Public Blockchain Moat only 3 points? Alliance DAO Founder's Comments Spark Crypto Community Debate
Original Article Title: "Is the Moat of Public Chains Only 3 Points? Alliance DAO Founder's Comments Sparked a Crypto Community Debate"
Original Article Author: Wenser, Odaily Planet Daily
Recently, Alliance DAO founder qw (@QwQiao) put forward a stunning point of view: "Blockchain moats are limited," and rated the moat of L1 public chains as only 3/10.
This statement quickly ignited the overseas crypto community, sparking heated discussions among crypto VCs, public chain builders, and KOLs. Dragonfly partner Haseeb angrily retorted that rating "the blockchain moat as 3/10" is simply absurd, even Aave founder Santi, who is averse to the industry's gambling atmosphere, never believed that blockchain has "no moat."
The debate over the meaning, value, and business model of blockchain and cryptocurrency constantly resurfaces in cycles. The crypto industry continues to oscillate between idealism and reality: people both cherish the decentralized original intention and aspire to have the status and recognition of the traditional financial industry while also being deeply mired in self-doubt about whether it is merely a repackaged casino. Perhaps the root of all these contradictions lies in scale—the total market value of the crypto industry has always hovered around 3-4 trillion dollars, which still seems small compared to the traditional financial giants with market capitalizations often in the hundreds of billions or trillions of dollars.
As professionals in the field, everyone has a contradictory mentality that is both arrogant and self-deprecating—arrogant because they have adhered to Satoshi Nakamoto's ideal of demonetization and the spirit of decentralization since the birth of blockchain, and the crypto industry has indeed become a burgeoning financial industry that is gradually gaining mainstream attention, acceptance, and participation. The self-deprecating aspect is probably like a poor boy who always feels that what he is doing is not particularly glorious, filled with the blood, sweat, tears, bitterness, and pain of a zero-sum game. In short, the limitation of industry scale has given rise to this cyclical identity anxiety, self-doubt, and self-denial.
Today, we will take advantage of the topic of "Moat Business Ratings" proposed by qw to discuss the existing chronic illnesses and core strengths of the crypto industry.
Origin of the Debate: Is Liquidity the Moat of the Crypto Industry?
This industry-wide discussion about "whether the crypto industry has a moat" actually originally stemmed from a statement by Paradigm team researcher frankie: "The greatest trick the devil ever pulled was convincing crypto people that liquidity is a moat."
It is evident that as a "purebred" VC, Frankie somewhat scoffs at the current trend in the crypto industry that highly esteems "liquidity is everything." After all, for an investor and research expert who holds financial and informational advantages, they often hope that the money they manage can be spent on projects and businesses with real-world use cases, capable of generating actual cash flow and providing them with continuous financial returns.
This viewpoint has also received agreement from many in the comments section:
· Multicoin partner Kyle Samani directly stated "+1";
· Ethereum Foundation member binji believes that "trust is the true moat, even if trust may flow due to opportunities in the short term, liquidity will always be placed where trust is."
· Chris Reis of the Arc blockchain team under Circle pointed out: "TVL always seems like the wrong North Star metric (business guidance goal)."
· Justin Alick of the Aura Foundation jokingly remarked, "Liquidity is like a capricious woman, she may leave you at any time."
· DeFi researcher Defi Peniel bluntly stated, "Relying solely on liquidity is not a moat, hype can disappear overnight."
Of course, there are also many who have refuted this:
· DFDV COO and CIO Parker commented, "What are you talking about? USDT is the worst stablecoin, but it holds absolute dominance. Bitcoin is the worst-performing blockchain, but it absolutely dominates."
· Former Sequoia Capital investor, now Folius Ventures investor KD gave a rhetorical question, "Isn't it?"
· Fabric VC investor Thomas Crow pointed out, "In a trading platform, liquidity is a moat— the deeper the liquidity, the better the user experience; this is the most critical feature in this vertical industry, without exception. That is why the main innovation of crypto asset trading is focused on solving the problem of insufficient liquidity (resulting in a poorer user experience). Examples include Uniswap, which obtains long-tail asset liquidity through LP, and Pump.Fun, which attracts liquidity before token launch through standardized contracts and pooled curves."
· Pantera investor Mason Nystrom retweeted and commented, "Liquidity is definitely a moat." He then provided different examples to illustrate: in public chains, Ethereum's current lead is due to DeFi liquidity (and developers); in CEXs, Binance, Coinbase, etc.; in lending platforms, Aave, MakerDAO; in stablecoins, USDT; in DEXs, Uniswap, Pancakeswap.
Then, we had the Alliance DAO founder qw's moat rating tweet:

In his view, the moat of a blockchain (public chain) itself is very limited, with a rating of only 3/10.
- He believes that Microsoft (key SaaS), Apple (brand + development ecosystem), Visa/Mastercard (payment network effect), TSMC (IP + physical infrastructure) can achieve a rating of 10/10 (strongest moat);
- Google (search and AI IP), Amazon (e-commerce network effect + logistics infrastructure), rating agencies like Moody's, S&P, FICO (regulation-driven + brand + rating network effect), large cloud providers (AWS/Azure/GCP, etc.) can achieve a rating of 9/10;
- Meta (social network effect), Nvidia (IP + CUDA network effect) have a rating of 8/10;
- The best crypto businesses in the crypto industry have a rating of 5/10;
- Public chains (blockchains) have a rating of only 3/10 (narrow moat).
qw further stated that a low moat rating is not necessarily a bad thing, but it means the team must be able to consistently lead innovation; otherwise, they will be quickly replaced. Subsequently, perhaps feeling that the previous ratings were too hasty, qw provided some additional ratings in the comments:
- The big three cloud service providers have a rating of 9/10;
- Bitcoin's moat rating is 9/10 (Odaily Planet Daily Note: qw pointed out that no one can replicate BTC's public chain founding story and the " Lindy Effect," but deducted 1 point because it is unclear if it can handle security budgets and quantum threats);
- Tesla 7/10 (Odaily Planet Daily Note: qw believes that the IP for autonomous driving is very impressive, but the automotive industry is commoditized, and humanoid robots may be similar);
- ASML, the lithography machine manufacturer, has a perfect 10/10 rating.
- AAVE's moat rating may be higher than 5 points (out of 10), with qw's reason being, "As a user, you must trust that their smart contract security testing is thorough enough not to lose your funds."
Of course, when seeing qw arrogantly acting as a "sharp critic," in addition to the debate on the "moat system" in the comments section, some people also made irrelevant sarcasm about qw's remarks. Someone even mentioned, "What about those completely failed launch platforms you invested in?" (Odaily Planet Daily Note: After launching pump.fun, Alliance DAO's subsequent investments in one-click launch platforms (such as Believe) have underperformed, to the point that he himself does not want to rate them)
With such a highly inflammatory focal point, Dragonfly partner Haseeb then made an angry retort.
Dragonfly Partner's Inner OS: Nonsense. I Have Never Seen Such Shamelessness
Regarding qw's "moat rating system," Dragonfly partner Haseeb wrote in a post: "What? Blockchain Moat: 3/10? This is a bit absurd. Even Santi doesn't believe that a public blockchain has no moat."
Ethereum has dominated for 10 consecutive years, with hundreds of challengers raising over $10 billion, trying to gain market share. After ten years of competitors trying to beat it, Ethereum has successfully defended its throne every time. If this still cannot demonstrate that Ethereum has a moat, I really don't know what a moat is.
In the tweet's comments section, qw also expressed his views: "What you are saying is all about looking back (the past ten years) and is factually incorrect (Ethereum no longer holds the throne on several metrics)."
Subsequently, the two engaged in several rounds of discussion on "What is a moat?" and "Does Ethereum really have a moat?" qw even brought up a post he made in November, pointing out that in his view, "moat" is actually revenue/profit. However, Haseeb then provided a counterexample—prominent crypto projects like OpenSea, Axie, and BitMEX, which, although once had high revenue, did not actually have a moat. A true moat should focus on whether "it can be replaced by a competitor."
Abra Global's Head of Asset Management, Marissa, also joined the discussion: "I agree (with Haseeb's point). qw's statement is a bit odd—switching costs and network effects can be strong moats—Solana and Ethereum both have these. I think over time, they will become stronger than other blockchains. They both have a strong brand and developer ecosystem, which is clearly part of the moat. Perhaps he is referring to those other blockchains that do not have these advantages."
Haseeb continued to mock Laman: "qw is just sophistry, bringing trouble upon oneself."
Building upon the above discussion, perhaps we should dissect what elements constitute the "true moat" of the public blockchain industry.
The 7 Major Components of a Public Blockchain Moat: From Characters to Business, from Origin to Network
In the author's view, the reason why qw's "moat scoring system" is somewhat unconvincing mainly lies in:
Firstly, its evaluation criteria only consider current industry status and revenue, disregarding a multi-dimensional assessment. Whether it is infrastructure like Microsoft, Apple, Amazon Web Services, or payment giants like Visa, Mastercard, qw's high ratings are mainly due to their strong revenue models. This clearly oversimplifies and superficializes the moat of a corporate giant's business. Moreover, Apple's global market share is not dominant, and payment giants like Visa are also facing challenges such as market contraction and declining regional business.
Secondly, it overlooks the complexity and uniqueness of blockchain projects and crypto assets compared to traditional internet businesses. As challengers to the fiat system, cryptocurrency and blockchain technology, as well as subsequent public chains and crypto projects, are based on the inherent "anonymity" and "node-based" nature of decentralized networks, which traditional revenue-driven businesses often cannot achieve.
Therefore, personally, I believe that the moat of a public blockchain business mainly lies in 7 aspects, including:
1. Technological Philosophy. This is also the greatest strength and differentiating factor of networks like Bitcoin, Ethereum, Solana, and numerous other public chain projects. As long as there is human vigilance against centralized systems, authoritarian governments, and fiat systems, and an acceptance of sovereign individuality and related concepts, the true demand for decentralized networks will persist;
2. Founder Charm. Satoshi Nakamoto, after inventing Bitcoin and ensuring the smooth operation of the Bitcoin network, disappeared without a trace, holding billions of dollars in assets yet unmoved. From a passionate World of Warcraft player who suffered at the hands of a game company to a co-founder of Ethereum, Vitalik courageously embarked on his decentralized spiritual journey. Solana's founder, Toly, and others were elite professionals in American tech giants, yet unsatisfied, they embarked on their path of building the "capital internet." Not to mention the various major public chains built on the legacy of the Meta Libra network using the Move language. The personal charm and charisma of founders are crucial in the crypto industry. Countless crypto projects have been favored by VCs, embraced by communities, and flooded with funds due to their founders, but also faded into obscurity due to founder resignations or accidents. A good founder is where the true essence of a public chain or a crypto project lies;
3. Developers and User Network. At this point, as emphasized by the Metcalfe Effect and Lindy Effect, the stronger the network effect of the same thing and the longer it exists, the more sustainable it is. The developer and user network is the cornerstone of public chains and many cryptocurrency projects because developers can be considered the first users of a crypto public chain or project and the most long-lasting users;
4. Application Ecosystem. If a tree only has roots but no branches, it will also find it hard to survive, and the same goes for crypto projects. Therefore, a rich and self-sustaining application ecosystem that generates synergies is crucial. Public chains like Ethereum and Solana have been able to survive through crypto winters because of the various application projects that have been consistently developed. Furthermore, the more robust the application ecosystem, the more sustainable the public chain's growth and contribution;
5. Token Market Value. If the aforementioned points are the inner core and foundation of a "moat," then the token market value is the external form and brand image of a public chain and a crypto project. Only when you "appear expensive," will more people believe you "have a lot of money," and you are a "land of opportunity," both individually and as a project;
6. External Openness. In addition to building its internal ecosystem, public chains and other crypto projects need to maintain openness and operability with the external environment, exchanging value with the outside world. Therefore, external openness is also crucial. Taking public chains like Ethereum and Solana as examples, their convenience and scalability lie in their bridging with traditional finance, user funds inflow and outflow, and various industries through payment, lending, and other gateways;
7. Long-Term Roadmap. A truly solid moat not only plays a supporting role in the short term but also needs continuous updates, innovation, and vitality in the long term. For public chains, a long-term roadmap is both a guiding star indicator and a powerful lever to encourage continuous development and innovation within and outside the ecosystem. Ethereum's success is closely related to its long-term roadmap planning.
Based on the elements above, a public chain can move from zero to one, from nothing to something, gradually pass through the period of rapid growth, and enter a mature iterative period. Correspondingly, liquidity and user stickiness naturally follow suit.
Conclusion: The Crypto Industry Has Not Yet Reached the "Talent Showdown" Stage
Recently, Moore Threads, known as the "Chinese version of NVIDIA," successfully landed on the Hong Kong stock market, achieving a milestone of 300 billion RMB on its first day of trading; shortly after, its stock price skyrocketed, reaching another astonishing breakthrough of over 400 billion RMB market cap today.
Compared to Ethereum, which took 10 years to finally reach a market cap of $300 billion, in just a few days, the Moore's Law thread has covered only 1/7 of the former's journey. And compared to the trillion-dollar market cap giants of the US stock market, the crypto industry is truly David to their Goliath.
This also inevitably makes us ponder once again that, with a funding scale and user involvement scale much smaller than those of the traditional financial industry and the internet industry today, we are far from the "talent competition" stage. The only pain point in the current crypto industry is that we do not yet have enough people, the attracted funds are not large enough, and the involved industries are not broad enough. Instead of worrying about those macro, broad "moats," perhaps what we should think about more is how cryptocurrencies can more quickly, at a lower cost, and more conveniently meet the real needs of a broader market user base.
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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) 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.
(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.
(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.
(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.
(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.
(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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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) 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.
(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.
(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.
(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.
(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.
(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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