2,000 Ether Accepted at Once, Worth Up to RMB 60 Million: Why Crypto Bribes Can’t Stay Hidden in China

The short answer

• A state functionary who uses their position to accept bitcoin, ether or other cryptocurrency and benefits someone in return can commit bribery. China does not recognise crypto as currency and treats related transactions as illegal financial activity, but that doesn’t mean it has no property value; in criminal law it can still be counted as “property” in the bribe amount.
• The bribe amount is generally converted at the market price at the time of receipt, though actual sale proceeds are sometimes used; the authorities decide on the evidence (lawyer’s summary, not statutory text).
• Receiving crypto is not safe: on-chain transfers are public, and investigators can now use blockchain analysis to reconstruct the full chain from briber to recipient and corroborate it with digital forensics.
• Once coins become cash, a house or gold, they leave traces in the real world; using other people’s accounts or registering assets in relatives’ names does not stop them being found to be bribe proceeds, and they remain subject to recovery.
• Converting or transferring coins to conceal their origin may separately constitute money laundering: predicate offences under Article 191 of the Criminal Law include corruption and bribery, judicial interpretation confirms “self-laundering” can be separately convicted, and transferring proceeds through “virtual asset” transactions is listed as a laundering method.

Is accepting cryptocurrency bribery?

Yes. The test is essentially the same as accepting cash or a house.

Article 385 of the Criminal Law: “A state functionary who takes advantage of their position to solicit property from another, or illegally accepts another’s property and seeks benefits for them, commits the crime of accepting bribes.”

The key word is “property”. Article 12 of the Supreme People’s Court and Supreme People’s Procuratorate Interpretation on Several Issues Concerning the Application of Law in Handling Criminal Cases of Embezzlement and Bribery (法释〔2016〕9号): “‘Property’ in bribery offences includes money, goods and property interests. Property interests include material benefits that can be converted into money, such as home renovation or debt forgiveness, and other benefits that require payment, such as membership services or travel.”

Cryptocurrency isn’t on that list. My summary: in judicial practice, mainstream cryptocurrencies such as bitcoin and ether are generally considered to have property value because they can be converted into money on overseas platforms, and so can be the object of a bribe. Two things should be distinguished here — since 2021 China has made clear that crypto-related business activities are illegal financial activities and does not recognise crypto as currency; but “not currency” and “no property value” are different matters. The former governs whether it can be lawfully traded in China; the latter decides whether it counts in a bribe amount.

How is the amount calculated: how much RMB is 2,000 ether?

The amount directly determines the sentence. Under 法释〔2016〕9号, a bribe of RMB 30,000 to under 200,000 is “relatively large”, 200,000 to under 3 million is “huge”, and 3 million or more is “especially huge”. Bribery is punished under Articles 386 and 383 of the Criminal Law; for especially huge amounts, the penalty is 10 years or more in prison or life imprisonment, plus a fine or confiscation of property.

The difficulty with crypto is valuation: overseas prices fluctuate, and “market price when received” and “peak market value” can differ several times over. My summary: in practice investigators tend to convert at the market price when received, and for portions already sold may use the actual proceeds; local judgments are not fully uniform, and the authorities decide on the evidence. So “peak value of RMB 60 million” is an assessment figure, not necessarily the bribe amount in a judgment.

The Yao Qian case: how a villa worth over RMB 20 million “developed the picture”

The following facts come from public disclosure in the documentary Technology Empowering Anti-Corruption, jointly produced by the publicity department of the Central Commission for Discipline Inspection / National Supervisory Commission and China Media Group, released on 14 January 2026:

• Yao Qian, former director of the Science and Technology Supervision Department and the Information Centre of the China Securities Regulatory Commission, and former head of the People’s Bank of China’s Digital Currency Research Institute, was placed under investigation in April 2024, expelled from the Party and public office that November, and transferred to prosecutors.
• In 2018, a crypto businessman surnamed Zhang asked Yao, through Yao’s subordinate Jiang Guoqing, to help with a token-issuance fundraising project. Yao put in a word with a crypto exchange, which helped the token issue succeed and raise 20,000 ether; Zhang then gave Yao 2,000 ether as thanks, whose assessed market value at one point exceeded RMB 60 million.
• In 2021, Yao transferred out 370 ether and exchanged them for RMB 10 million.
• That RMB 10 million, plus two other sums totalling RMB 12 million, was used to pay for a villa in Beijing costing more than RMB 20 million, registered in the name of one of Yao’s relatives but actually owned by Yao.
• Investigators found a hardware wallet in a drawer in Yao’s office and used blockchain analysis to reconstruct the 2018 transfer of 2,000 ether from the briber’s wallet to Yao’s wallet, and the 2021 transfer of 370 ether exchanged for RMB 10 million.

The official summary was blunt: crypto that is never cashed out is just a string of numbers, but once virtual assets become real assets they are easily exposed; the villa was the “developer fluid” that revealed Yao.

Why turning coins into cash and property is the biggest giveaway

• On-chain anonymity only hides “who is operating”, not “whose pocket the money ends up in”. A hardware wallet and seed phrase can hide private keys, but converting to RMB inevitably creates counterparties, bank records and timestamps.
• Big-ticket spending stands out most. A villa worth over RMB 20 million, luxury cars and gold are matched transaction by transaction when tracing funds.
• “Shell accounts” and nominee holdings don’t change the nature. Opening accounts in other people’s names or registering assets to relatives is a routine breakthrough point for big-data cross-checking; if it can be shown the person actually controls the asset and the money came from bribes, it will still be identified and recovered.
• Recovery has no expiry discount. Article 64 of the Criminal Law: “All property illegally obtained by a criminal shall be recovered or compensation ordered; lawful property of victims shall be returned promptly.” Article 18 of 法释〔2016〕9号 adds that illegal gains shall be recovered or compensation ordered, and recovery continues for anything not yet recovered.

Why cashing out after accepting coins can add a money-laundering charge

Article 191 of the Criminal Law (excerpt): “Whoever, in order to conceal or disguise the source and nature of proceeds and gains from drug crimes, organised-crime offences, terrorist offences, smuggling, corruption and bribery, crimes undermining financial management order, or financial fraud, commits any of the following acts … (2) converting property into cash, financial instruments or securities; (3) transferring funds by transfer or other payment and settlement methods; … (5) concealing or disguising the source and nature of criminal proceeds and gains by other means.”

Note two points: first, corruption and bribery are on the list of predicate offences, so bribe proceeds can be the object of money laundering; second, Article 1 of the Supreme People’s Court and Supreme People’s Procuratorate Interpretation on Money Laundering Cases (法释〔2024〕10号) makes clear that laundering to conceal the proceeds of one’s own predicate offence is punished under Article 191 — so-called “self-laundering” can be separately convicted; and Article 5(1)(6) lists “transferring or converting criminal proceeds through ‘virtual asset’ transactions or financial asset exchanges” as concealment “by other means”.

My summary: “laundering” crypto bribes through OTC exchanges or cross-border transfers may lead to a separate money-laundering conviction in addition to bribery; whether the offences are punished cumulatively depends on whether the acts were independent and intended to conceal.

Practical reminders for two groups

For crypto practitioners and project teams: asking a state functionary to put in a word, helping your project and then giving thanks makes the briber liable too; intermediaries who introduce, pass on requests or handle the transfer (like the subordinate Jiang Guoqing in this case) may be treated as accomplices to bribery or prosecuted for introducing bribes.

For state functionaries and their families: accepting, holding on someone’s behalf or cashing out crypto are all within the scope of recovery; switching to hardware wallets, overseas accounts or property in relatives’ names only adds more points of exposure without changing the nature of the assets. If it comes to that, under Article 383(3) of the Criminal Law, truthful confession, sincere remorse and active return of the proceeds remain the realistic path to a lighter or mitigated sentence.

What is unverified, and limitations

The case facts come from the documentary content publicly released by discipline-inspection authorities, i.e. the official account; I have not seen a published judgment in the Yao Qian case, and the final conviction and sentence are subject to an effective judgment. The valuation basis for crypto bribes (market price when received or sale proceeds) is not yet uniform across courts; the related statements are the lawyer’s summary, not statutory text.

This is a general overview of crypto bribery and not legal advice on any particular case. If you or someone close to you is dealing with crypto, duty crimes or recovery of crypto-related funds, contact Wang Xin: phone +86 186-0113-9509, WeChat wang223040.

This is an English edition of Wang Xin’s original Chinese article, 一次收下2000枚以太币，市值最高6000万：虚拟货币受贿为什么藏不住？. It explains the law of the People’s Republic of China in general terms and is not legal advice for any particular case; outcomes depend on the specific facts and on how local authorities apply the rules.