A Legal Distinction, Not a Verdict, Holds $5.1 Billion in Bitcoin

The UK government holds 61,245 Bitcoin seized from devices in London in 2018. At current prices the stash is worth approximately $5.1 billion. On October 12, 2026, Mr Justice Mark Turner issued a ruling in civil recovery proceedings holding that Chinese law applies to decide whether victims of Ponzi schemes run by Zhimin Qian in China between 2014 and 2017 have rights to that Bitcoin.

The ruling is a choice-of-law decision, not a final ownership verdict. Victims' lawyers had argued for English law, or a combination of English and Chinese law. Prosecutors argued for Chinese law. The court sided with prosecutors on which law governs. Lawyers for investors are reportedly pursuing an appeal.

What follows is narrower than either side's preferred outcome. Under Chinese law, victims must establish a proprietary interest in the Bitcoin, not a mere creditor's claim. A proprietary interest would attach to the specific assets; a creditor's claim would rank as an unsecured debt against whatever remains. If victims cannot prove the former, the UK government keeps the assets and all appreciation since seizure. The $5.1 billion figure is not a pot the court has awarded to anyone. It is the current market value of property whose legal owner remains undetermined.

The case tests how courts treat seized cryptocurrency when victims of foreign fraud seek recovery, and whether appreciation in seized assets goes to victims or the state. The choice-of-law ruling could shape international asset recovery and cryptocurrency regulation.

A parallel case shows a different risk in the same system. Paul Chowles, 44, from Bristol, a former National Crime Agency officer, was jailed for five and a half years at Liverpool Crown Court after pleading guilty to theft and money laundering for stealing about 50 Bitcoin seized during an NCA investigation. A confiscation order requires him to repay £1.8 million, equal to the value of 30 Bitcoin recovered from him, which had ballooned from £36,000.

That case concerns insider theft from a seizure, not the ownership question now before the High Court. But it illustrates the same underlying problem: seized crypto sits somewhere between evidence, state property, and contested restitution, and the rules for handling it are still being written.

For the 61,245 Bitcoin, the fight now shifts to what victims can prove under Chinese law. Whether the government retains the $5.1 billion, or victims establish a proprietary interest, depends on evidence not yet tested. The reported appeal may also reopen the choice-of-law question before any ownership determination is reached.