China's Supreme People's Procuratorate published an article titled "Systematically Resolving the Dilemmas in Criminal Law Regulation of Money Laundering Using Virtual Currency"

According to a report by Procuratorial Daily, researchers from the Yuhu District People's Procuratorate of Xiangtan City, Hunan Province, and the Faculty of Law of Xiangtan University have co-authored an article proposing a systematic solution to the regulatory dilemmas in criminal law for money laundering crimes involving virtual currencies. The article notes that current judicial practice faces three core challenges: behavioral characterization, evidence collection, and recovery of illicit funds and loss compensation. First, Article 191 of China’s Criminal Law, which defines the crime of money laundering, still limits predicate offenses to seven categories, leading to a large number of cases being charged only with the crime of concealing and disguising criminal proceeds. Second, tools such as mixers, privacy coins, and cross-chain transfers fragment the evidence chain, making it difficult for traditional investigation methods to trace the source. Third, conflicts in the legal status of virtual currencies, gaps in procedural rules, and cross-border cooperation barriers hinder the enforcement of illicit fund recovery. In response, the authors put forward targeted suggestions: For the behavioral characterization dilemma, shift from passive identification to active review at the judicial level, and activate the guiding function of procuratorial supervision and assessment standards at the supervisory level. For the evidence verification dilemma, establish adaptive authentication and review standards for electronic evidence, build a tiered standard of proof and reasonable presumption rules, and explore the authorization and standardized application of technical investigation measures. For the illicit fund recovery and loss compensation dilemma, establish a national-level cross-departmental collaborative disposal mechanism, and actively participate in and lead the construction of international rules and cooperation platforms.