Author: Henry,Outbound Compliance Notes

On June 5th, the High Court of England held a procedural hearing regarding the asset disposal in the Qian Zhiming case, and 16,000 Chinese victims registered their claims through an international law firm alliance. This case, known as the largest Bitcoin money laundering case in the UK, originates from the illegal deposit-raising case involving Tianjin Blue Sky Gery Electronic Technology Co., Ltd.

Qian Zhiming case

From 2014 to 2017, the main suspect Qian Zhiming launched ten types of P2P financial products labeled "zero risk, high return," such as "Sky No. 1," "Sky No. 2," and "Advantageous Coin," under the name of Blue Sky Gery. Through promotion meetings and recruiting new members, she attracted public investments with high interest rates. Over four years, the funds raised exceeded 40 billion yuan, affecting nearly 130,000 people.

In July 2017, Qian Zhiming illegally crossed into Myanmar from China, traveling through Thailand, Laos, and Malaysia, finally escaping to the UK. She was arrested in April 2024, and in November 2025, she was sentenced to 11 years and 8 months.

So where did all the illicit funds go?

The answer is: Bitcoin.

Since 2014, Qian Zhiming has continuously used the illicit funds to purchase Bitcoin on “Huobi,” having bought a total of 194,951 Bitcoins at an average price of 2,815 yuan/unit (according to her defense lawyer's statistics). By the time she was sentenced, the price of Bitcoin had surged 266 times to 750,000 yuan/unit.

When the UK police arrested Qian Zhiming, her computer contained 61,000 Bitcoins.

So the next difficulty is, what is the nature of so many Bitcoins? How should they be dealt with? Who has the right to participate in the distribution? This has become an unprecedented issue in the history of judicial cooperation between China and the UK.

16,000 Chinese Victims

Currently, about 16,000 Chinese victims have entered the civil recovery process under the UK Proceeds of Crime Act. Compared to the nearly 130,000 victims in the Blue Sky Gery case, the number participating in the UK process is still less than 13%.

These investors are not fighting alone; they have gradually formed several recovery alliances composed of UK and Chinese law firms.

The firm representing the largest number is the UK boutique law firm Candey, whose corresponding Chinese partners include Yingke, Duan and Duan (Beijing), and Mankun; the large comprehensive UK firm Fieldfisher, designated by the court as the lead firm, primarily collaborates with Jiren Law Firm; the international firm Eversheds Sutherland cooperates with Jingzhi (Shenzhen) Law Firm. Additionally, teams like Debenhams Ottaway and Duan and Duan's UK office also represent hundreds of victims.

This is a rare model of cross-border collaboration.

Chinese law firms are responsible for communicating with victims, collecting evidence, and organizing materials, while UK law firms handle court appearances in the UK, submit legal opinions, and advance litigation processes.

First Discussing Legal Fees

One of the core issues discussed at the High Court hearing on June 5th was not how to distribute the assets, but how to allocate the legal fees. Since the UK court is facing thousands of victims asserting their rights simultaneously, it is necessary to first address the common legal issues faced by all applicants before gradually handling individual loss determination and asset distribution.

To avoid different legal teams duplicating resource investments, the court had previously designated Fieldfisher as the lead firm, responsible for representing all individual victims in advancing a key issue—the applicability of law. The court clarified that the legal fees incurred from this work would be considered common expenses and should be shared among the beneficiary group.

According to information disclosed in court, by the end of April, Fieldfisher had incurred approximately 190,000 pounds in this common legal issue. This amount does not represent the total cost of work, but is calculated after deducting the corresponding workload for its clients.

The ensuing dispute is: should this fee be shared according to the number of victims or based on the amount of each claim?

Some lawyers argue that if the losses claimed by victims represented by different teams vary greatly, merely averaging by number may not be fair; while others believe that calculating by amount significantly increases the costs of statistics and accounting.

Ultimately, the judge adopted a compromise solution.

Each law firm will pay their corresponding shares to the court account in proportion to the number of victims they represent, with a deadline of June 26th at 4 PM. This fund will not be paid directly to Fieldfisher, but will be temporarily held by the court until a responsibility-sharing mechanism is established.

It is worth noting that currently, some major proxy teams have litigation financing institutions involved behind them, so this initial cost is also expected to be primarily borne by the financing parties.

Determining Asset Ownership

What truly determines the direction of the case is the upcoming applicability hearing scheduled for July. The core question is: should the UK court apply Chinese law or UK law?

However, this choice may directly determine how much compensation the victims can ultimately receive. According to Chinese judicial practice, participants in illegal fundraising and the platform are usually recognized as being in a debtor-creditor relationship. Investors hold a right to request the return of funds from the platform, rather than ownership of a specific asset.

If the court adopts this perspective, even if the involved Bitcoins have significantly appreciated in value over the past few years, the scope of claims that victims can assert may still primarily revolve around the original losses.

UK law may offer another pathway. UK common law has long developed a "property tracing" doctrine. If a continuous connection can be established between an asset and the invaded funds, the rights of the original owner could extend to the new assets, even if the form of the assets has changed.

This is precisely the most highly scrutinized part of the case. Because when the Blue Sky Gery case broke out in 2017, the price of Bitcoin was far lower than it is today. After years of increases, the asset scale corresponding to 60,000 Bitcoins has reached tens of billions of dollars.

Domestic Liquidation and UK Procedures Concurrent

Meanwhile, domestic liquidation procedures are also progressing.

The Tianjin authorities had previously initiated registration and verification work for the Blue Sky Gery case liquidation. According to relevant announcements, due to the widespread involvement of regions and participants, some investors have not yet completed registration confirmation, hence the verification deadline has been extended to January 2026. The final verification results will become an important basis for subsequent fund returns.

However, several attorneys involved in the case pointed out that the domestic liquidation process and the UK's civil recovery process are independent of each other.

Even if investors have reported cases, registered, or participated in domestic liquidation, they still need to assert their claims according to the requirements of the UK court to participate in the asset distribution in the UK.

Ten years ago, the P2P scam left countless families devastated. Now, with the main suspect Qian Zhiming hiding for years finally brought to justice, how the victims will legally recover and be compensated will become an unprecedented legal challenge, as well as a landmark case in the history of judicial cooperation between China and the UK. The subsequent developments are worth noting.

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