The UK has started to make efforts to seize Chinese people's overseas assets.

Byline: Attorney Shao Shiwei

According to information publicly disclosed by the media and the UK’s Crown Prosecution Service, in March 2026 the English High Court issued unexplained wealth orders and interim freezing orders against a Chinese citizen and its associated companies for 85 London properties. The total value of the relevant properties exceeded £81 million (about RMB 738 million). However, in this proceeding, that Chinese citizen was neither charged in the UK nor convicted in the UK.

The investigation shows that the person’s real identity is Su Jiangbo, a man from Xiamen, Fujian who has been wanted domestically in China for more than two years for allegedly engaging in online gambling and operating casinos.

Seeing this news, it’s hard not to think of the Qian Zhimin case. In November 2025, Qian Zhimin was sentenced in the UK to 11 years and 8 months for money laundering-related crimes. The more than 60,000 bitcoins involved in the case became one of the largest-scale bitcoin seizure cases in the UK to date, with the related assets also handled through subsequent civil recovery proceedings.

Taken together, these two cases show that the UK has begun to actively use a parallel approach of civil recovery and criminal prosecution to deal with—and, as much as possible—confiscate those huge sums of money that originally came from China but had already flowed into the UK.

1 The UK—The preferred destination for dirty money worldwide

The UK, especially London, has long been viewed by outsiders as the “preferred destination for dirty money worldwide.”

In May 2024, a senior official at the UK’s Foreign, Commonwealth & Development Office publicly mentioned that, according to estimates, 40% of global money laundering activities flow through the City of London and the UK’s Crown Dependencies (The Guardian, May 2024). According to the UK’s National Crime Agency (NCA) estimate, criminal proceeds exceeding £100 billion a year are generated through or flow into the UK.

And in the real estate sector, it is precisely the place where the UK’s most concentrated and most visible funds are deposited. Compared with funds in accounts and financial products, real estate is more stable and more suitable for long-term holding, nominee holding, and resale; therefore, it has long been an important destination for all kinds of suspicious funds to be deposited.

According to data from Transparency International UK, between 2016 and 2022, at least £6.7 billion worth of UK real estate was purchased with suspicious wealth.

One key channel for dirty money to enter London’s real estate market is overseas jurisdictions such as the British Virgin Islands. Research by Transparency International shows that there are 494 UK properties, with a total value of about £5.9 billion, that are linked to suspicious funds flowing in through UK overseas jurisdictions; among them, more than 90% of the funds came from the British Virgin Islands.

Reports by organizations such as Transparency International have repeatedly pointed out that large amounts of illegal funds from countries including Russia, China, and Nigeria have flowed into London’s high-end property market.

Because the UK has long been an important landing place for dirty money, in recent years its law enforcement agencies have become increasingly proactive in dealing with large amounts of unexplained wealth.

2 Why are the UK law enforcement agencies so proactive in dealing with large amounts of unexplained wealth?

Is this enforcement shift merely an upgrade in governance driven by anti–money laundering pressure? Obviously not.

Financial factors are the most realistic driving force. According to publicly disclosed data from the Crown Prosecution Service (CPS), over the past five years the UK has recovered £478 million in illegal assets. Meanwhile, the 61,000 bitcoins seized in the Qian Zhimin case are currently worth about £5.5 billion (about RMB 50 billion).

For enforcement authorities, the value reflected by cases like these is clearly not only a “governance outcome” in the sense of anti–money laundering, but also genuine asset recovery.

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

Under the UK’s Proceeds of Crime Act 2002 (POCA), Part 5 establishes a civil recovery regime, allowing enforcement authorities to recover proceeds of crime through civil proceedings without a criminal conviction. The Criminal Finances Act 2017 further introduced unexplained wealth orders (UWO). As long as enforcement authorities have reasonable grounds to suspect that the relevant property is materially inconsistent with the lawful income of the person concerned, they can require an explanation of the property’s source. If the respondent fails to respond within the prescribed time without reasonable grounds, the relevant property may be presumed to be recoverable property (i.e., presumed to be proceeds of crime). If the respondent cannot provide evidence, the property will then enter the civil recovery procedure.

This means that combating money laundering not only doesn’t lose money—it can also generate revenue. Against the backdrop of fiscal tightening, this is undoubtedly a “win-win” proposition.

3 How does the money of Chinese people flow out?

At bottom, the reason the UK is able to target these assets is that the money has already been transferred out of the country.

But how exactly does Chinese people’s money go out? This is also a high-frequency scenario that Attorney Shao encountered when handling related cases.

In recent years, Attorney Shao has handled many criminal cases involving illegal buying and selling of foreign exchange. Among the people involved he has come into contact with are intermediaries, exchange companies, “U traders,” underground banks, and the like.

From these cases, we can also see that the common foreign-exchange exchange methods are roughly as follows:

First, the “ant relocation” approach.

This is the most common method for ordinary people. In practice, it usually involves borrowing or collecting foreign-exchange purchase quotas from relatives and friends, splitting up the personal annual foreign-exchange purchase quotas that would otherwise be subject to restrictions, and then transferring the funds in batches out of the country.

Second, “matching deals” through underground banks.

This is also one of the most common routes. The person exchanging foreign currency transfers RMB into the designated onshore account specified by the underground bank; offshore, the bank arranges personnel to convert an equivalent amount of foreign currency into a designated overseas account.

Third, a virtual-currency channel.

Onshore funds first buy stablecoins such as USDT through OTC over-the-counter transactions, and then, via on-chain transfers, are exchanged overseas into fiat currencies such as US dollars and British pounds. This is also a relatively common type among the illegal buying and selling of foreign exchange cases Attorney Shao has handled.

Especially in scenarios where onshore funds are used for purchasing overseas property or asset allocation overseas, they are often used in combination with overseas local foreign-exchange companies and underground banks, with the latter assisting in the “landing” of fiat currency.

Fourth, using corporate channels.

For example, through methods such as fictitious trade and inbound guarantees with outbound loans, it typically uses shell companies, fabricated transaction backgrounds, and cooperation between onshore and offshore companies to move funds out—funds that would otherwise be inconvenient to transfer directly out—under the guise of corporate transactions or financing.

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

Money sent out through these methods is then “laundered” again via overseas purchases of property, shareholding, opening accounts, and other steps, making the already hard-to-explain source of funds even more difficult to account for.

4 Who will get pulled into this legal-risk chain of asset seizure?

Throughout the entire chain of fund transfer, landing, and holding, there is often a whole set of role division behind the scenes.

First category: asset holders

The person who transfers the assets themselves is naturally the most direct target. For example, Qian Zhimin is a typical case.

But in Attorney Shao’s view, under civil recovery mechanisms such as the UWO, the rather ironic point is:

Under this mechanism, as long as the source of the funds cannot be explained, the property will be confiscated. As long as the investigated person cooperates by handing over the property to UK law enforcement authorities, the investigated person will not be punished (even if the investigated person’s conduct is viewed as a criminal offense in China)—that is to say, compared with conviction, law enforcement cares more about your money.

For example, in the Song Shijie case, the Anhui Securities Regulatory Bureau has already issued an administrative penalty against him, confiscating illegal gains and imposing a fine equal to the same amount, totaling about 22.28 million yuan. At the same time, the Shanghai police also filed a case for investigation into his alleged illegal operation of securities business and money laundering. Afterwards, based on tips and evidence provided by Chinese authorities, the UK authorities investigated his assets in the UK. In the end, Song Shijie agreed to hand over seven of his London properties and the funds held in his UK bank accounts, with a total value of about £16.7 million (about RMB 160 million).

Through this settlement, Song Shijie avoided criminal charges he might have faced in the UK.

This case was a joint law-enforcement action by Chinese police. However, as of January 2026, the forfeiture payments of 22.28 million yuan imposed by the Anhui Securities Regulatory Bureau of China have still not been paid.

As Caixin pointed out: “Song Shijie, the market manipulator whom the Anhui Securities Regulatory Bureau tried every possible way to reach but still couldn’t, and who has been in arrears with a forfeiture payment of 22 million yuan—actually handed over to the UK and the United States assets and settlement money totaling nearly 200 million yuan.”

Second category: intermediaries

Apart from the asset holders themselves, those with higher risk are intermediaries such as foreign-exchange companies, underground banks, OTC merchants, and overseas real estate brokers.

Whether it’s buying property overseas, transferring funds out, or landing funds into accounts, many times you cannot do without the assistance of such groups.

In their own understanding, they often are only “helping exchange foreign currency,” “helping arrange an account,” or “helping get the payment landed overseas,” and it looks like they are only introducing someone or providing intermediary services.

However, from the perspective of criminal-law risks in Mainland China, the offense that this group is most likely to touch is the crime of illegal operation related to the buying and selling of foreign exchange; and once the funds they assist in transferring themselves have the attribute of criminal proceeds, it may further involve risks such as money laundering and concealing or disguising proceeds of crime.

Because from an enforcement perspective, intermediaries are a key link that makes the entire illegal foreign-exchange industry chain viable.

Third category: peripheral participants

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

For example, friends and relatives help split up foreign-exchange exchanges, provide accounts, receive and make payments on someone’s behalf, hold shares as nominees, and hold property as nominees; in their own understanding, it is often just helping out, lending a card, or putting a name on it for nominee holding.

But these actions are also important components in the entire chain of asset transfer, landing, and concealment.

This group may not necessarily enter the criminal procedure at the outset, but they may still face legal risks at different levels regarding foreign exchange, money laundering, illegal operation, and the like.

5 Risk warnings for those sending money overseas

Through these cases, it can be seen that overseas is not the “safe haven” for property that many people imagine. In the past, a considerable number of people thought that as long as the funds successfully transferred out of the country and the assets successfully landed in overseas accounts, property, or other holding structures, the risk would already have disappeared.

The misconception of these people is that only if they are criminally convicted would their property be at risk.

But the “cleverness” of the UK’s UWO (unexplained wealth orders) and civil recovery mechanism lies in the fact that it allows law enforcement authorities to first have a “reasonable suspicion” about the source of the wealth, and then confiscate these assets through civil procedures, without necessarily needing to criminally convict the person first.

Although this enforcement mechanism, in appearance, is an anti–money laundering enforcement tool, based on the concrete outcomes in the handled cases, its function is more about—without first completing a criminal conviction—controlling and taking into their own possession high-value assets whose sources cannot be explained.

In the past, Chinese people tried to find ways to get the money out. Now, the UK is trying to find ways to keep the money in its own pocket.