Written by: Lawyer Liu Honglin

The ups and downs of the cryptocurrency industry are truly exhilarating. Tonight, we were supposed to have a team dinner, but upon returning to the office, a document suddenly landed on my desk. The gist of it was a notification from several ministries regarding further prevention and handling of risks related to cryptocurrencies.

I saw many friends in my social circle sharing related content, and my first feeling was that the sky had fallen again for this industry. I started to go through the entire regulatory document line by line, contemplating whether I should write an interpretative article discussing what this might mean for practitioners in the industry. This includes stablecoins, offshore RMB stablecoins, intermediary services for some foreign institutions providing publicity and traffic within the country, and the very hotly debated RWA (Real World Assets) in mainland China over the past year. The regulatory document detailed these aspects extensively, even to the point of specifying that the business scope in company registrations cannot include cryptocurrencies or virtual currencies. This might sound abstract, but in some so-called economic free trade zones, certain companies have explicitly listed business areas related to the judicial handling of cryptocurrencies.

From a regulatory perspective, there are signs of a resurgence in cryptocurrency and mining, so we see more detailed restrictions on cryptocurrency mining. For instance, in mainland China, it is no longer permissible to sell cryptocurrency mining machines. Previously, this was considered a 3C hardware item, and now this document feels like the sky has fallen, as it has clearly negated the business opportunities that many in the industry were trying to find in the gaps.

Interestingly, within about an hour of this document being released, we saw the China Securities Regulatory Commission (CSRC) issue its first document of 2026, which, in my view, signifies a new dawn.

Why? Because this document clearly states that if approved by the relevant regulatory authorities in mainland China, namely the CSRC, one can engage in RWA activities overseas. This clarifies a potential clause I noticed while reviewing the previous document. The earlier document explicitly stated that first, you cannot engage in RWA in mainland China, and second, you cannot target the Chinese populace while conducting RWA overseas. However, it added an exception clause, allowing such activities with the approval of relevant departments.

I was pondering what this means. What conditions or stipulations might be involved? For which so-called institutions and partners is space being reserved? To my surprise, it turns out to be the CSRC itself. This essentially means that the CSRC, in conjunction with several other ministries, has reiterated the regulatory framework for cryptocurrencies established in China over the past few years, but has left a door open for the CSRC. High-quality domestic assets can engage in RWA overseas with government approval. From this perspective, it seems to brighten the outlook for cryptocurrencies or the entire WEB3 industry in China.

However, I personally believe that this slight brightness has little to do with the vast majority of small teams and ordinary entrepreneurs. This is essentially a very niche securities-related business. This means that those who can engage in such business are likely institutions that have smoother communication with the CSRC. This is very beneficial for partners in mainland China or Hong Kong that are strong in financial innovation, especially in securities-related businesses. However, this has no relation to the consumer rights and anchored dividend discussions that are quite active in the Greater Bay Area and mainland China. So, while the sky has fallen, this represents a serious tightening and contraction for the entire industry. For many knowledge-sharing communities and those assisting foreign exchanges, projects, and top-tier partners, the space for discussing courses and providing consulting services domestically has significantly diminished, as the core clients and market funds should be overseas. Conversely, if you were previously engaged in brokerage-related businesses or overseas development and financing, this actually provides a policy opening from China.

This is a rather subtle situation: after hitting the brakes hard, it suddenly navigates you to an interesting destination. We are quite curious about who will ultimately benefit from this interesting destination. Therefore, I, Lawyer Honglin, will continue to observe this matter and will share further insights if more information arises.

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