World’s Largest Crypto Laundering Case: 
Main Suspect Pleads Guilty — Cross-Border Justice for Chinese Victims?

This article was first published on Caixin.com on 📅 30/09/2025

On 29 September 2025, London’s Southwark Crown Court opened proceedings in what has been described as the world’s largest cryptocurrency money laundering case (R v Zhimin Qian a.k.a. Yadi Zhang & Seng Hok Ling T20240028). Expected to last 12 weeks, the trial took a dramatic turn on day one when the first defendant, Zhimin Qian, entered a guilty plea. Whether her co-defendant, Seng Hok Ling, will follow suit or contest the charges remains to be seen shortly.

With Qian’s guilty plea, a jury trial became unnecessary. The case now proceeds directly to sentencing, which the judge will determine under UK sentencing guidelines. Although she missed the chance for a materially reduced sentence through an early plea, that did not stop UK law enforcement agencies from hailing a “landmark victory” just hours later. After all, investigators seized more than 61,000 bitcoins—worth over £5 billion (around RMB 47 billion) at current prices—an unprecedented haul that even surpassed the total funds defrauded in the Tianjin Lantian Gerui Electronic Technology Co Ltd investment scam she orchestrated in China from 2014 to 2017.

For legal professionals and media in both China and the UK, the anticipated months-long courtroom battle ended before it began. But for British law enforcement, this was a defining moment. Still, behind the headline-grabbing plea, the “second half” of the battle—cross-border asset recovery—has only just begun, and it will test the limits of Sino-UK judicial cooperation. The pursuit of substantive justice is far from over.

Scope and Limits of the Guilty Plea

Qian’s guilty plea covers only two charges brought by the Crown Prosecution Service (CPS): possessing criminal property (cryptocurrency) and transferring criminal property (cryptocurrency). Under English law, these offences carry a maximum sentence of 14 years. The broader fraud scheme in China, however, remains outside the jurisdiction of the English court. Whether Qian could eventually be extradited to China—given the absence of a formal extradition treaty—would require special case-by-case arrangements, subject to both governmental and judicial scrutiny in both countries.

Even so, Qian’s conviction on money-laundering charges is settled within the UK criminal process. The focus now shifts to the civil recovery proceedings already initiated in the High Court in September 2024. In effect, her guilty plea in the UK also indirectly validates the fraud allegations in China.

The UK Path to Asset Recovery and Challenges for Chinese Victims

The CPS has made it clear that it will not pursue immediate criminal confiscation, considering the civil recovery proceedings at the High Court. The Director of Public Prosecutions (DPP) has stated they will not seek an order vesting the property in the trustee for civil recovery under s.266 of POCA until a reasonable period has elapsed so that those who claim an interest in the property can obtain legal advice and make any appropriate representations and/or applications to the High Court, including any application under s.281 of POCA.

For the tens of thousands of Chinese victims, bringing a claim under Section 281 of POCA will be an uphill battle. They must first establish a clear, traceable link between their original “investments” and the bitcoins seized in the UK—an enormously difficult task in any sophisticated cross-border money-laundering case. On top of that, inevitably, they must also count on Chinese law enforcement to furnish detailed, admissible evidence to support their claims in the High Court, something the Chinese authorities are not used to doing. That unfamiliarity, combined with deep institutional differences, makes the challenge even tougher.

“Unprecedented” Sino-UK Judicial Cooperation

Media coverage repeatedly highlighted comments from senior officials at the Metropolitan Police and CPS, who spoke of “unprecedented cooperation” with Chinese counterparts. They noted that:

• Through a meticulous investigation and unprecedented cross-border collaboration with Chinese law enforcement, compelling evidence was obtained to prove the criminal origins of the crypto assets Qian attempted to launder in the UK;
• Qian’s guilty plea reflects years of hard work across both the UK and China. The UK side offered its gratitude to law enforcement teams in Tianjin and Beijing, China, stressing that they had collaborated throughout.

Against the backdrop of longstanding Western criticism of China’s human rights record and judicial independence, this case stands out. In the past, Interpol fugitives often argued political persecution and human rights violations to block Chinese evidence from being admitted in the UK or the US. Here, however, after more than a year of disclosure and trial preparation, the fruits of Sino-UK collaboration clearly played a decisive role. While the public may never see the details, Qian’s decision to plead guilty on day one serves as indirect confirmation of that cooperation’s effectiveness.

Given the plea, Qian’s defence lawyer, Roger Sahota, abandoned the hardline not-guilty stance he had taken a year earlier. Instead, he said on Monday: “By pleading guilty today, Ms Zhang (a.k.a Qian) hopes to bring some comfort to the investors who have waited since 2017 for compensation, and to reassure them that the significant rise in cryptocurrency values means there are more than sufficient funds available to repay their losses.” The message, however, carried undertones that were open to interpretation.

For nearly 130,000 Chinese victims, the news—delivered just before China’s 8-day long National Day holiday—landed like a shot of adrenaline. Whether their misfortune stemmed from greed, naivety, or even manipulation that left them clinging to Qian’s words, many will now pin their hopes on the possibility of recovering their “investments.” Setting aside judgments about human nature, one thing is certain: China and the UK still have a “second paper” to answer in this test of judicial cooperation.

China’s Possible Response under its Criminal Law and Criminal Procedure Law?

China’s current legal framework has no equivalent to the English civil recovery regime. Whether such a mechanism should be introduced remains a matter of legislative reform and academic debate. For now, reference can only be made to existing provisions in China’s Criminal Law and Criminal Procedure Law.

Article 64 of the Criminal Law, together with Article 298 of the Criminal Procedure Law, sets out a “special procedure for the confiscation of unlawful gains.” This applies in major cases such as corruption, terrorism and other serious crimes where a suspect has absconded or died, allowing prosecutors to apply to the court for confiscation of illicit assets.

This procedure is part of the criminal process, not a civil power, and the evidentiary standard remains that of criminal law. While it differs fundamentally from the English civil recovery regime in legal basis, nature, triggers and standard of evidence, it nonetheless shares the same principle — that “stripping criminals of illicit wealth or unlawful gains”.

Qian’s case may well fit the criteria:

• She has been on China’s wanted list for over a year;
• Her arrest in the UK qualifies as “absconding”;
• Her guilty plea and the evidence disclosed in the English proceedings—particularly regarding the criminal origin, transfer and conversion of the crypto-assets—could provide strong grounds for Chinese prosecutors to launch the special confiscation procedure.

If a Chinese court were to issue a confiscation ruling and seek recognition and enforcement in the UK, it may complement the English civil recovery proceedings and pave the way for effective cross-border asset recovery.

Looking Ahead: The Second Big Test for Sino-UK Judicial Cooperation

On 29 November 2024, the UK government issued a policy paper stressing general principles to compensate overseas victims (including affected States) in bribery, corruption and economic crime cases – aiming to ensure overseas victims are able to benefit from asset recovery proceedings and compensation orders made in the UK. This provides a policy framework for cooperation with China.

Against the backdrop of globalised economic crime, where illicit funds routinely flow abroad and are “laundered” in Western markets, success in this case would represent a milestone. If China and the UK can deliver on this “second paper”, it could set a powerful precedent for cross-border asset recovery worldwide.

Qian’s guilty plea marked a high point for UK law enforcement. But for the nearly 130,000 Chinese victims, real hope lies in whether Beijing and London can see through the “second half” of asset recovery together. The toughest test of cross-border cooperation is only just beginning.