billion dollars, and the Financial Times valued the coins at about 3.8 billion pounds. Both calculations here are derived from those reported inputs rather than from any court finding.
Qian built the schemes through a Tianjin company incorporated in 2014, left China in 2017 and entered the United Kingdom on a St Kitts and Nevis passport in the name Yadi Zhang. The Metropolitan Police searched her property and a safe deposit box at the end of October 2018 and seized the devices holding the keys. She was arrested in April 2024, pleaded guilty in September 2025, and was sentenced at Southwark Crown Court in November 2025 to 11 years and eight months for possessing and transferring criminal property under the Proceeds of Crime Act 2002.
How many people stand behind the claims is not settled. Investors have filed under section 281 of the same Act, the provision that lets a person assert ownership of property the state is trying to recover. Court records list at least 128,409 linked investment contracts, which counts contracts rather than claimants, and the reports reviewed here do not reconcile the two. One of them cites roughly 16,000 Chinese applicants through a single Chinese-language source, and that figure is not corroborated elsewhere in this record, so it is left aside here.
Lawyers for the victims intend to appeal the choice-of-law ruling, which Crypto Briefing reports is expected to be heard in 2027. Until that is decided the next phase turns on expert evidence about what Chinese law actually says, a question no party has yet put before the court.
The distance between seizing assets and returning them to the people who lost them is where cases like this usually settle. Mashinsky's lifetime industry ban arrived with a 35 million dollar figure that New York may never collect. Treasury Secretary Scott Bessent has twice named the same billion dollars of Iranian crypto, once as already taken and once as still being isolated. Victims of an exploit at Drift earlier this year are being paid about a cent on every dollar lost.
For now the bitcoin stays where it has been since 2018, held by UK authorities while the Director of Public Prosecutions pursues civil recovery. No court has yet decided who is entitled to it, and the one that will has just been told to answer the question in a legal system other than its own.
