In this article, we analyse and compare the feasibility and respective advantages and disadvantages of two potential paths for achieving collective compensation in the Lantian Gerui case: one dominated by UK judicial proceedings and the other dominated by administrative mechanisms (including government negotiations and mutual legal assistance). We consider that although a UK judicially-led path offers procedural transparency and formal fairness, it also entails significant risks, including limited access to evidence, duplicative verification of Chinese victims’ identities and losses, procedural inefficiency, and the potential preclusive effect of judicial res judicata. By contrast, an administrative path may enhance the Chinese side’s ability to shape the process and outcome, leverage existing Chinese judicial findings to improve efficiency, and reduce the costs and burdens associated with cross-border claims; however, such a path is likewise subject to uncertainties arising from bilateral relations and other international political factors. We take the view that the Chinese side should not passively follow the path predetermined by the UK, but should, within the limited time window available, proactively assess the overall implications of each option and explore whether alternative paths may better serve the collective interests of the Chinese victims.

In this article, we conduct an analytical assessment of the highly scrutinized s.281 rights protection path under the UK POCA in the Lantian Gerui case. It must be noted that, if successful, the s.281 rights protection path can exclude the relevant Bitcoin assets from the UK civil recovery proceedings and secure all appreciation benefits of the Bitcoin assets; however, its premise is that victims must satisfy the highly stringent evidentiary burden of establishing a “traceable proprietary interest,” and must also bear significant litigation costs and the risk of adverse costs if unsuccessful.

Cross-Border Enforcement Guideline - Quebec Province, Canada

The estate dispute concerning the late founder of the Wahaha Group, Zong Qinghou, has drawn widespread attention recently. On 1 August 2025, the Court of First Instance, the High Court of Hong Kong Special Administrative Region, delivered a judgment in case Jacky Zong v Kelly Fuli Zong [2025] HKCFI 3355, providing important reference for interim relief measures in cross-border disputes between the Mainland of China and Hong Kong.

Cross-border Enforcement Guideline - New York State, USA

On 21 May 2025, the Court of Appeal of the High Court of Hong Kong handed down a judgment in Court of Appeal Civil Appeal No. 118, 119, 120 and 121 of 2024 and held that the “Execution Ruling” (执行裁定书）issued by the Mainland court based on the “Execution Certificate” (执行证书） issued by the notary office in Mainland of China was not a registrable Mainland judgment under the Mainland Judgments (Reciprocal Enforcement) Ordinance (Cap. 597) (“MJREO”). Consequently, the creditor was unable to register the “Execution Ruling” (执行裁定书）through the statutory registration mechanism in the Hong Kong court.