Authors: Huang Wenjing, He Weiyi
Introduction
As global anti-money laundering standards tighten and China’s new Anti-Money Laundering Law takes effect, cryptocurrency-related crimes have evolved to exhibit characteristics of high frequency, high value, and high concealment. From early fake trading platforms to today’s on-chain phishing and fragmented money laundering schemes enabled by smart contracts, victims not only face asset losses but also struggle with information asymmetry in seeking redress and difficulties in gathering evidence.
However, in judicial practice, victims commonly face a core challenge: although they know the funds are still on the blockchain, they struggle to prompt public security authorities to carry out asset freezes, seizures, and disposals. This is often due to incomplete evidence, unclear reporting descriptions, and insufficient communication and cooperation, leading to missed opportunities for timely investigation.
This article, combining the latest judicial practices and technical methods, aims to provide victims with a clear and actionable roadmap to help break through the deadlock in recovery efforts.
The possibility of on-chain asset tracking
First point: How does the law view your cryptocurrency losses?
It depends on the nature of the matter.
- If it is a general investment or trading dispute and you believe the project team has failed to fulfill its obligations, the court is likely to consider this a risk you assumed yourself, making it difficult to recover your funds.
- But if you were scammed, hacked, or robbed, it’s entirely different. Current judicial practice has clearly established that cryptocurrencies are legally recognized as valuable "property." Therefore, public security organs are obligated to open an investigation, and legally seize and confiscate these illicit gains to return them to the victims.
Second point: If technology can track it, why don't the police freeze it immediately?
Blockchain transaction records are publicly accessible, but this does not mean law enforcement can take immediate action.
The police must have clear evidence proving that “these funds were directly stolen from the victim and transferred to this specific address or account.” Due to the anonymity of cryptocurrencies and criminals’ rapid fund transfers—such as using cross-chain bridges or mixing tools—the first few hours up to 48 hours after reporting are critical. If the chain of evidence is unclear or incomplete, law enforcement cannot effectively investigate.
Third: The key to success lies in the "firsthand evidence" you provide.
To advance the case and successfully freeze assets, the quality of the evidence you submit is critical. Especially when dealing with offshore platforms or complex transfer pathways, screenshots of chat conversations alone are far from sufficient.
A set of evidence materials clearly addressing the following issues is required:
- Identity verification: Who are you, and who is the other party?
- Behavioral proof: How did the other party deceive or steal from you? What was the complete sequence of events?
- Proof of funds: Where did your funds come from, and to which blockchain address were they transferred?
- Technical analysis: (if possible) show the subsequent flow of funds to prove where they ultimately went.
Simply put, the more professional and clear your preparation, the faster and more successful the police operation will be!
Build a systematic chain of evidence: from identity anchoring to fund flows
To help you report effectively and prompt police action, you need to prepare a clear and compelling set of evidence. This evidence can be organized and understood across four levels:
Step 1: Prove “who you are” and “where your funds come from”
This is where everything begins. You need to prove to the police that:
1. Your real identity (ID card).
2. The legitimate source of your invested funds. This includes:
Your original transaction records from bank card, Alipay, or WeChat Pay used to purchase cryptocurrency. This proves that your funds are legitimate.
Your account information on the centralized exchange (such as UID, screenshots of identity verification, and bound phone number). This proves that these asset accounts belong to you and serves as the basis for future fund reimbursement.
Step 2: Fully and accurately reconstruct "How was the money transferred out?"
This is the most critical technical evidence—it cannot rely solely on screenshots. For each transferred fund, you must compile the following “three-piece set” of information:
1. Transaction Hash (TxID): This is the unique "ID number" of this transaction on the blockchain.
2. Wallet Address: The address for sending and receiving funds.
3. Exact time and amount:
Organize this information into a clear table, along with links to the blockchain explorers where the data was verified. This will allow law enforcement and tracing experts to easily follow the fund flow.
Step 3: Prove that the other party’s activity is “not a legitimate transaction, but criminal!”
This is to help law enforcement accurately classify the incident as fraud or theft, rather than a simple investment loss. You need to gather evidence demonstrating fraudulent behavior by the platform or individual, such as:
- Websites and promotional materials of fraudulent platforms.
- Screenshots of chat records and community trading signals where the other party promised "principal-guaranteed high returns."
- If your account is accessed by someone unauthorized (e.g., unexpectedly compromised), proactively contact the exchange to obtain records of unusual logins, IP addresses, or large transaction risk control reports. This can effectively refute claims that “you made a mistake.”
Step 4: Provide a professional "fund flow chart" highlighting key exit points.
When funds have undergone complex transfers, such as multiple transactions or coin mixing, a fund flow analysis report issued by a professional institution is essential. This report transforms chaotic transaction records into a clear “fund path map” and achieves two key objectives:
1. Track the destination: Clearly identify which platform or address your funds ultimately went to.
2. Identify the leverage point: If the funds ultimately flow into a centralized exchange requiring identity verification, law enforcement can use this report to quickly issue legal documentation to the exchange, demanding the freezing of the relevant accounts. This is a crucial step in recovering the assets.
The core of the report lies in identifying the final "exit point" of the assets. If the funds ultimately flow into centralized exchanges requiring KYC verification, or into a known black-market OTC money-laundering pool, law enforcement agencies can use this information to issue investigation requests to the exchanges or implement emergency fund freezes.
Practical Communication Skills: How to Communicate Effectively with Law Enforcement Agencies
How clearly and professionally you state the case when reporting it directly affects the police’s assessment and subsequent actions. The key lies in three points:
First point: Accurately state the nature of the case:
Don't simply say, "I was scammed" or "I lost money on my investment." The police need to clearly determine whether this constitutes a criminal offense rather than a routine economic dispute. You can express it like this:
- I fell victim to a cryptocurrency scam (or theft/unauthorized fundraising). The party involved was not a legitimate counterparty but instead transferred my assets through a fraudulent platform (or phishing link/unauthorized access to my account).
This can directly prompt the police to handle the matter according to criminal case procedures.
Second: Clearly outline the fund flow:
Clearly state the key information in the shortest possible terms. Help law enforcement quickly grasp the essentials using this template:
- My funds were transferred from my real-name-verified account at [XX Bank/Alipay] to my account on [XX Exchange] (e.g., Huobi), exchanged for [USDT], and then transferred on [Month/Day, Time:Minute] to the wallet address provided by the suspect. Preliminary tracking shows that these assets have since flowed to [XX overseas exchange/some well-known money laundering address pool], and they are still traceable.
This will immediately make it clear to law enforcement: the asset flow is traceable, conditions for investigation are likely met, and the situation is urgent.
Third: Proactively offer actionable solutions.
Law enforcement may not be familiar with blockchain operations; you can proactively provide clear instructions to assist them in performing the steps quickly and facilitate swift progress.
- Submit the Asset Freeze Recommendation: Prepare a written submission detailing the specific cryptocurrencies, wallet addresses, current platforms (if applicable), and estimated values to be frozen. This will significantly reduce the time required for law enforcement to verify the information.
- Inquire about technical support channels: In many regions, local police have partnered with professional blockchain security firms. You may politely ask: “Would you like us to contact a professional technical firm to provide a fund flow analysis report or assist in preparing legal documents?” or “Do you require us to issue an official technical assistance letter?”
Asset Disposition and Liquidity: Judicial Trends in 2026
Asset freezing does not mean the pursuit of justice is over; what victims care about most is the "disposition and return of assets," which is crucial. The subsequent process primarily involves the following three key steps:
First: How can assets be legally converted into cash?
In the past, privately selling coins through informal channels carried high risks. Now, more standardized pathways are available: for example, pilot programs have begun in Beijing and other areas, where police entrust officially designated compliant institutions—such as the Beijing Property Exchange—to conduct public auctions for asset disposal.
- You need to pay attention: Ensure the cash-out process is transparent and compliant, so that the funds ultimately returned to your account are legitimate local currency (CNY). This fundamentally avoids the risk of your funds being frozen again after they are returned.
Second: What fees will be deducted upon refund?
During the disposal process, necessary third-party service fees, such as technical analysis and asset custody, may be incurred.
- Please note: With the assistance of a lawyer, verify whether these fees are reasonable and whether the deduction percentages are transparent. Ensure that your refund amount is clearly traceable to avoid unnecessary asset loss during the disposal process.
Third: What if the money flows overseas?
For funds that have been transferred to overseas exchanges or addresses, international cooperation mechanisms may still be available:
- Core strategy: Encourage law enforcement agencies to issue a wanted notice through INTERPOL, or contact stablecoin issuers (such as Tether, the issuer of USDT) to request that the relevant wallet addresses be added to a blacklist.
- Once successful, the USDT in these addresses will be globally frozen and cannot be transferred, buying us valuable time for subsequent legal recovery efforts.
Mankin's summary: The core of recovering your funds lies in "legal monetization, transparent restitution, and leveraging international mechanisms to track and block assets." Understanding these pathways can help you better cooperate with law enforcement and legal counsel to ensure your assets are safely and maximally returned to you.
Conclusion
Enforcing rights in the cryptocurrency space is a prolonged battle against time and technology. In today’s legal environment, victims can no longer passively wait; instead, they must act as “first movers in evidence collection” and “providers of technical expertise,” proactively building a robust chain of evidence and establishing professional communication mechanisms.
Remember: The earlier you intervene, the more detailed the evidence, and the more professional your communication, the higher the likelihood of asset recovery. Cryptocurrencies are not an untouchable lawless domain—they are a transparent ledger where every detail leaves a trace.
Checklist
1. Basic Identity and Account Documentation
- Victim identification documents
- Bank account information (for deposits / withdrawals)
- Exchange account registration information (UID, bound phone number, email)
- Platform identity verification screenshot
2. Fund Flow and On-Chain Evidence
For each involved transfer:
- Transaction Hash (TxID)
- Wallet address (send / receive)
- Transfer timestamp
- Currency and Amount
- Full-page screenshot of the blockchain explorer (including the URL)
- Failed or blocked transfers (if any)
- Apply for a timestamp or notarization certificate from a third-party platform (such as an evidence preservation platform).
- If the wallet supports on-chain signing, you can export records of signing operations to prove ownership.
3. Platform and Behavioral Evidence
- Screenshot of the investment platform page (yield promises, terms and conditions)
- Customer service chat log
- Group chat and operational commitment screenshots
- Abnormal activity logs (such as login records, IP address logs, unauthorized transfer records, or unusually large transfers deviating from typical behavior provided by the trading platform or wallet)
4. Fund Analysis and Technical Report
- On-chain tracking path diagram
- Multi-address clustering analysis explanation
- Final destination of funds judgment (exchange / mixer / cross-chain bridge)
- Explanation of the involved amount and cryptocurrency price calculation (with specified time point)
5. Freeze Recommendation
- Cryptocurrency
- Wallet address
- Current valuation
- Related exchanges
- Explanation of Freeze Urgency
6. Key Supervision Focuses During the Disposal Phase
When the court decides to dispose of virtual currency, the victim and their attorney should pay close attention to:
- Is the cash-out platform compliant and licensed?
- Does it comply with foreign exchange management requirements?
- Are the disposal fees reasonable?
- Is the return path closed?
- Is the victim reimbursement ratio transparent?
