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

According to information publicly released by the media and the UK Crown Prosecution Service, in March 2026, the High Court of England issued an Unexplained Wealth Order and a temporary freezing order against a Chinese citizen and the 85 London properties held under that person’s name and associated companies. The total value of the related properties exceeds 81 million pounds sterling (about RMB 738 million). However, in this proceeding, the Chinese citizen was not charged in the UK, nor convicted in the UK.

An investigation shows that this person’s real identity is Su Jiangbo, a man from Xiamen, Fujian, who is wanted domestically in connection with allegedly engaging in online gambling and running a gambling den in China for more than two years.

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 60k Bitcoins involved became one of the largest Bitcoin seizure cases in UK history, and the related assets were also subject to additional civil recovery proceedings.

Placing these two cases side by side shows that the UK has started to actively handle large sums of money by running civil recovery and criminal prosecution in parallel—processing and, as much as possible, seizing those massive assets originally originating from China but already flowing into the UK.

1 United Kingdom—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, senior officials at the UK Foreign, Commonwealth & Development Office publicly mentioned that, according to estimates, 40% of global money-laundering activity flows through the City of London and the UK’s Royal overseas territories (The Guardian, May 2024). According to estimates by the UK National Crime Agency (NCA), every year, criminal proceeds of more than 100 billion pounds sterling flow into or through the UK.

And in the real estate sector, it is precisely the UK’s most concentrated and most visible pool of parked capital. Compared with account funds and financial products, real estate is more stable and more suitable for long-term holding, nominee holding, and resale—so it has long been an important destination for all kinds of suspicious capital.

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

One key channel for dirty money to enter the London real estate market is overseas territories such as the British Virgin Islands. Research by Transparency International shows that there are 494 UK properties, with a total value of approximately £5.9 billion, that are linked to suspicious funds flowing in through UK overseas territories; and 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 poured into London’s high-end property market.

Precisely because the UK has long been an important endpoint for dirty money inflows, in recent years its law enforcement agencies have become increasingly proactive in handling unexplained large sums of assets.

2 Why Are UK Law Enforcement Agencies So Proactive in Handling Unexplained Large Sums of Money?

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

Fiscal considerations are the most realistic driving force. According to public data released by the UK Crown Prosecution Service (CPS), over the past five years, the UK has recovered £478 million in illegal assets. And in the Qian Zhimin case, the 61k-plus Bitcoins that were seized are currently worth about £5.5 billion (about RMB 50 billion).

For law enforcement agencies, the assets involved in cases like this are clearly not only “governance outcomes” in the sense of anti–money laundering, but also genuine cash asset recovery.

Institutionally, the UK has long prepared the tools for this.

Under the UK’s Proceeds of Crime Act 2002 (POCA), Part 5 establishes a civil recovery framework that allows law enforcement authorities to recover proceeds of crime through civil proceedings without criminal conviction. The Criminal Finances Act 2017 further introduced Unexplained Wealth Orders (UWO). As long as law enforcement authorities have reasonable grounds to suspect that the relevant property is demonstrably inconsistent with the lawful income of the person concerned, they can require the person to explain the source of the property. If the applicant fails to respond within the specified time without reasonable grounds, the relevant property may be presumed to be property recoverable (i.e., presumed to be proceeds of crime). If the applicant cannot provide evidence, the property will then enter the civil recovery process.

This means that cracking down on money laundering is not just “no loss,” it can also generate revenue. Against the backdrop of fiscal tightening, this is undoubtedly a win-win deal.

3 How Does the Money of Chinese Nationals Flow Out?

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

But how exactly does this money of Chinese nationals get out? This is also a high-frequency scenario that Attorney Shao encounters in handling related cases.

In recent years, Attorney Shao has handled many criminal cases involving illegal trading of foreign exchange. The individuals involved he has come across include intermediaries, foreign exchange exchange companies, “U merchants,” underground money exchanges, and so on.

From these cases, it’s also clear that the common methods of exchanging foreign currency generally include the following:

First type: Ant moving-house style.

This is the most common method for ordinary people. Operationally, it typically involves borrowing and collecting foreign exchange purchase quotas from friends and relatives, then splitting the personal annual foreign exchange purchase quota that would otherwise be restricted, and transferring the funds out in batches to overseas destinations.

Second type: Offsetting trades via underground money exchanges.

This is also one of the most common routes. The person exchanging foreign exchange deposits RMB into a designated domestic account at the underground money exchange, while overseas the money exchange arranges personnel to convert an equivalent amount of foreign currency into a specified overseas account.

Third type: Virtual currency channels.

Domestic funds first buy stablecoins such as USDT through OTC over-the-counter trading, and then through on-chain transfers, the funds are exchanged overseas into fiat currencies such as USD and GBP. This is also a relatively common category among the illegal foreign exchange trading cases Attorney Shao has handled.

Especially in scenarios where domestic funds are used for purchasing property overseas or for overseas asset allocation, they often involve cooperation with foreign exchange companies locally overseas and underground money exchanges, with the latter assisting in the landing of fiat currency.

Fourth type: Using corporate channels.

For example, methods such as fictitious trade or using “import” and “export” loans with internal guarantees. Typically, these rely on shell companies, fabricated transaction backgrounds, and coordinated operations by domestic and overseas enterprises, exporting funds that would otherwise be inconvenient to leave the country directly under the name of corporate transactions or financing.

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

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

4 Who Will Get Pulled Into This Type of Legal Risk Chain Involving Asset Seizure?

Under the entire chain of transferring funds, landing them, and holding them, behind the scenes there is often a whole set of role divisions.

First category: Asset holders

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

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

Under this mechanism, as long as the source of funds cannot be explained, the property will be confiscated. As long as the investigated person cooperates by submitting the property to UK law enforcement authorities, the investigated person will not be penalized (even if the investigated person’s conduct would be treated as a criminal offense in China). In other words, compared with conviction, law enforcement agencies care more about your money.

Taking the Song Shijie case as an example, the Anhui branch of the CSRC has imposed an administrative penalty on him for confiscating illegal gains and fining an amount equal to the fine, totaling about RMB 22.28 million. Meanwhile, the Shanghai police also filed a case for investigation due to his alleged illegal operation of securities business and money laundering. After that, the UK, based on clues and evidence provided by the Chinese side, investigated his assets in the UK. Ultimately, Song Shijie agreed to hand over seven of his properties in London and the funds in his UK bank accounts, with a total value of approximately £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 part of a joint law enforcement action by Chinese police. However, as of January 2026, the amount confiscated by China’s Anhui CSRC—RMB 22.28 million—has still not been paid.

As Caixin reported: “Song Shijie, the market manipulator that the Anhui CSRC could not reach no matter what, who also had outstanding RMB 22 million in unpaid confiscation and penalty—somehow delivered assets worth nearly RMB 200 million in settlement money for asset confiscation to the UK and the United States.”

Second category: Intermediaries

Aside from the asset holder themselves, those with higher risk include foreign exchange companies, underground money exchanges, OTC merchants, and overseas real estate brokers and agents—intermediaries who are involved.

Whether it’s purchasing property overseas or transferring funds overseas or having accounts opened and the funds landing, very often it can’t be done without the assistance of these groups.

In their own understanding, it is often simply “help exchanging currencies,” “help arrange an account,” or “help get the money landed overseas,” which looks like merely introducing others or providing intermediary services.

But from the perspective of criminal legal risk in mainland China, the group that is most likely to touch is the crime of illegally dealing in foreign exchange. And once the funds they helped transfer themselves have the attributes of criminal proceeds, there may be further risks such as money laundering and concealing or disguising the proceeds of crime.

Because in the law enforcement perspective, the intermediary introducer is a key link that makes the entire illegal foreign exchange industry chain possible.

Third category: Peripheral participants

Compared with the first two groups, peripheral participants often underestimate their own risks the most.

For example, friends and relatives help split foreign exchange deals, provide accounts, collect and pay on behalf of others, and hold shares or hold property as nominees on behalf of others. In their own understanding, they often just “help out,” “lend a card,” or “put 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 enter the criminal process from the start, but they may still face legal risks at different levels—such as risks involving foreign exchange, money laundering, and illegal business operation.

5 Risk Reminder for Those Who Send Money Overseas

From these cases, it can be seen that overseas is not necessarily a safe haven for property for many people’s imagination. In the past, a significant portion of people believed that as long as the funds were successfully transferred out of the country, and the assets successfully landed in overseas accounts, property, or other holding structures, the risk would already disappear.

Their misconception is that they believe only if they are convicted in a criminal case would their assets be at risk.

But the “cleverness” of the UK’s UWO (Unexplained Wealth Order) and civil recovery mechanism is that it allows law enforcement authorities to first “reasonably suspect” the source of wealth, and then confiscate these assets through civil proceedings, without necessarily needing to convict the person first.

Although this enforcement mechanism appears from the outside to be an anti–money laundering enforcement tool, judging by the specific outcomes of case handling, its function is more about controlling and seizing high-value assets whose source cannot be explained—without first completing criminal conviction.

In the past, Chinese people tried to figure out ways to get money out. Now, the UK tries to figure out ways to keep the money in its own pockets.