China’s Supreme Folks’s Procuratorate has revealed a set of suggestions that might reshape how the nation investigates and prosecutes cryptocurrency-related cash laundering, together with a proposal to deal with the usage of mixers and privateness cash as proof of legal intent.
The article, launched within the official Procuratorial Each day, was written by two prosecutors from Hunan Province’s Yuhu District and an affiliate legislation professor at Xiangtan College.
The authors argue that the decentralized, pseudonymous, and cross-border design of digital currencies has outpaced China’s authorized framework and created a three-part downside: defining the offense, gathering proof, and recovering stolen property.
On the heart of the talk is a spot between statutes. China’s Anti-Cash Laundering Regulation has dropped restrictions on which predicate offenses qualify, however Article 191 of the Felony Regulation nonetheless limits cash laundering prices to seven classes.
Consequently, most crypto instances fall below Article 312, which covers concealing legal proceeds, a cost the authors describe as a catch-all. They name for wider use of the cash laundering statute and a “one case, two checks” precept that might require investigators to search for laundering indicators in each main legal probe.
Burden shifts in China’s courts
Three proposals stand out. The primary, described as blockchain self-authentication, would deal with on-chain data from public block explorers as dependable when hash values match, and would preliminarily set up their integrity.
The second would shift the burden of proof: as soon as prosecutors submit a transaction-chain evaluation report, the protection would wish to disprove it.
The third would permit courts to presume laundering intent from conduct alone. Beneath that normal, the usage of mixers or privateness cash, the sale of huge holdings at off-market costs, or high-value transactions by nameless wallets with no clear supply would set up intent except a defendant provided an affordable rebuttal.
The authors additionally deal with proof assortment, noting that mixers, privateness cash, and decentralized exchanges permit multi-layered splitting and cross-chain transfers that conventional strategies battle to hint.
They suggest adaptive guidelines for digital information, tiered requirements of proof, and clearer authorization for technical measures resembling real-time monitoring and visitors evaluation, with limits to guard private data and cybersecurity.
Asset restoration presents an additional impediment. With crypto buying and selling banned in China, authorities maintain seized cash with no authorized channel to liquidate them.
The paper recommends a nationwide platform to retailer, worth, and eliminate confiscated property by compliant channels, together with an skilled committee that might set values utilizing on-chain information and worldwide alternate costs.
It additionally urges bilateral and multilateral agreements and a blockchain-based “judicial cooperation chain” to hint and freeze funds moved overseas.
The suggestions carry no authorized drive, however they sign a potential course for China’s courts. The proposals arrive as Chinese language-language laundering networks processed $16.15 billion in 2025, about 20% of the worldwide whole, based on Chainalysis.
In 2024, Chinese language prosecutors introduced prices in opposition to greater than 3,000 individuals in crypto-related laundering instances, a determine that underscores the size of the problem.
China’s Supreme Folks’s Procuratorate has revealed a set of suggestions that might reshape how the nation investigates and prosecutes cryptocurrency-related cash laundering, together with a proposal to deal with the usage of mixers and privateness cash as proof of legal intent.
The article, launched within the official Procuratorial Each day, was written by two prosecutors from Hunan Province’s Yuhu District and an affiliate legislation professor at Xiangtan College.
The authors argue that the decentralized, pseudonymous, and cross-border design of digital currencies has outpaced China’s authorized framework and created a three-part downside: defining the offense, gathering proof, and recovering stolen property.
On the heart of the talk is a spot between statutes. China’s Anti-Cash Laundering Regulation has dropped restrictions on which predicate offenses qualify, however Article 191 of the Felony Regulation nonetheless limits cash laundering prices to seven classes.
Consequently, most crypto instances fall below Article 312, which covers concealing legal proceeds, a cost the authors describe as a catch-all. They name for wider use of the cash laundering statute and a “one case, two checks” precept that might require investigators to search for laundering indicators in each main legal probe.
Burden shifts in China’s courts
Three proposals stand out. The primary, described as blockchain self-authentication, would deal with on-chain data from public block explorers as dependable when hash values match, and would preliminarily set up their integrity.
The second would shift the burden of proof: as soon as prosecutors submit a transaction-chain evaluation report, the protection would wish to disprove it.
The third would permit courts to presume laundering intent from conduct alone. Beneath that normal, the usage of mixers or privateness cash, the sale of huge holdings at off-market costs, or high-value transactions by nameless wallets with no clear supply would set up intent except a defendant provided an affordable rebuttal.
The authors additionally deal with proof assortment, noting that mixers, privateness cash, and decentralized exchanges permit multi-layered splitting and cross-chain transfers that conventional strategies battle to hint.
They suggest adaptive guidelines for digital information, tiered requirements of proof, and clearer authorization for technical measures resembling real-time monitoring and visitors evaluation, with limits to guard private data and cybersecurity.
Asset restoration presents an additional impediment. With crypto buying and selling banned in China, authorities maintain seized cash with no authorized channel to liquidate them.
The paper recommends a nationwide platform to retailer, worth, and eliminate confiscated property by compliant channels, together with an skilled committee that might set values utilizing on-chain information and worldwide alternate costs.
It additionally urges bilateral and multilateral agreements and a blockchain-based “judicial cooperation chain” to hint and freeze funds moved overseas.
The suggestions carry no authorized drive, however they sign a potential course for China’s courts. The proposals arrive as Chinese language-language laundering networks processed $16.15 billion in 2025, about 20% of the worldwide whole, based on Chainalysis.
In 2024, Chinese language prosecutors introduced prices in opposition to greater than 3,000 individuals in crypto-related laundering instances, a determine that underscores the size of the problem.
