Crypto Speculation Bubble Has Burst? Examining the Crypto Investment Space from First Principles

By: blockbeats|2025/03/12 15:00:02
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Original Article Title: First Principles - Compounders, L1s, IR, Buybacks
Original Article Author: 0xkyle__, DeFiance Capital Member
Original Article Translation: ChatGPT

Editor's Note: The author believes that the biggest problem in the crypto field is not talent or capital, but rather a lack of first principles thinking, leading to the industry being trapped in a cycle of short-termism, extractive culture, and low trust. The author analyzes the reasons why compounders are hard to come by, proposes the need to drive long-term thinking from the top and focus on building revenue-generating products, criticizes the inefficiency of general-purpose Layer 1 blockchains, suggests their focus on specific domains and building their own ecosystem to give tokens value, further emphasizes that liquidity token projects should establish an investor relations role to enhance transparency, rather than relying solely on buybacks and burns, advocates for using funds to expand products and solidify long-term competitive advantages to break the current nihilistic deadlock and achieve sustainable growth.

Below is the original content (rearranged for better readability and understanding):

The biggest issue in this field is neither talent nor capital. Simply put, it is a lack of first principles thinking. This is a culture that must change. That 1% of people need to start pushing this field forward.

If you've been following my Twitter lately, you'll notice I've been shilling some very low-hanging fruit that seems to have a high leverage effect, appears very easy to accomplish, but no one seems to "get" or execute well on. Here are some points I've made:

· The real issue is: Why aren't more chains using their grant programs to incubate their own dapps and build dapps clearly consistent with the chain instead of hoping these dapps don't ditch the chain within two years?

· The reason this industry has the price action it does now is largely that everyone has this mentality: "You have to sell because one day it's going to zero." And that's because no one has really built a good product that people want to continuously DCA into. Crypto needs compounders.

· The "marketing" in the crypto space is often not aligned with the product in most cases. If you're not a consumer-facing product—like you're a yield platform, why are you even marketing to retail users. The best marketing is often price appreciation. And the best at doing that are liquidity pools.

In this article, I will discuss each of the following topics:

· Compounders, Culture, Short-termism

· Layer 1 Maximalism is Dead, Long Live the Change

· Liquidity Tokens and Investor Relations

· Buyback and Burn is Least Worst, Not Best

I titled this post "First Principles" because all of these points came to me during a simple thought exercise on how to change the industry today using common sense.

This isn't profound. Insanity is doing the same thing over and over again but expecting different results.

We've been through three cycles of doing the same thing over and over again—essentially creating hollow, zero-sum value accrual, maximal extractive tokens and apps, because for some stupid reason, we decided every four years to open a casino so rabidly, drawing capital from around the world to gamble.

Guess what? Three cycles later, ten years on, people are finally realizing the house, the scammers, the manipulators, the people rigging the machines, the ones selling you overpriced food and drinks in the casino, have taken all your money. The only thing you can show after months of hard work is how you managed to lose all your history on-chain. An industry predicated on "I'll come in, make my money, then leave" does not lead to the building of any long-term compounding.

Crypto Speculation Bubble Has Burst? Examining the Crypto Investment Space from First Principles

This place used to be better, used to be a place for legitimate financial innovation and cool tech. We used to be excited about novel, interesting apps, new tech, "changing the future of finance."

But due to extreme short-termism, a maximal extractive culture, and low-integrity people, we've spiraled into this eternal financial nihilism self-devouring loop, where everyone thinks constantly aping into random scam tokens is a good idea, this loop collectively self-fulfills because "I'll sell before he scams me." (Seriously, I've seen someone say they know the "SBF token" is a scam but will sell before getting rugged for a "quick profit.")

You can say I don't have building experience—fair point. But it's a small field and a short time in existence; working in this space for four years, collaborating with some of the best and brightest funds, has given me a deep understanding of what works and what doesn't.

Reiterating: Insanity is doing the same thing over and over again but expecting different results. As a field, year after year, we've gone through the same motions—feeling this nihilism post-inevitable price collapse, believing it's all worthless. I felt it during the NFT crash (god, this was all a scam), people are feeling it now post-recent meme coin failures, and people felt it during the ICO era.

Changing the status quo is simple: we just need to start doing things differently.

Compounding, Culture, Short-Termism

Compounding is simply an asset that only goes up over many years—think Amazon, Coca-Cola, Google, and the like. Compounding is about companies with the potential for sustainable, long-term growth.

Why haven't we seen compounders in the crypto space?

The answer is more nuanced than this, but fundamentally—extreme short-termism and misalignment of incentives. Indeed, the incentive structures have many issues, well-covered in Cobie's private capture, phantom pricing article. I won't dive into that, as the focus of this piece is, what can we as individuals actually do?

For investors, the answer is clear—Cobie points it out here: you can opt out (you probably should).

Indeed, people have been opting out: this cycle, we've seen the decline of "CEX tokens" as retail participants opt not to buy these tokens; while individuals may not have the power to change this systemic issue at a protocol level, the good news is that financial markets are quite efficient—people want to make money, and when the existing mechanisms don't allow for that, they don't invest, rendering the whole process unprofitable, thus forcing a change in mechanisms.

However, this is just the first step of the process—to truly build compounders, companies need to start instilling long-term thinking in this space. It's not just that "private capture" is bad, it's the entire thought chain that got us here—like a self-fulfilling prophecy, founders seem collectively to believe "I'll make my money and exit," with nobody really interested in playing the long game—that means the chart always looks like a McDonald's golden arch.

The top must change: a company is only as good as its leadership. Most projects fail not due to lack of developers but due to high-level decisions to exit. This industry must start to see those founders with high integrity, high energy, and long-term thinking as the role models, not the idealized "pump and dump" founders.

The average quality of founders in this space is not high, that's no news. After all, this is a field where those tethered to pumpfun tokens are called "developers"—the bar isn't really that high. As long as you have a vision that goes beyond the first two months of token launch, you're ahead of the pack.

I also believe that the market will start to economically incentivize this long-termism; we're beginning to see it already. Despite recent sell-offs, Hyperliquid is still up 4x from its launch, which is not something many projects can boast about in this cycle. When you know the founder is aligned with the long-term growth of the product, the argument for "HODLing" is usually easier to make.

The natural conclusion is that founders with high integrity and high stickiness will begin to occupy a large portion of the market share because, frankly, when everyone is tired of scams, they just want to work for someone with a vision who won't exit scam—and there are very few of those.

Aside from having a good leader, the establishment of compounding also depends on the assumption of whether the product is good. In my view, this issue is easier to solve than finding a good founder. The reason the crypto space has so many pointless products is that the people creating these pointless products also have a "make money and leave" mentality—they choose not to tackle new problems and instead just fork popular things and try to make money from them.

However, the reality is that this industry does indeed reward this frivolous idea—such as the AI agent frenzy in Q4 2024. In this scenario, after the dust settles, we will see the usual McDonald's M-shaped pattern—hence, companies must also start focusing on building profitable products.

No revenue path = no long-term believers/holders = no buyers with no assets because there is no future to bet on.

This is not an impossible task—crypto businesses do make money. Jito has a yearly revenue of 9 billion, Uniswap 7 billion, Hyperliquid 5 billion, Aave 4.88 billion—they continue to make money even in the bear market (just not as much).

Looking ahead, I believe the fleeting, narrative-driven speculative bubble will become smaller and smaller. We have already seen this—2021's gaming and NFT pricing amounted to trillions, but this cycle, the peak of memes and AI agents is only in the billions. It's a macro-level euthanasia rollercoaster.

I believe everyone should be free to invest in what they want. But I also believe people want their investments to yield returns—when a game is so clearly seen as "this is a hot potato, I must sell before it goes to zero," the rollercoaster will speed up, the market will shrink as people choose to exit or lose all their money.

Revenue solves this issue—it lets you as an investor understand that people are willing to pay for the product, thus having a certain long-term growth outlook. When something lacks a revenue path, it is almost uninvestable on a long-term basis. On the other hand, a revenue path leads to a growth path, attracting buyers who are willing to bet on continuous asset growth.

In conclusion, building a compounding system requires:

· Top-down instilling of long-term thinking

· Focus on building revenue-generating products

The Death of General-Purpose L1, A Necessity for Change

If you were to sort Coingecko's homepage by market cap, you would find that blockchain occupies more than half of it; apart from stablecoins, Layer 1 holds significant value in our industry.

However, the chart of the second-largest digital asset after Bitcoin looks like this:

If you bought Bitcoin in July 2023, based on the current price, you would be up 163%.

If you bought Ethereum in July 2023, based on the current price, you would be up 0%.

And that's not even the worst part. The bubble of 2021 triggered a wave of "Ethereum killers"—new blockchains aimed at surpassing Ethereum in some technological way, whether in speed, development language, block space, etc. But despite the hype and significant fund inflows, the results did not meet expectations.

Today, four years from 2021, we are still facing the consequences of that wave—a total of 752 smart contract platforms have launched tokens on Coingecko, and there may be more yet to launch.

Unsurprisingly, most of their charts look like this—making Ethereum's chart look relatively good in comparison:

Therefore—despite four years of effort, billions of dollars poured in, over 700 different blockchains, only a few L1s exhibit decent activity—and even those have not reached the "breakthrough level of user adoption" that everyone expected four years ago.

Why? Because most of these projects were built on the wrong premise. As Luca Netz pointed out in his article "What is Consumer Cryptography," many of today's blockchains follow a generic approach, with each blockchain dreaming that they will "power the Internet economy."

However, this takes a tremendous effort, ultimately leading to fragmentation rather than penetration, as a product trying to do everything usually ends up doing nothing well. This is an effort that costs too much money and time—frankly, many blockchains struggle to answer a simple question: "Why should we choose you over blockchain number 60?"

The L1 space is another case of everyone following the same script but expecting a different result—they compete for the same limited developer resources, trying to outdo each other in funding, hackathons, developer homes, and now, apparently, we are still making phones (?)

Let's assume an L1 succeeds. Each cycle, a few L1s manage to break through. But can this success be sustained? The success story of this cycle is Solana. But here is a viewpoint that many of you won't like: what if Solana becomes the next Ethereum?

During the last cycle, there were people so convinced of Ethereum's success that they put most of their net worth into Ethereum. Ethereum still has the highest TVL chain, and now there's even an ETF—however, the price remains stagnant. This cycle, the same type of people are saying the same things—Solana is the chain of the future, Solana ETF, and so on.

If history is any indication, the real question is—can today's victory ensure tomorrow's relevance?

My view is simple: rather than building a general-purpose blockchain, L1s should build around a core focus that is more meaningful. A blockchain does not need to be all things to all people. It just needs to excel in a particular area. I believe the future is blockchain-agnostic—it just needs to excel, and the technical details won't matter as much.

Today, builders are already showing signs of this—founders building a DApp are mainly concerned not with the speed of the chain but with the distribution of the chain and end-user consumption—Is your chain being used? Does it have the necessary distribution to make the product appealing?

44% of web traffic runs on WordPress, but its parent company Automattic is valued at only $7.5 billion. 4% of internet traffic runs on Shopify, but its valuation is $120 billion—that's 16 times Automattic's value! I believe L1s will also reach a similar end state, where value will accrue to applications built on the blockchain.

To that end, I believe L1s should take a bold step and build their own ecosystem. If we analogize blockchain to a city (thanks to Haseeb's post in 2022), we can see that cities started because specific advantages made them viable economic and social centers, then over time, they focused on a dominant industry or function:

· Silicon Valley → Technology

· New York → Finance

· Las Vegas → Entertainment and Hospitality

· Hong Kong and Singapore → Trade-Centric Financial Hubs

· Shenzhen → China's Hardware Manufacturing and Technology Innovation Hub

· Paris → Fashion, Art, and Luxury Goods

· Seoul → K-pop, Entertainment, and Beauty Industry

L1 follows the same pattern — demand is driven by the allure and activity they offer; hence, teams must start focusing more on excelling in a particular vertical — crafting the kind of allure that draws people into their ecosystem rather than building various expos hoping for users to be drawn in.

Once you have that allure that draws people into the ecosystem, you can build a city around it. Again, Hyperliquid is an example of a team doing this well and iterating on first principles in this regard. They built a native sustainable DEX order book, spot DEX, staking, oracle, multisig — all built in-house, then extended to HyperEVM, a smart contract platform for people to build on.

Here's why it is effective broken down simply:

· Starting with "Building the Allure" First: By first building a perpetual trading product, Hyperliquid attracted traders and liquidity before expanding.

· Owning the Stack: Having critical infrastructure (oracle, staking) reduced vulnerabilities and created a moat.

· Ecosystem Synergies: HyperEVM now serves as a playground for developers, leveraging Hyperliquid's existing user base and liquidity.

This "Allure First, City Second" pattern mirrors successful web2 platforms (e.g., Amazon starting from books and then expanding into everything else). Solve an exceptionally well problem, then let the ecosystem organically expand from that core value.

Therefore, I believe blockchain should start integrating its products, building its own allure, owning the stack; as a captain, you are a visionary — this allows you to align your blockchain with your larger, long-term vision for L1; and ensure the project doesn’t immediately give up when chain activity begins to decline because everything is built internally;

Most importantly, this process has brought fungibility to your token—if the blockchain is the city, the token is the currency/good people transact with; by imbuing value into the token through utility—people need to buy your token to do interesting things on-chain. It gives value to your currency and gives people a reason to hold it.

Oh, but remember—just because you specialize, it doesn't mean there's a market demand for it. Another bitter pill to swallow is that L1 has to work in the right way at the right time. The blockchain has to develop products that people want—sometimes, people don't truly want 'web3 games' or 'more data availability.'

Liquidity Tokens & Investor Relations

The next topic is about how I believe liquidity token projects should evolve in this space. Quite simply—liquidity token projects need to start establishing Investor Relations (IR) roles and quarterly reports, allowing investors—whether retail or professional—to see clearly what the company is up to. This role is not novel nor revolutionary—but severely lacking in this space.

However, the space does little in terms of IR. I've been told by several project Biz Dev leads that if you have some kind of 'regular sales call pitching your liquidity token to funds,' you're doing more than 99% of the other projects in this space.

Biz Dev is cool for attracting builders and ecosystem funds, but IR roles telling the public what the token does are better—really that simple. If you're a token looking to attract buyers, you need to market yourself—and the way you do that is not by renting the biggest booth at a conference or advertising at airports but by pitching yourself to capital-rich buyers.

By providing quarterly growth updates, you start showing investors that the product is legitimate and can accrue value—allowing investors to speculate on the long-term prospects of the product.

As for how you should go about it—a good starting list:

· Reports discussing quarterly expenses/revenue, protocol upgrades, numbers, but no MNPI—published on blog/website

· Monthly interfacing with liquidity fund managers, discussing your product/pitching yourself

· Hosting more AMAs

Buybacks and Burns Aren't Bad, but Not Ideal Either

Lastly, I want to discuss buybacks and burns in this space. My take is: if that money has no other purpose, I think buybacks and burns are a decent use. From my perspective, crypto has not yet reached a point where companies can rest on their laurels; there is much to be done in terms of growth.

The first and most important use of revenue should always be to expand the product, upgrade technology, and enter new markets. This is consistent with driving long-term growth and building a competitive advantage; a good example of this is the acquisition spree by Jupiter, as they have been using cash to acquire assets, products, and key talent in the space.

While I know some people like buybacks and burns and will call for dividends, my view is that most crypto operates more akin to tech stocks, as the investor base is similar in nature: seeking high returns, investors are looking for outsized returns.

As such, companies returning value directly to token holders via dividends doesn't make much sense—they could, but if they build a larger moat with cash reserves that serve them in 5 to 10 years, they would benefit greatly from the product.

Crypto is now at the cusp of entering the mainstream—so slowing down now makes no sense; rather, doubling down in cash to ensure the next winner is ahead for a longer time frame is key because although all prices are down, crypto institutional settings have never been better—adoption of stablecoins, blockchain technologies, tokenization, and so on.

Thus, buybacks and burns, while much better than just cashing out, are still not the most effective use of capital considering how much work is left to be done.

Conclusion

This bear market has already started to make people realize the necessity of building revenue-generating products as a path to profitability and the inevitable need to play a legitimate investor relations role in showcasing token performance.

There's still much work to be done in this space. I remain optimistic about the future of crypto.

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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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