According to public information from the media and the British Crown Prosecution Service, in March 2026, the British High Court issued an unidentified wealth order and a temporary freezing order against 85 London properties owned by a Chinese citizen and his affiliated companies. The total value of the relevant properties exceeded 81 million pounds (approximately RMB 738 million). However, in this procedure, the Chinese citizen was not prosecuted by the UK, nor was he convicted by the UK.

Investigation revealed that this person's true identity is Su Jiangbo, a man from Xiamen, Fujian Province who has been wanted for more than two years in China for engaging in online gambling and opening casinos.

Seeing this news, it is difficult not to think of the Qian Zhimin case. In November 2025, Qian Zhimin was sentenced to 11 years and 8 months in the UK for money laundering-related crimes. The more than 60,000 Bitcoins involved became one of the largest Bitcoin seizure cases in the history of the UK, and the related assets are also in civil recovery proceedings.

Putting these two cases together, it can be seen that the UK has begun to actively usecivil recovery and criminal prosecution in parallel to process and collect as much as possible the huge amounts of property that originally originated from China but has flowed into the UK.

1 UK - the world's top destination for dirty money

The United Kingdom, especially London, has long been regarded by the outside world as"the world's preferred destination for dirty money."

In May 2024, senior British Foreign Office officials publicly mentioned that an estimated 40% of the world's money launderingflows through the City of London and the British Crown Dependencies (The Guardian, May 2024). The National Crime Agency (NCA) estimates that more than £100 billion of criminal proceeds pass through or flow into the UK every year.

The real estate sector is the most concentrated and conspicuous capital sink in the UK. Compared with account funds and financial products, real estate is more stable and more suitable for long-term holding, holding on behalf of others and changing hands. Therefore, it has always been an important destination for the accumulation of various types of suspicious funds.

At least £6.7bn of UK property was purchased with questionable wealth between 2016 and 2022, according to Transparency International UK.

A key channel for dirty money to enter the London property market is overseas territories such as the British Virgin Islands. Research by Transparency International shows that a total of 494 British properties, with a total value of approximately 5.9 billion pounds, are related to suspicious funds flowing through British overseas territories, of which more than 90% come from the British Virgin Islands.

Reports from organizations such as Transparency International have repeatedly pointed out that a large amount of illegal funds from Russia, China, Nigeria and other countries have poured into London's high-end real estate market.

Because the UK has long been an important destination for the inflow of dirty money, in recent years its law enforcement agencies have become increasingly active in handling huge amounts of property of unknown origin.

2 Why are British law enforcement agencies so aggressive in dealing with huge amounts of property of unknown origin?

Is this enforcement change simply a governance upgrade under anti-money laundering pressure? Apparently not.

Financial factors are the most realistic driving force. According to public data from the British Crown Prosecution Service (CPS), the UK has recovered 478 million pounds of illegal assets in the past five years. The 61,000 Bitcoins seized in the Qian Zhimin case are currently worth about 5.5 billion pounds (about 50 billion yuan).

For law enforcement agencies, this type of case obviously corresponds not only to "governance results" in the sense of anti-money laundering, but also to the asset recovery of real money.

From an institutional perspective, the UK has already prepared the tools for this.

According to the UK's Proceeds of Crime Act 2002 (POCA), Part 5 of it establishes a civil recovery system, allowing law enforcement agencies to recover criminal proceeds through civil procedures without a criminal conviction. The "Criminal Finance Law 2017" further introduces the Unknown Wealth Order (UWO). As long as the law enforcement agency has reasonable grounds to suspect that the relevant property is obviously inconsistent with the legal income of the party, it can require the party to explain the source of the property; if the respondent fails to respond within the prescribed period without reasonable reasons, the relevant property may be presumed to be recoverable property (that is, presumed to be proceeds of crime). If the respondent is unable to provide evidence, the property will subsequently enter civil recovery procedures.

This means that combating money launderingnot only does not lose money, but also generates income. In the context of fiscal austerity, this is undoubtedly a good deal that “kills two birds with one stone”.

3 How does Chinese people’s money flow out?

In the final analysis, the reason why the UK can focus on these assets is that the money has been transferred out of the country.

But how do Chinese people get their money out? This is also a high-frequency scenario that Lawyer Shao encounters when handling related cases.

In recent years, Lawyer Shao has represented many cases involving criminal offenses due to illegal trading of foreign exchange. The people involved in the cases he has contacted include intermediaries, currency exchange companies, U-commerce merchants, underground banks, etc.

It can also be seen from these cases that the common methods of currency exchange are roughly as follows:

The first type, ants move.

This is the most common way for ordinary people. The operation usually involves borrowing and collecting foreign exchange purchase quotas from relatives and friends, breaking up the personal annual foreign exchange purchase quota that should have been restricted, and then transferring the funds out of the country in batches.

The second type is underground bank competition.

This is also one of the most common paths. The currency exchanger transfers RMB into the domestic account designated by the underground bank, and overseas, the bank arranges personnel to transfer the equivalent value of foreign currency to the designated overseas account.

The third type is virtual currency channel.

Domestic funds first buy stablecoins such as USDT through OTC transactions, and then transfer them on the chain to convert them into legal currencies such as US dollars and pounds sterling overseas. This is also a relatively common type of illegal foreign exchange trading cases represented by Lawyer Shao.

Especially in scenarios where domestic funds are used to purchase houses overseas and allocate assets overseas, they are often used in conjunction with local overseas currency exchange companies and underground banks, with the latter assisting in the implementation of legal currency.

The fourth method is to use corporate channels.

For example, false trade, domestic guarantees and overseas loans, etc. usually rely on shell companies, fictitious transaction backgrounds, and the cooperation of domestic and foreign enterprises to transfer funds that are originally inconvenient to leave the country directly in the name of corporate transactions or financing.

These different illegal currency exchange routes actually face the same potential risks:

The money sent out through this method is then "cleaned" by purchasing houses, holding shares, and opening accounts overseas, which makes the originally unclear source of funds even more difficult to explain.

4 Who will be involved in the legal risk chain of such asset seizure?

Under the entire chain of fund transfer, landing, and holding, there is often a complete set of role divisions behind it.

Category 1: Asset Holders

The person transferring the assets is of course the most direct target. Qian Zhimin, for example, is a typical example.

But in Lawyer Shao's view, the ironic point under civil recovery mechanisms such as UWO is:

Under this mechanism, as long as the source of funds cannot be explained, the property will be confiscated; as long as the property is handed over to the British law enforcement agencies, the person under investigation will not be punished (even if the behavior of the person under investigation is considered a criminal offense in our country) - in other words, Law enforcement agencies care more about your money than conviction.

Take Song Shijie's case as an example. The Anhui Securities Regulatory Bureau has confiscated his illegal gains and imposed an equal fine, totaling an administrative penalty of approximately 22.28 million yuan. At the same time, the Shanghai police have also opened an investigation into his suspected illegal securities business and money laundering. Since then, the British side has launched an investigation into its assets in the UK based on clues and evidence provided by China. In the end, Song Shijie agreed to hand over seven of his properties in London and the funds in his British bank account, with a total value of approximately 16.7 million pounds (approximately 160 million yuan).

Through this settlement, Song Shijie avoided possible criminal charges in the UK.

This case is a joint law enforcement action by the Chinese police, but as of January 2026, the fine and confiscation of 22.28 million yuan against the China Anhui Securities Regulatory Bureau has not been paid.

As the Caixin report pointed out: "Song Shijie, a market manipulator who was unable to contact the Anhui Securities Regulatory Bureau in every possible way and owed 22 million yuan in fines and confiscations to the state treasury, actually handed over nearly 200 million yuan in asset forfeiture settlement funds to the United Kingdom and the United States"

Category 2: Intermediary Facilitator

In addition to the asset holders themselves, those with higher risks are intermediary participants such as currency exchange companies, underground banks, OTC merchants, and overseas real estate agencies.

Whether it is buying a house overseas, transferring funds, or opening an account, it is often impossible to do without the assistance of this group of people.

In their own understanding, they often just "help to change the exchange rate", "help to arrange the account", "help to transfer the money overseas", it seems that they just help to introduce or provide intermediary services.

However, from the perspective of criminal legal risks in mainland China, this group is most likely to be involved in illegal business crimes such as illegal trading of foreign exchange; and once the funds they assist in transferring have the attribute of criminal proceeds, they may further involve risks such as money laundering and concealment of criminal proceeds.

Because from the perspective of law enforcement, the intermediary is a key link in the establishment of the entire illegal currency exchange industry chain.

The third category: peripheral participants

Compared to the first two types of people, peripheral participants are often the most likely to underestimate their own risks.

For example, relatives and friends help with currency exchange, providing accounts, collection and payment, holding shares, and real estate. In their own understanding, they often just do a favor, borrow a card, and hold it under their name.

But these behaviors are also an important part of the entire asset transfer, landing, and concealment chain.

This type of group may not necessarily enter criminal proceedings from the beginning, but they may still face different levels of legal risks related to foreign exchange, money laundering, illegal operations, etc.

5 Risk tips for those who invest overseas

It can be seen from these cases that overseas is not the safe haven for property that many people imagine. In the past, quite a few people believed that as long as funds were successfully transferred out of the country and assets were successfully placed in overseas accounts, real estate or other holding structures, the risk would have disappeared.

The misunderstanding of these people is that they believe that their property will be at risk only if they are criminally convicted.

But the "brilliant" thing about the UWO (Unknown Wealth Order) and civil recovery (civil recovery) mechanisms in the UK is that it allows law enforcement agencies to first have "reasonable doubts" about the source of the wealth, and then confiscate the property through civil procedures, without necessarily having to convict the person first.

Although this law enforcement mechanism appears to be an anti-money laundering law enforcement method, judging from the specific case handling results, its function is to control and take possession of high-value assets whose sources are unclear without first completing a criminal conviction.

In the past, the Chinese were trying to get money out, but now the British are trying to keep money in their pockets.