From "King of the Forks" to "Institutional Wonderland"? Can Pectra's Upgrade Reshape the Ethereum Ecosystem Landscape

By: blockbeats|2025/03/14 08:15:03
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Original Article Title: "From 'King of Forks' to 'Institutional Playground'? Can the Pectra Upgrade Reshape the Ethereum Ecosystem Landscape?"
Original Article Author: Ac-Core, YBB Capital Researcher

1. Background of the Pectra Hard Fork

From

Image Source: coinpedia

The Ethereum Pectra upgrade went live on March 5th, combining the Prague and Electra updates to optimize Ethereum's execution layer and consensus layer. The Pectra fork is a major upgrade to the Ethereum network aimed at improving ETH staking experience, enhancing Layer 2 (L2) scalability, expanding network capacity, and introducing 11 Ethereum Improvement Proposals. The upgrade process was first implemented on the Holesky testnet on February 24, 2024, with the final deployment of Pectra to the mainnet planned for April 8, 2024, subject to successful upgrades on the Holesky and Sepolia testnets.

Pectra follows the Dencun upgrade implemented in March 2024. According to ethereum.org (see Reference 1), the Ethereum Pectra upgrade is expected to integrate several key Ethereum Improvement Proposals that collectively address challenges in scalability, security, and user experience. The Pectra upgrade will be implemented in two phases:

Phase 1: Mid-March 2025

● L2 Blob Capacity Doubling: Increasing the Blob capacity per block from 3 to 6 to reduce congestion and lower fees;

● Account Abstraction: Allowing Gas fees to be paid with stablecoins like USDC and DAI, providing more payment flexibility;

● Increased Validator Staking Limit: Raising the staking cap from 32 ETH to 2,048 ETH to enable large-scale staking operations;

Phase 2: End of 2025 or Early 2026

● Implementation of Verkle Trees: Replacing Merkle-Patricia with a more efficient data structure to improve data storage and synchronization;

● Peer Data Availability Sampling (PeerDAS): By allowing nodes to validate transaction data without storing all data, it improves scalability.

II. Specific Content of the 11 Improvement Proposals for the Pectra Upgrade

Image Source: datawallet

Ethereum's Pectra upgrade consists of 11 EIPs (Ethereum Improvement Proposals). These proposals are aimed at enhancing various aspects of the network, such as scalability, security, account abstraction, and the validator staking mechanism. The following will outline the key proposals of the improvement proposals (different researchers have differing opinions on the key proposals, the following are solely personal views on important proposals) and the impact of the proposals on Ethereum's development.

1. EIP-7702: Account Abstraction

· Content: This proposal allows Externally Owned Accounts (EOAs) to perform some smart contract functions, making account operations more flexible, such as batch transactions and sponsoring gas fees. This greatly enhances wallet functionality, enabling it to support more operation modes.

· View: This proposal undoubtedly makes account abstraction wallets more powerful. They can now not only perform regular transfer operations but also execute some advanced functions similar to smart contracts, such as batch transactions or having someone else pay your gas fees. (Related EIP-7840 provides a broader account function extension, which may allow users to customize more complex account behaviors)

2. EIP-7251: Validator Staking Increase

· Content: The maximum staking balance for validators is increased from 32 ETH to 2048 ETH. This can streamline validator management, allowing for a larger scale of validator nodes, thus reducing management complexity.

· View: The significant increase in the staking amount undoubtedly increases Ethereum's centralization. The more concentrated the nodes, the easier it is for malicious behavior, while also raising the profitability difficulty of the Ethereum market. Node operation and MEV arbitrage costs will significantly increase, making it no longer suitable for the "average person" and more suitable for institutions.

3. EIP-7002: Withdrawal Improvement

· Content: Allows execution layer addresses to trigger withdrawal operations, reducing the trust assumptions between the consensus layer and execution layer, simplifying the withdrawal process, and enhancing the network's flexibility.

· Viewpoint: Mainly aimed at making the withdrawal process simpler, eliminating the need for complex steps. Validators can withdraw more directly from staking, reducing intermediate steps.

4. EIP-6110: Validator Activation Delay Optimization

· Content: Validator activation delay for deposits has been reduced from about 9 hours to about 13 minutes, greatly improving validator participation efficiency and flexibility.

· Viewpoint: The speed at which new validators join the network has significantly increased, reducing costs from a storage management and contract storage perspective, shrinking from the previous 9 hours to just 13 minutes. To some extent, this also enhances Ethereum's resource utilization.

5. EIP-7691: Data Block Extension

· Content: Increased data block capacity by 50%, meaning the network can process more transactions, enhancing overall scalability and transaction throughput.

· Viewpoint: Ethereum's block size has increased by 50%, allowing the network to process more transactions, especially during peak periods, reducing the likelihood of network congestion and increasing transaction speed. (Related to EIP-7742, which can dynamically adjust the Blob's capacity, adjusting the maximum and target Blob quantity per block, especially for L2)

6. EIP-7516: Improving MEV Transparency

· Content: Providing more information and transparency about the maximum extractable value of MEV to help users and developers better understand and monitor MEV activities on the blockchain.

· Viewpoint: Increased transparency on MEV, as well as increased arbitrage difficulty as with EIP-7251, greatly ensures transaction fairness at a higher cost.

7. EIP-7549: Gas Fee Adjustment

· Content: By adjusting the Gas fee structure, further optimizing the network's fee mechanism, alleviating network burden during peak hours, making transaction fees more reasonable.

· Viewpoint: Adjusting the Gas fee structure means that even when the network is busy, transaction fees will be more stable, reducing the situation where users have to pay high fees during peak periods. (EIP-6046 also involves adjusting the Gas fee structure, but EIP-7549 proposes a more dynamic and flexible fee adjustment scheme)

8. EIP-7685: Governance Mechanism Optimization

· Content:  Optimize network governance to enhance decentralized governance mechanisms, making the governance process more transparent and efficient.

· Viewpoint: Ethereum's governance may become more transparent and efficient, especially in the proposal review and approval process, improving governance efficiency and making community decision-making more flexible.

9. EIP-7021: Validator Penalty Mechanism Optimization

· Content:  Adjust the penalty mechanism for validators to ensure that validator behavior aligns more with the network's interests and reduces the impact of misconduct.

· Viewpoint: The improved penalty mechanism will better constrain validator behavior, serving as a remedial mechanism for increasing the maximum staking balance from 32 ETH to 2048 ETH to balance network security and validator incentives, ensuring consensus layer stability.

10. EIP-7683: Smart Contract Performance Optimization

· Content:  Optimize smart contract execution efficiency, particularly in terms of Gas consumption, reduce execution costs, and improve smart contract operation efficiency on the network.

· Viewpoint: Smart contracts run more efficiently, consuming less Gas fees, which may fundamentally improve Uniswap's relevant mechanisms, lowering transaction costs, and increasing transaction speed, with DeFi applications being the direct major beneficiaries.

11. EIP-6123: Cross-Chain Compatibility Improvement

· Content:  Enhance Ethereum's network's cross-chain compatibility with other blockchains to support more cross-chain operations in the future, promoting interoperability between different blockchains.

· Viewpoint: Enhanced compatibility between Ethereum and other blockchains also optimizes the account abstraction mechanism, making it simpler to transfer assets and perform operations between different blockchains, strengthening custom functionality.

III. Pectra Dual-Layer Upgrade

Image Source: cryptoticker

Pectra adopts a dual-layer upgrade approach by merging the execution layer (Prague) and the consensus layer (Electra) to address potential synchronization issues that may arise from separate upgrades in the past. The execution layer and consensus layer of Ethereum often serve different functions, so historically, these two aspects have usually been upgraded separately.

● Execution Layer (Prague): Responsible for processing user transactions, executing smart contracts, and managing state changes. This is the part where users directly interact with Ethereum, and it is the core layer that runs all decentralized applications (DApps) and smart contracts.

● Consensus Layer (Electra): Manages validators through a Proof of Stake (PoS) mechanism to ensure block generation and chain security. This layer is the foundation for network consensus and security, with validators staking to ensure their behavior aligns with the network's best interest.

It is worth noting:

EIP-6110, EIP-7002, EIP-7251, EIP-7549, EIP-7685, and EIP-7691 require changes to Ethereum's Consensus Layer.

EIP-2537, EIP-2935, EIP-6110, EIP-7002, EIP-7623, EIP-7685, EIP-7702, and EIP-7840 require changes to Ethereum's Execution Layer.

EIP-7623: Cross-Chain Message Mechanism Improvement

Enhances the handling of cross-chain messages to improve the efficiency and security of cross-chain communication. While the Pectra upgrade primarily focuses on improvements to Ethereum's internal Execution Layer and Consensus Layer, EIP-7623 specifically targets interactions with external blockchains, particularly optimizing cross-chain asset and information transfers.

EIP-2537: BLS12-381 Curve Operations

Introduces support for the BLS12-381 curve in Ethereum for encryption and zero-knowledge proofs. EIP-2537 is a proposal to introduce support for a specific cryptographic curve that serves verification and privacy-related functions. In contrast, proposals in the Pectra upgrade are more broadly focused on transactions, Gas fee optimization, and validator mechanisms.

EIP-2935: Validator Set Reversion

Provides a more flexible mechanism for nodes that lose their validator status to reclaim their eligibility. EIP-2935 focuses on a validator recovery mechanism to ensure that validators can continue to participate in consensus under certain conditions, while EIP-7251 and EIP-7021 in the Prague upgrade concentrate more on improving staking limits and penalty mechanisms.

IV. Impact of Pectra on Ethereum and the Cryptocurrency Market

Image Source: voiceofcrypto

DApps

The Pectra hard fork brought smart contract functionality to regular wallets, which can streamline the development process and expand the potential application scope. Features such as social recovery and transaction batching make it easier to create user-friendly DApps, whether in DeFi, GameFi, or other applications. Users can expect a more reliable and efficient DApp experience on the Ethereum network.

However, a major challenge that Ethereum itself faces is the pronounced "parasitic" effect of Layer 2 (L2). L2 chains have attracted a significant amount of DeFi activity, leading to a reduction in transaction fees on the Ethereum mainnet and an increase in ETH's inflation rate. While L2 chains are part of the Ethereum ecosystem, their centralized sequencers and independent economic models have raised questions about the value of the Ethereum mainnet.

Ethereum's Long-Term Value

During this cycle, many Ethereum holders have been dissatisfied with ETH's price performance. Many see the Pectra upgrade as a hope to change the rules of the ETH game, primarily focusing on improving practical staking and L2 scalability. Overall, the Pectra upgrade has brought many changes to Ethereum, making wallet operations more flexible, enabling batch transaction processing or gas fee sponsorship. Validator staking limits have increased, withdrawal and network joining speeds have accelerated, and operations have become more convenient. The network's block capacity has relatively increased, allowing for faster transaction processing, and gas fees are more stable, avoiding sudden spikes in fees during peak times.

The significant increase in staking thresholds has increased overall MEV transparency, raised MEV costs, and made network governance more transparent and efficient. In terms of smart contracts, execution will be more cost-effective, and cross-chain compatibility has also improved. However, the challenge of Ethereum's fragmented scalability issue raises the question of whether the development roadmap should focus on a single-network high throughput approach rather than relying on an aggregation of multiple chains to solve it. These challenges will also become constraints on Ethereum's future development.

Solana's price surge is mainly attributed to high throughput, low transaction costs, and backing from American capital. A single-chain liquidity is cohesive and unified, while Ethereum has solved scalability issues through L2, innovation has become fragmented and duplicated. A single network is superior to the L2 aggregation path. From a market perspective, Ethereum's greatest advantage lies in having the most comprehensive and decentralized DeFi network, with DeFi being Ethereum's greatest value proposition.

The Compromise of Decentralization

The biggest advantage of this upgrade lies in enhancing the overall security and scalability of Ethereum, but the double-edged sword of EIP-7251 will potentially reduce the network's operational load by merging validator counts and alleviating the burden of large storage, deepening Ethereum's centralization, turning Ethereum into the playground of large investors and institutions.

However, whether relying on a massive 2048 ETH stake, cutting off retail participation to attract large capital investment, shifting towards Solana and Sui to embrace U.S. capital, thus driving up the price of ETH, remains to be seen. Current Ethereum seems to be facing a new challenge, with narrative capability, centralized pull-up, and decentralized PoS staking forming the "new impossible triangle."

Where Is the New Narrative Polestar?

Ethereum seems to be losing direction, with fragmented ETH gradually inflating year by year, DeFi activities moving to layer two chains, and fee capture on layer one significantly decreasing. Layer two chains are effectively independent blockchains, with centralized sequencers being seen as entirely different blockchain networks. Base's substantial earnings flow to Coinbase, Arbitrum's profits flow to Arbitrum DAO, and profits flow completely out of Ethereum's layer one.

Bitcoin has a clear polestar of "digital gold," Solana's polestar is "Nasdaq on-chain." Blockchain embraces AI, Solana relies on DeFAI and AI Agent-related narratives to quickly gain prominence, and the SOL/ETH exchange rate has made the biggest "Ethereum killer" Solana's dream come true. Metis's ReGenesis plan will transform into an AI public chain, with intent-centricity also combating DeFAI.

So what is Ethereum's polestar after all? Why does the ETF repeatedly fail?

The root cause lies in the lack of staking rewards and centralized value attribution. The current form of the Ethereum ETF does not allow investors to participate in staking. By holding Ethereum through an ETF, investors miss out on about a 3.5% yield and must pay additional management fees, and they also cannot obtain DeFi income.

Similarly, in terms of value attribution, Ethereum's strong decentralized attribute makes it difficult to attribute to any particular capital force, and "Wall Street capital" has not yet truly "usurped" the victory of decentralization. More are just supporting DApps through stablecoins and DeFi, but the Pectra upgrade will increase the maximum stake balance from 32 ETH to 2048 ETH. It seems to be supporting the introduction of real-world assets into Ethereum by using staking as exposure, developing a more Ethereum-friendly version of RWA. Therefore, in the short term, Ethereum's polestar may be ETF staking, raising Ethereum's price expectations to an equally important level as Bitcoin's strategic reserve landing.

References:
(1)https://eips.ethereum.org/EIPS/eip-7600
(2)https://ethroadmap.com/?ref=bankless.ghost.io#pectra%20sticky
(3)https://eips.ethereum.org/EIPS/eip-7742
(4)https://eips.ethereum.org/EIPS/eip-7702
(5)https://eips.ethereum.org/EIPS/eip-7685
(6)https://eips.ethereum.org/EIPS/eip-7251
(7)https://eips.ethereum.org/EIPS/eip-7002
(8)https://eips.ethereum.org/EIPS/eip-6110
(9)https://eips.ethereum.org/EIPS/eip-2935
(10)https://eips.ethereum.org/EIPS/eip-2537
(11)https://www.galaxy.com/insights/research/ethereum-all-core-developers-execution-call-187/
This article is contributed content and does not represent the views of BlockBeats.

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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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