Roughly 16,000 Chinese investors who lost money in Qian Zhimin's fraudulent crypto scheme have been granted permission to challenge an October ruling that would have allowed the UK to pocket most of the gains on approximately 61,000 BTC seized from the convicted fraudster.

On October 16, a UK court decided the group may continue seeking to claw back its losses from the seized cryptocurrency, which is now valued at about $5 billion. The appeal followed an October 12 judgment by Justice Mark Turner, who ruled that Chinese law — not English law — should govern the investors' claims to the seized Bitcoin.

English and Chinese law diverge on seized crypto claims

The case has brought into focus a key distinction between how English and Chinese law handle claims to seized cryptocurrencies.

Under English law, the claimants can assert rights to the Bitcoin itself, which would include all of the dollar gains the tokens have accumulated over the years. Chinese law, by contrast, caps the amount recoverable closer to the principal and interest the investors originally put in.

In this case, that gap amounts to billions of dollars — money that could end up either with the victims or in the UK Treasury. Much of that disputed sum is a product of Bitcoin's appreciation since Qian converted her customers' funds in 2017, and at roughly 61,000 BTC the stash ranks among the largest cryptocurrency seizures by any law enforcement agency.

Justice Turner reasoned that "The relevant damage occurred in China. The applicants parted with their money in China. The alleged fraudulent representations were made in China," explaining why he resolved to handle the claims under Chinese law.

The judge also stressed that his ruling does not decide who ultimately owns the Bitcoin. It does, however, raise the bar for the claimants, who must first establish ownership rights under Chinese law before a British court decides whether their claims are strong enough for the seized assets to be returned to them.

The Crown Prosecution Service, which is pursuing civil recovery of the crypto held in UK government accounts, has argued the victims can be made whole through a compensation route run from the Chinese side The dispute underscores a recurring challenge in crypto enforcement: when a fraud, its perpetrators, and the seized assets span multiple jurisdictions, more than one legal system can lay claim to the same coins, and the governing-law question alone can shift the outcome by billions.

The scheme behind the seized Bitcoin

Qian ran a wealth-management Ponzi scheme through Tianjin Lantian Gerui Electronic Technology between 2014 and 2017. Court figures cited in reports put the inflows into the scheme at about £4.1 billion. She fled to Britain in 2017 after converting customers' funds into Bitcoin and later received an 11-year sentence after admitting fraud and money laundering.

Qian's fixer, Hok Seng Ling, a 48-year-old Malaysian national living in Matlock, Derbyshire, handed the British government £5,603,305 plus £1,990 in interest, the Daily Mail reported on October 20 after a freedom-of-information request to the CPS. The confiscation sum was drawn mostly from cryptocurrency seized at his arrest. Ling, who helped launder Qian's funds and evade police by booking Airbnbs and arranging helpers, received a sentence of four years and 11 months at Southwark Crown Court.

Parallel forfeiture case in Tianjin

While the case moves through UK courts, prosecutors have made claims on the same assets in China. Shanghai outlet The Paper reported that the Tianjin Second Intermediate People's Court said on October 13 that it had accepted a September 28 application from the city's procuratorate to confiscate Qian's criminal proceeds.

The application lists 61,896.41552945 BTC, alongside Bitcoin Cash, XRP, Dogecoin, cash in multiple currencies, jewelry and investment holdings. Prosecutors say the property, seized by British authorities, represents the proceeds of a fund-raising fraud that cost more than 102,000 participants a combined RMB 19.977 billion.

The court set a six-month notice period during which affected investors can join the proceedings. That window gives the Chinese case a near-term milestone to watch, even as the UK appeal over which legal system governs the victims' claims advances separately.

The Chinese forfeiture order does not automatically override the claims process being handled by the UK courts, setting the two jurisdictions on a possible collision course over the same wallet — and leaving open which process ultimately determines where the roughly $5 billion in crypto ends up.