China's dedicated money-laundering offense covers only seven categories of predicate crime, so prosecutors often fall back on a broader "concealment" charge to go after crypto cases, the authors note, a workaround they say has swelled into an overstretched catch-all.
Mixers as a red flagThe boldest proposals concern proof. The authors argue courts should be able to presume a suspect meant to launder money, unless the suspect “provides reasonable counter-evidence,” when they use tools designed to obscure transactions such as mixers or privacy coins, offload large amounts of crypto at “obviously unreasonable” prices, or run high-frequency, large-scale transfers through anonymous wallets with no link to their identity.
They also float a "blockchain data self-verification" principle using on-chain records that can be checked on a public block explorer, with matching hash values, would be treated as presumptively genuine, shifting the burden onto whoever disputes them. Reports from compliant blockchain analytics firms, such as fund flow maps and address clustering, would count as expert evidence, and laundering could be established from circumstantial, fragmentary evidence as long as it forms a coherent chain, even if not every coin is traced to its source.
The seized-coin problemThe third piece addresses what China should do with crypto once it seizes it. Because Beijing bans trading, authorities that confiscate tokens have no clean legal way to cash them out, leaving billions of dollars in limbo.
