Virtual Money Judicial Disposal Raises Attention from the Supreme People's Procuratorate

Recently, the issue of judicial disposal of Virtual Money has increasingly garnered follow. Judicial authorities and local finance departments hope to liquidate seized Virtual Money to conclude cases and increase fiscal revenue. Disposal companies are also looking to gain relevant business opportunities. Even Renmin University of China has established specialized training courses on this topic.

In August 2024, the Supreme People's Court listed "Research on the Disposal of Involved Virtual Money" as a key funding project. Nearly a year later, the Supreme People's Procuratorate (referred to as "Supreme Procuratorate") also issued an announcement on the establishment of theoretical research projects for prosecutorial applications in 2025, which includes six projects related to virtual money, four of which directly involve judicial disposal. This indicates that the judicial disposal of involved virtual money has become a key focus area for the Supreme Procuratorate.

In 2025, the Supreme Procuratorate established a total of 234 research projects on prosecutorial application theory, of which 110 received funding, and 124 were self-funded. It is noteworthy that all six projects related to Virtual Money belong to the funded category.

The Supreme Court and the Supreme Procuratorate have successively focused on issues related to judicial disposal, highlighting the increasingly prominent importance of this field. However, there are still some contradictions in practice. Currently, there are no courts or procuratorates in China that directly handle the disposal of involved virtual money; the actual operations are mostly conducted by public security organs as the entrusted party.

The formation of this situation has its reasons: on the one hand, the particularity of virtual money makes court personnel lack understanding of disposal methods, while the public security department is relatively more familiar; on the other hand, existing legal provisions also provide certain space for public security organs to handle cases. The "Judicial Interpretation of the Criminal Procedure Law," "Regulations on Procedures for Public Security Organs to Handle Criminal Cases," and "Provisions on Several Issues Concerning the Implementation of the Criminal Procedure Law" and other regulations together constitute the legal basis for the current disposal model.

However, with the popularization of Virtual Money knowledge and the in-depth research on judicial disposal by various parties, the willingness of the procuratorate and the court to participate in disposal is also increasing.

Currently, the mainstream disposal model adopts a "domestic entrustment + overseas disposal" joint approach. However, regardless of the model adopted, it is essential to strictly adhere to the regulations in the 2021 "9.24 Notice" that prohibits domestic institutions from engaging in Virtual Money and fiat currency exchange business. Therefore, domestic third-party disposal institutions can only perform the role of "re-entrustment" and assist in settlement, rather than directly conducting disposal.

What really needs to be followed is the compliance of overseas disposal and cashing operations, including whether they meet local regulatory requirements and whether they have the legal qualifications for Virtual Money exchange, etc.

With the continuous research by the Supreme People's Procuratorate and the Supreme People's Court on judicial disposal, it is expected that the judicial disposal of domestic involved Virtual Money will welcome new changes in practical operations and legal guidance, and new disposal paths may emerge. The development in this field is worth following.