One technological setting, different legal questions
Mentioning BTC, USDT or mining does not by itself determine arbitrability or whether arbitration is suitable. A platform user’s claim, management of entrusted assets and an equipment supply arise from different legal relationships. Start with the claim, party status, agreement, legal seat and intended enforcement country. Judicial protection of a property interest is also distinct from whether a particular dispute may be referred to arbitration.
What follows is the author’s comparison of four cases. Their results belong to their respective jurisdictions and facts. Those differences do not support a single international formula permitting or prohibiting all cryptoasset disputes; each decision answers a narrower question.
Consent to arbitration and the customer’s status
In Payward v Chechetkin, the English court refused recognition and enforcement of a JAMS award on public-policy grounds associated with consumer and financial protection. Yet paragraphs 159–161 accept that the relevant issues were in principle capable of arbitration. For a platform clause, therefore, technical acceptance is only one consideration: mandatory customer protection, governing law and a real opportunity to pursue the claim also matter.
Blockstream v Innosilicon addressed a different question: which group company was bound by supply-contract clauses. The court examined delegation of jurisdictional questions, the respondent’s conduct and prior Chinese judicial review. Those facts cannot be transferred to every non-signatory. The arbitration-agreement guide supplies the general framework.
Return of assets and monetary compensation
In Gao Zheyu, the award was set aside because ordering the dollar value of BTC, converted into renminbi, supported prohibited exchange. It does not follow that return of the cryptoasset in kind would necessarily have been permitted. Blockstream used a monetary valuation of lost BTC in a commercial dispute over defective miners, while the US judicial inquiry concentrated on the respondent being bound by the clause.
A claimant should separately justify the remedy’s permissibility and the calculation: asset, quantity, valuation date, quotation source, payment currency and contractual basis for the loss. An arbitration clause does not remove restrictions in the country where the result must take effect. Comparing the two decisions identifies those questions; it does not establish a common judicial valuation method for cryptoassets.
Russian context: access to property-rights protection
Constitutional Court Resolution 2-P of 20 January 2026 concerns a state-court claim involving 1,000 USDT. For acquisition outside mining, the Court removed the reporting-related obstacle within the regulatory system examined; its interim rule requires information proving lawful acquisition and use. The reporting condition for mined currency was upheld. Classification of the disputed asset and the appropriate remedy remained for the ordinary courts.
This does not mean the Court authorised arbitration of every cryptocurrency dispute or ordered the USDT’s return. For arbitration research, it supplies a starting question about the protected property interest, separate from arbitrability and the validity of the clause.
Assessing whether a future award can withstand review
Check in sequence who agreed and in what capacity; whether the clause covers the claim; which mandatory rules remain applicable; what evidence establishes transfer, control and lawful acquisition; and why the chosen remedy is permissible. Then identify the applicable challenge procedure and actual debtor assets in the intended enforcement countries. Arbitration can offer specialist adjudication, but its advantages depend on the agreement and the ability to give the result effect.
Distinguish annulment at the seat from refusal of foreign enforcement. In Blockstream, the US court expressly lacked power to annul the Hong Kong award. The final monetary judgment followed on 13 July 2026; appeal 26-1705 was registered, but its outcome is not established by the available material. The setting-aside and refusal guide explains the distinct review mechanisms.
How courts addressed the issue
High Court of England and Wales · EWHC 1780 (Comm)Payward: arbitrability does not guarantee enforcementShenzhen Intermediate People’s Court · Guiding Case 199Gao Zheyu: the monetary value of BTC and public interestUS District Court, Southern District of New York · 25-cv-902 (CM)Blockstream: enforcing an award concerning mining equipmentConstitutional Court of Russia · Resolution 2-PRussia’s Constitutional Court: access to protection for digital-currency claimsGeneral information. The applicable legal framework depends on the particular dispute, seat and enforcement country.