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OTC Checklist
Transactions for the Disposal of Crypto Assets Seized by the Chinese Government
  1. OTC transactions involving seized cryptocurrencies are fully legal and compliant. See separate documentation for details.
  1. Assets are disposed of on a case-by-case basis. Each case must receive a final court judgment in its local jurisdiction before the associated cryptocurrencies‘ disposal can be processed.
  1. The composition and amount of crypto assets in each case wallet vary. Wallets may contain Bitcoin, Ethereum, and various altcoins.
  1. The judicial appraisal price is based on the total USDT-convertible value of all cryptocurrencies in the wallet. The real-time price lock is defined in the signed purchase agreement.
  1. Foreign individuals and institutions must first register and submit KYC, it’s form shall be forwarded. It takes approximately 10 working days to determine whitelist eligibility.
  1. Once whitelisted, overseas buyers must sign a commission framework agreement with the Hong Kong-based agent Global Digital Assets Consulting Limited, which applies to all future transactions.
  1. The Chinese state treasury must receive no less than 80% of the judicially assessed value in foreign exchange.
  1. Therefore, the maximum judicial discount margin is 20%. In some cases, the discount may be less than 10%, depending on wallet composition, as appraised and communicated by the licensed company Digital Asset Disposal (Horgos) Co., Ltd.
  1. Buyers will receive the wallet's full asset list in advance and may choose whether to participate after being invited to an OTC transaction in mainland China. Payment must be made in fiat foreign currency. Further details available upon request.
  1. Distribution of the discount margin in judicial transactions: to be specified upon request.

Note: Most past transactions have followed this distribution model. Attempts to alter the structure have typically caused deals’ failure.
11. Chinese nationals who engaged in crypto activities before 2018 while residing in China — even if they have since obtained foreign citizenship and cannot return to China — are not advised to participate in such OTC transactions, whether or not they are aware of any existing official records or cases against them.
12. Do not use third-party bank accounts to wire payments.
Always use your own account that has passed KYC and AML screening. Violations may expose you to significant legal and transactional risks.
Global Digital Assets Consulting Limited May 2025
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