2030 Hindsight on 2025: The Year Wall Street Took Over Bitcoin

By: blockbeats|2025/03/07 11:45:03
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Original Title: "2030 Retrospective on 2025: The Year Wall Street Officially Took Over Bitcoin"
Original Author: Daii, Airdrop Reference Founder

2030 Hindsight on 2025: The Year Wall Street Took Over Bitcoin

One day in 2030, when BlackRock's Bitcoin ETF's AUM surpassed that of the S&P 500 index fund, Wall Street traders suddenly realized: the thing that they once mocked as a "dark web toy" now held the global capital by the throat.

But all the turning point started in 2025 — the year when the price of Bitcoin surged past $250,000 amidst the institutional whale hunting, yet no one could clearly say who it belonged to anymore. On-chain data showed that over 63% of the circulating supply was locked in institutional custody addresses, and Bitcoin exchange liquidity dried up to only support three days of trading volume.

The above is a fantasy; let us return to the present for now.

A substantial amount of funds continues to flow out from Bitcoin ETFs, causing Bitcoin to briefly drop below $80,000. The explanation for this phenomenon mainly revolves around two aspects:

1. From a policy perspective, it was due to the U.S.-China trade war initiated by Trump;

2. From a fund perspective, it was because 56% of short-term holders — hedge funds — closed their arbitrage positions.

However, analysts believe that the current Bitcoin bull market is in the "distribution phase."

The "distribution phase" of a Bitcoin bull market usually refers to the late stage before and after the price peak, where whales gradually sell off their chips, transferring Bitcoin from early holders to new market entrants. This phase signifies the market transitioning from a frenzy of upward movement to the top area and is a crucial juncture for the bull-bear shift.

No more suspense; let's give the answer first: the current market liquidity structure has changed.

· OG retail and OG whales are playing the role of sellers;

· Institutional whales and new retail entrants through ETFs are becoming the main buyers.

In the cryptocurrency field, "OG" is an abbreviation for "Original Gangster" (and is also often interpreted as "Old Guard"), specifically referring to the earliest participants, pioneers, or long-standing core group in the Bitcoin space.

In short, old money is exiting, and new money is entering. Among the new money, institutions are dominant.

Next, we will provide you with a detailed analysis from the perspectives of market structure, current cycle characteristics, roles of institutions and retail investors, cycle timeline, and more.

1. Typical Market Structure: Whale Distribution to Retail at the End of a Bull Market

A typical Bitcoin bull market at the end phase exhibits a pattern where whales distribute chips to retail investors, meaning early large holders sell coins to latecomer retail investors at high prices.

In other words, retail investors often buy at high prices in a euphoric atmosphere, while the "smart money" whales take the opportunity to sell in batches at the peak, realizing profits. This process has played out multiple times in historical cycles:

For example, as the 2017 bull market approached its peak, the Bitcoin balance held by whales saw a net decrease, indicating a significant amount of chips moved away from whale hands. This was because at the time, there was a massive influx of new demand into the market, providing enough liquidity for whales to distribute their holdings, as detailed in: The Shrimp Supply Sink: Revisiting the Distribution of Bitcoin Supply.

Overall, the market structure at the end of a traditional bull market can be summarized as follows: early holders progressively sell off, increasing market supply, while retail investors buy in large quantities driven by FOMO (Fear Of Missing Out) sentiment. This distribution behavior often comes with signs such as increased Bitcoin inflows to exchanges, movement of old coins on-chain, foreshadowing the market is about to peak and reverse.

2. Characteristics of This Bull Market Cycle: Structural New Changes

The distribution phase of the current bull market cycle (2023-2025) differs from the past, especially in the behaviors of retail and institutional investors.

2.1 Unprecedented Institutional Participation in This Cycle

The introduction of Bitcoin spot ETFs and the aggressive Bitcoin purchases by publicly traded companies have made the market participants more diverse, no longer solely driven by retail investors. The entry of institutional funds has brought a deeper pool of capital and more stable demand, directly reflected in the reduced market volatility compared to the past — analysis shows that the maximum drawdown of the current bull market is significantly smaller than in previous cycles, with peak retracements typically not exceeding 25%-30%. This is attributed to the intervention of institutional funds stabilizing volatility.

At the same time, market maturity has increased, with each cycle seeing a diminishing price increase, leading to a more stable trend. This can also be observed from indicators such as the growth rate of the realized cap: this cycle's realized cap has only expanded a small portion of the previous peak, indicating that the frenzy has not yet fully unleashed (see: Thinking Ahead).

Realized Cap is a key metric to measure the market's capital inflow situation. Unlike the traditional Market Cap, Realized Cap is not simply the current price multiplied by the circulating supply, but considers the price of each Bitcoin at its last on-chain transaction. Therefore, it better reflects the actual scale of funds invested in the market.

Of course, the above indicators may also indicate that the market is entering a more mature and stable development stage.

2.2 Retail Investors' Behavior in This Round is Also More Rational and Diverse

On the one hand, experienced retail investors (individual investors who have experienced multiple market cycles) are relatively cautious, taking profits earlier after a certain price increase, which is different from the past when retail investors chased the price all the way to the top.

For example, data from early 2025 shows that small holders (retail investors) net transferred approximately 6,000 BTC (about $6.25 billion) to exchanges in January, starting to cash out early, while during the same period, whales only marginally net increased by about 1,000 BTC, essentially staying put. This divergence indicates that many retail investors believe it's a phase of a peak, choosing to take profits, while whales (seen as "smart money") remain on hold, apparently expecting a higher profit margin.

On the other hand, the enthusiasm of new retail investors is still accumulating. Indicators such as Google Trends indicate that public attention temporarily dropped after the price reached a new high and "reset," without reaching the peak of mass hysteria seen in the late stages of past cycles. This suggests that the current bull market may not have entered the final frenzy stage yet, with remaining upside potential in the market.

2.3 Institutional Investors' Behavior Has Become a Key Feature of This Bull Market

The previous bull market of 2020-2021 was the first time a large number of institutions and publicly traded companies entered the market, leading to an increase in whale holdings—a phenomenon where institutions and other new "whales" bought large amounts, causing Bitcoin to flow from retail hands to these whale accounts.

This trend has continued in the current cycle: large institutions are heavily buying Bitcoin through channels such as OTC markets, trust funds, or ETFs, making traditional whales no longer net sellers, to some extent delaying the distribution phase's arrival. This has made the distribution of this bull market more gradual and decentralized, rather than the previous pattern where retail investors were the only buyers: the market's depth and breadth have increased, and new funds are sufficient to absorb the chips sold by long-term holders.

A Glassnode report points out that a significant amount of wealth has already transferred or is transferring from long-term holders to new investors, marking a sign of maturity in the Bitcoin market—long-term holders have realized record profits (up to $21 billion in a single day), and new investors have enough demand to absorb these sell-offs, see Bitcoin sees wealth shift from long-term holders to new investors – Glassnode.

It is evident that in this bull market, the interaction between retail investors and institutions has created a more resilient market environment.

3. Evolution of Roles: Institutional and Retail Investors' Impact on Liquidity

As the market participant structure evolves, the roles of institutions and retail investors in the allocation phase have also undergone significant changes.

CryptoQuant CEO Ki Young Ju summarized the current allocation pattern as follows: "OG Retail" (Original Gangster Retail) + existing whales → new retail investors (through ETFs, MSTR, and other channels) + new whales (institutions).

In other words, retail investors and whales who experienced the early stages of the cycle are gradually selling off, and the party stepping in to buy includes not only traditional retail investors but also ordinary investors entering through investment vehicles like ETFs and institutions acting as whale entities.

This diversified participation pattern is starkly different from the traditional "whale → retail" linear distribution model.

· In this cycle, OG Retail (early entrant individual holders) may hold a significant amount of Bitcoin. They choose to cash out and exit at the peak of the bull market, providing some selling pressure and liquidity to the market.

· Similarly, OG whales (early large holders) will also gradually sell off to realize profits multiple times over. In response, institutional whales as new buying forces absorb this selling pressure massively. They buy through custody accounts and ETFs, with Bitcoin flowing from old wallets to these institutions' custody wallets.

· Furthermore, some traditional retail investors now indirectly hold Bitcoin through ETFs and publicly traded company stocks (such as MicroStrategy's stock), representing a new form of "retail buying the dip."

This role transition has had a profound impact on market liquidity and price trends.

3.1 More Bitcoin Moving Off Exchanges

On one hand, the selling behavior of OG holders usually leaves significant on-chain footprints: increased activity in old wallets, large transfers flowing to exchanges, and more.

For example, in this bull market, it has been observed that some long-dormant wallets have become active, moving coins to exchanges in preparation for sale, indicating that old holders are starting to distribute chips. Ki Young Ju pointed out that the activities of OG players are reflected through on-chain and exchange data, whereas the movement of "paper Bitcoins" (such as ETF shares, Bitcoin-related stocks) is only reflected in custody wallet on-chain records during settlement. In other words, institutional fund buying often occurs off-exchange or through custody, with direct on-chain reflections being the increase in balance of custody addresses, rather than direct exchange movements as with traditional exchanges.

The current exchange's Bitcoin balance is 2.22 million coins, which is also a reflection of this characteristic.

3.2 New Whales, New Retail Investors Show More Resilience

On the other hand, institutional investors, as newly emerged whales, not only provide massive buying support but also enhance the market's resilience to sell pressure and liquidity depth.

Unlike the panic selling often seen during retail-dominated periods in the past, institutional funds tend to buy the dip and hold for the long term. When the market experiences a pullback, the intervention of these professional funds often helps stabilize the price. For example, some analysis attributes the reduced volatility of this bull market to institutional participation: when retail investors sell, institutions are willing to buy to ensure market liquidity, resulting in much smaller price retracements.

Although the launch of Bitcoin ETFs has brought significant incremental funds to the market, some ETF holders (such as hedge funds) may primarily engage in arbitrage trading, leading to higher fund liquidity. Recent outflows of ETF funds indicate that some institutional funds are only engaging in short-term arbitrage rather than holding long term. The recent drop in Bitcoin below $80,000 faced selling pressure from hedge funds closing out arbitrage positions.

However, newly entered retail investors have shown strong resilience, not panic selling at each adjustment but willing to continue holding, with Bitcoin's short-term holder metric showing greater resistance to price drops.

Overall, the interaction between OG retail investors + OG whales and new institutional whales + new retail investors has formed the unique supply-demand pattern in the current market: early holders provide liquidity, while institutions and new buyers absorb chips, making the distribution process in the later stages of the bull market smoother and more traceable.

4. Market Cycle Timeline: Historical Trends and Prospects for This Bull Market

From historical data, the Bitcoin market demonstrates a roughly four-year cycle, each containing a full cycle of bear market - bull market - transition. This is highly related to the Bitcoin block reward halving event: after the halving, new coin issuance sharply decreases, followed by a roughly 12-18 month period of a significant price surge (bull market), and then entering a bear market correction near the peak.

4.1 History

Looking back at the timeline of several major bull markets:

· The first halving occurred at the end of 2012, and the Bitcoin price peaked in December 2013, about 13 months later;

· The second halving in 2016, with the bull market peak near $20,000 in December 2017, about 18 months later;

· In May 2020, during the third halving, Bitcoin experienced a double peak near $70,000 at two high points (April and November) around 17-18 months later by the end of 2021.

Based on this, it is speculated that the fourth halving in April 2024 may trigger a new bull market, with the peak likely to occur approximately one to one and a half years after the halving, around the second half of 2025, ushering in the final distribution phase (end of the bull market).

Of course, cycles do not mechanically repeat, and changes in market conditions and participant structure may affect the duration and peak of this bull market.

4.2 Optimistic

Some analysts believe that the macro environment, regulatory policies, and market maturity will have a significant impact on this cycle.

For example, Grayscale's research team pointed out in a late 2024 report that the current market is only in the mid-term stage of a new cycle. If the fundamentals (user adoption, macro environment, etc.) remain strong, the bull market may extend into 2025 or even longer. They emphasize that the newly introduced spot Bitcoin ETF has broadened the channels for fund inflows, and the clarity of the future U.S. regulatory environment (such as the potential impact of the Trump administration) may further boost the crypto market valuation.

This means that this bull market is expected to be longer than previous cycles, and the upward trend may extend beyond the traditional time window.

On the other hand, there is also on-chain data supporting the view of a longer bull market. For example, the current cycle's Realized Cap has not yet reached half of the peak of the previous cycle, indicating that the market's enthusiasm has not been fully released. Some analysts therefore predict that the final peak of this bull market may far exceed the previous cycle, with peak expectations commonly raised to $150,000 or even higher.

4.3 Conservative

However, some opinions suggest that the peak will occur within 2025.

For instance, CryptoQuant's Ki Young Ju predicts that the final distribution phase of the Bitcoin bull market (various OG holders and institutions concentrating on selling to the final buyers) will take place within the year 2025. His assessment is based on the early distribution phase already entered and the observed influx of new retail funds, believing that it is not necessary to switch to a bearish view prematurely before the final distribution is completed.

Combining historical patterns and current indicators, it can be speculated that this bull market will most likely enter its final stages in the second half of 2025 when, as prices reach a phase peak, various holders will accelerate chip distribution to complete the final distribution process.

Of course, the precise timing and magnitude are difficult to predict, but based on the cycle length (around 1.5 years post-halving) and market signs (retail frenzy level, institutional fund flows, etc.), 2025 may become a key year.

Conclusion

As Bitcoin evolves from a geeky toy to a trillion-dollar strategic asset, this bull market cycle may reveal a harsh truth: the essence of financial revolution is not to eliminate old money but to reconstruct the genetic chain of global capital with new rules.

The current "distribution phase" is indeed the coronation ceremony of Wall Street formally taking over the crypto world. When OG whales hand over their chips to BlackRocks, this is not the prelude to a collapse but the march of restructuring the global capital landscape—Bitcoin is transforming from retail's myth of sudden wealth to the "digital strategic reserve" on institutional balance sheets.

The most ironic part is that while retail investors are still calculating their "exit scam passwords," firms like BlackRock have already included Bitcoin in their 2030 balance sheet template.

The ultimate question of 2025: is this the peak of a cyclical cycle or the birth pangs of a new financial order? The answer lies in the icy blockchain data—each outflow from an OG wallet is contributing to the custodial addresses of BlackRocks; each ETF's net inflow is redefining the notion of "value storage."

For investors navigating through the cycle, here is a piece of advice: the greatest risk is not missing out but interpreting the rules of 2025 with the cognition of 2017. When "holding addresses" turn into "institutional custody accounts," when the "halving narrative" becomes a derivative of the Federal Reserve interest rate decisions, this century's handover has transcended the bull-bear dichotomy—

History tends to repeat itself, but this time, what takes the stage is not retail tears but the incessant chain of institutional treasury on-chain transfers.

This trend towards institutionalization can perhaps be likened to the evolution of the Web 1.0 era—where the internet, originally belonging to geeks, ultimately fell into the hands of FAANG (Facebook, Apple, Amazon, Netflix, and Google) giants.

History's cyclical nature is always brimming with dark humor.

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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk


Foreword: Today, the People's Bank of China's website published the "Notice of the People's Bank of China, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration for Market Regulation, China Banking and Insurance Regulatory Commission, China Securities Regulatory Commission, State Administration of Foreign Exchange on Further Preventing and Dealing with Risks Related to Virtual Currency and Others (Yinfa [2026] No. 42)", the latest regulatory requirements from the eight departments including the central bank, which are basically consistent with the regulatory requirements of recent years. The main focus of the regulation is on speculative activities such as virtual currency trading, exchanges, ICOs, overseas platform services, and this time, regulatory oversight of RWA has been added, explicitly prohibiting RWA tokenization, stablecoins (especially those pegged to the RMB). The following is the full text:


To the people's governments of all provinces, autonomous regions, and municipalities directly under the Central Government, the Xinjiang Production and Construction Corps:


  Recently, there have been speculative activities related to virtual currency and Real-World Assets (RWA) tokenization, disrupting the economic and financial order and jeopardizing the property security of the people. In order to further prevent and address the risks related to virtual currency and Real-World Assets tokenization, effectively safeguard national security and social stability, in accordance with the "Law of the People's Republic of China on the People's Bank of China," "Law of the People's Republic of China on Commercial Banks," "Securities Law of the People's Republic of China," "Law of the People's Republic of China on Securities Investment Funds," "Law of the People's Republic of China on Futures and Derivatives," "Cybersecurity Law of the People's Republic of China," "Regulations of the People's Republic of China on the Administration of Renminbi," "Regulations on Prevention and Disposal of Illegal Fundraising," "Regulations of the People's Republic of China on Foreign Exchange Administration," "Telecommunications Regulations of the People's Republic of China," and other provisions, after reaching consensus with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, and with the approval of the State Council, the relevant matters are notified as follows:


  I. Clarify the essential attributes of virtual currency, Real-World Assets tokenization, and related business activities


  (I) Virtual currency does not possess the legal status equivalent to fiat currency. Virtual currencies such as Bitcoin, Ether, Tether, etc., have the main characteristics of being issued by non-monetary authorities, using encryption technology and distributed ledger or similar technology, existing in digital form, etc. They do not have legal tender status, should not and cannot be circulated and used as currency in the market.


  The business activities related to virtual currency are classified as illegal financial activities. The exchange of fiat currency and virtual currency within the territory, exchange of virtual currencies, acting as a central counterparty in buying and selling virtual currencies, providing information intermediary and pricing services for virtual currency transactions, token issuance financing, and trading of virtual currency-related financial products, etc., fall under illegal financial activities, such as suspected illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures business, illegal fundraising, etc., are strictly prohibited across the board and resolutely banned in accordance with the law. Overseas entities and individuals are not allowed to provide virtual currency-related services to domestic entities in any form.


  A stablecoin pegged to a fiat currency indirectly fulfills some functions of the fiat currency in circulation. Without the consent of relevant authorities in accordance with the law and regulations, any domestic or foreign entity or individual is not allowed to issue a RMB-pegged stablecoin overseas.


(II)Tokenization of Real-World Assets refers to the use of encryption technology and distributed ledger or similar technologies to transform ownership rights, income rights, etc., of assets into tokens (tokens) or other interests or bond certificates with token (token) characteristics, and carry out issuance and trading activities.


  Engaging in the tokenization of real-world assets domestically, as well as providing related intermediary, information technology services, etc., which are suspected of illegal issuance of token vouchers, unauthorized public offering of securities, illegal operation of securities and futures business, illegal fundraising, and other illegal financial activities, shall be prohibited; except for relevant business activities carried out with the approval of the competent authorities in accordance with the law and regulations and relying on specific financial infrastructures. Overseas entities and individuals are not allowed to illegally provide services related to the tokenization of real-world assets to domestic entities in any form.


  II. Sound Work Mechanism


  (III) Inter-agency Coordination. The People's Bank of China, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of virtual currency-related illegal financial activities.


  The China Securities Regulatory Commission, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of illegal financial activities related to the tokenization of real-world assets.


  (IV) Strengthening Local Implementation. The people's governments at the provincial level are overall responsible for the prevention and disposal of risks related to virtual currencies and the tokenization of real-world assets in their respective administrative regions. The specific leading department is the local financial regulatory department, with participation from branches and dispatched institutions of the State Council's financial regulatory department, telecommunications regulators, public security, market supervision, and other departments, in coordination with cyberspace departments, courts, and procuratorates, to improve the normalization of the work mechanism, effectively connect with the relevant work mechanisms of central departments, form a cooperative and coordinated working pattern between central and local governments, effectively prevent and properly handle risks related to virtual currencies and the tokenization of real-world assets, and maintain economic and financial order and social stability.


  III. Strengthened Risk Monitoring, Prevention, and Disposal


  (5) Enhanced Risk Monitoring. The People's Bank of China, China Securities Regulatory Commission, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration of Foreign Exchange, Cyberspace Administration of China, and other departments continue to improve monitoring techniques and system support, enhance cross-departmental data analysis and sharing, establish sound information sharing and cross-validation mechanisms, promptly grasp the risk situation of activities related to virtual currency and real-world asset tokenization. Local governments at all levels give full play to the role of local monitoring and early warning mechanisms. Local financial regulatory authorities, together with branches and agencies of the State Council's financial regulatory authorities, as well as departments of cyberspace and public security, ensure effective connection between online monitoring, offline investigation, and fund tracking, efficiently and accurately identify activities related to virtual currency and real-world asset tokenization, promptly share risk information, improve early warning information dissemination, verification, and rapid response mechanisms.


  (6) Strengthened Oversight of Financial Institutions, Intermediaries, and Technology Service Providers. Financial institutions (including non-bank payment institutions) are prohibited from providing account opening, fund transfer, and clearing services for virtual currency-related business activities, issuing and selling financial products related to virtual currency, including virtual currency and related financial products in the scope of collateral, conducting insurance business related to virtual currency, or including virtual currency in the scope of insurance liability. Financial institutions (including non-bank payment institutions) are prohibited from providing custody, clearing, and settlement services for unauthorized real-world asset tokenization-related business and related financial products. Relevant intermediary institutions and information technology service providers are prohibited from providing intermediary, technical, or other services for unauthorized real-world asset tokenization-related businesses and related financial products.


  (7) Enhanced Management of Internet Information Content and Access. Internet enterprises are prohibited from providing online business venues, commercial displays, marketing, advertising, or paid traffic diversion services for virtual currency and real-world asset tokenization-related business activities. Upon discovering clues of illegal activities, they should promptly report to relevant departments and provide technical support and assistance for related investigations and inquiries. Based on the clues transferred by the financial regulatory authorities, the cyberspace administration, telecommunications authorities, and public security departments should promptly close and deal with websites, mobile applications (including mini-programs), and public accounts engaged in virtual currency and real-world asset tokenization-related business activities in accordance with the law.


  (8) Strengthened Entity Registration and Advertisement Management. Market supervision departments strengthen entity registration and management, and enterprise and individual business registrations must not contain terms such as "virtual currency," "virtual asset," "cryptocurrency," "crypto asset," "stablecoin," "real-world asset tokenization," or "RWA" in their names or business scopes. Market supervision departments, together with financial regulatory authorities, legally enhance the supervision of advertisements related to virtual currency and real-world asset tokenization, promptly investigating and handling relevant illegal advertisements.


  (IX) Continued Rectification of Virtual Currency Mining Activities. The National Development and Reform Commission, together with relevant departments, strictly controls virtual currency mining activities, continuously promotes the rectification of virtual currency mining activities. The people's governments of various provinces take overall responsibility for the rectification of "mining" within their respective administrative regions. In accordance with the requirements of the National Development and Reform Commission and other departments in the "Notice on the Rectification of Virtual Currency Mining Activities" (NDRC Energy-saving Building [2021] No. 1283) and the provisions of the "Guidance Catalog for Industrial Structure Adjustment (2024 Edition)," a comprehensive review, investigation, and closure of existing virtual currency mining projects are conducted, new mining projects are strictly prohibited, and mining machine production enterprises are strictly prohibited from providing mining machine sales and other services within the country.


  (X) Severe Crackdown on Related Illegal Financial Activities. Upon discovering clues to illegal financial activities related to virtual currency and the tokenization of real-world assets, local financial regulatory authorities, branches of the State Council's financial regulatory authorities, and other relevant departments promptly investigate, determine, and properly handle the issues in accordance with the law, and seriously hold the relevant entities and individuals legally responsible. Those suspected of crimes are transferred to the judicial authorities for processing according to the law.


 (XI) Severe Crackdown on Related Illegal and Criminal Activities. The Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, as well as judicial and procuratorial organs, in accordance with their respective responsibilities, rigorously crack down on illegal and criminal activities related to virtual currency, the tokenization of real-world assets, such as fraud, money laundering, illegal business operations, pyramid schemes, illegal fundraising, and other illegal and criminal activities carried out under the guise of virtual currency, the tokenization of real-world assets, etc.


  (XII) Strengthen Industry Self-discipline. Relevant industry associations should enhance membership management and policy advocacy, based on their own responsibilities, advocate and urge member units to resist illegal financial activities related to virtual currency and the tokenization of real-world assets. Member units that violate regulatory policies and industry self-discipline rules are to be disciplined in accordance with relevant self-regulatory management regulations. By leveraging various industry infrastructure, conduct risk monitoring related to virtual currency, the tokenization of real-world assets, and promptly transfer issue clues to relevant departments.


  IV. Strict Supervision of Domestic Entities Engaging in Overseas Business Activities


(XIII) Without the approval of relevant departments in accordance with the law and regulations, domestic entities and foreign entities controlled by them may not issue virtual currency overseas.


  (XIV) Domestic entities engaging directly or indirectly in overseas external debt-based tokenization of real-world assets, or conducting asset securitization activities abroad based on domestic ownership rights, income rights, etc. (hereinafter referred to as domestic equity), should be strictly regulated in accordance with the principles of "same business, same risk, same rules." The National Development and Reform Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other relevant departments regulate it according to their respective responsibilities. For other forms of overseas real-world asset tokenization activities based on domestic equity by domestic entities, the China Securities Regulatory Commission, together with relevant departments, supervise according to their division of responsibilities. Without the consent and filing of relevant departments, no unit or individual may engage in the above-mentioned business.


  (15) Overseas subsidiaries and branches of domestic financial institutions providing Real World Asset Tokenization-related services overseas shall do so legally and prudently. They shall have professional personnel and systems in place to effectively mitigate business risks, strictly implement customer onboarding, suitability management, anti-money laundering requirements, and incorporate them into the domestic financial institutions' compliance and risk management system. Intermediaries and information technology service providers offering Real World Asset Tokenization services abroad based on domestic equity or conducting Real World Asset Tokenization business in the form of overseas debt for domestic entities directly or indirectly venturing abroad must strictly comply with relevant laws and regulations. They should establish and improve relevant compliance and internal control systems in accordance with relevant normative requirements, strengthen business and risk control, and report the business developments to the relevant regulatory authorities for approval or filing.


  V. Strengthen Organizational Implementation


  (16) Strengthen organizational leadership and overall coordination. All departments and regions should attach great importance to the prevention of risks related to virtual currencies and Real World Asset Tokenization, strengthen organizational leadership, clarify work responsibilities, form a long-term effective working mechanism with centralized coordination, local implementation, and shared responsibilities, maintain high pressure, dynamically monitor risks, effectively prevent and mitigate risks in an orderly and efficient manner, legally protect the property security of the people, and make every effort to maintain economic and financial order and social stability.


  (17) Widely carry out publicity and education. All departments, regions, and industry associations should make full use of various media and other communication channels to disseminate information through legal and policy interpretation, analysis of typical cases, and education on investment risks, etc. They should promote the illegality and harm of virtual currencies and Real World Asset Tokenization-related businesses and their manifestations, fully alert to potential risks and hidden dangers, and enhance public awareness and identification capabilities for risk prevention.


  VI. Legal Responsibility


  (18) Engaging in illegal financial activities related to virtual currencies and Real World Asset Tokenization in violation of this notice, as well as providing services for virtual currencies and Real World Asset Tokenization-related businesses, shall be punished in accordance with relevant regulations. If it constitutes a crime, criminal liability shall be pursued according to the law. For domestic entities and individuals who knowingly or should have known that overseas entities illegally provided virtual currency or Real World Asset Tokenization-related services to domestic entities and still assisted them, relevant responsibilities shall be pursued according to the law. If it constitutes a crime, criminal liability shall be pursued according to the law.


  (19) If any unit or individual invests in virtual currencies, Real World Asset Tokens, and related financial products against public order and good customs, the relevant civil legal actions shall be invalid, and any resulting losses shall be borne by them. If there are suspicions of disrupting financial order and jeopardizing financial security, the relevant departments shall deal with them according to the law.


  This notice shall enter into force upon the date of its issuance. The People's Bank of China and ten other departments' "Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation" (Yinfa [2021] No. 237) is hereby repealed.


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