On January 25, UK prosecutors reiterated their established position in the money laundering case involving Qian Zhimin and 60,000 bitcoins. According to publicly available information, UK authorities continue to regard the proposal submitted to the court on October 15, 2025—reserving a defined portion of assets within a civil recovery framework to enable collective compensation for a large number of Chinese victims—as the most feasible practical solution at present.
This stance indicates that the UK has not opted for a highly complex, victim-by-victim allocation approach, but instead favors an institutionalized asset reservation mechanism that leaves room for subsequent cross-border coordination.
Reserved Assets Provide an Institutional Basis for Cross-Border Cooperation
Under this arrangement, once the reserved asset amount is confirmed and approved by the court, the assets may, through cooperation between UK and Chinese law enforcement authorities, be transferred to China to facilitate the implementation of specific victim compensation plans. Any payouts would still be contingent on verification of victim identities and loss amounts, and must align with factual records already registered and confirmed by Chinese police.
This means that compensation will not be executed immediately, but will instead be carried out through coordinated administrative and legal processes across jurisdictions.
Compensation Expectations Recenter on the “Actual Loss” Principle
The UK position also sends a clear signal: compensation boundaries will be limited to victims’ verified actual losses. Given the significant appreciation in Bitcoin’s price over the years, expectations among some victims of receiving “excess compensation” derived from asset appreciation are not considered realistic under this legal pathway.
This approach reflects a clear distinction in judicial practice between loss compensation and gains from asset appreciation, and helps prevent compensation mechanisms from being amplified by market volatility.
The Practical Significance of Civil Recovery in Crypto Cases
Compared with criminal confiscation, civil recovery often offers greater flexibility in crypto cases involving large numbers of victims across multiple jurisdictions. By reserving assets and deferring distribution, authorities can secure an executable compensation pathway for victims without delaying the primary legal proceedings.
In this process, the traceability of on-chain assets serves as a critical foundation. The identification of asset origins, transaction paths, and associated addresses directly influences the court’s determination of the recoverable scope.
The Role of On-Chain Analysis in Compensation and Compliance
Cases of this nature demonstrate that, as crypto asset price volatility and cross-border mobility become more pronounced, law enforcement and judicial institutions are increasingly reliant on on-chain data. Systematic analysis of fund flows helps clarify the scale of recoverable assets and reduces the risk of disputes during subsequent distribution stages.
In industry practice, on-chain risk analysis capabilities such as those provided by Trustformer KYT are more often used to support asset tracing and association identification, offering structured references for cross-border law enforcement cooperation and compliance decision-making. As such cases continue to emerge, how to build more efficient linkages between legal procedures and on-chain facts will remain a key issue in the field of crypto-related judicial practice.