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Thirteen Ministries and Seven Associations Issue Document to Prevent Virtual Currency Risks, Where is the Path for RWA?

Summary: On December 5th, seven Chinese industry associations, following a prior inter-ministerial meeting, issued a "Risk Warning on Preventing Illegal Activities Involving Virtual Currencies." This article analyzes the implications for Real World Asset (RWA) tokenization in mainland China. The core conclusion is that RWA projects are effectively prohibited within mainland China. The warning explicitly states that no RWA activities are approved by financial regulators. Key legal obstacles include: 1) classification as illegal fundraising or unauthorized securities issuance, 2) a complete ban on support from financial institutions and payment platforms, and 3) the non-legal status of related stablecoins, which touches on monetary sovereignty. Operating such projects domestically carries significant legal risks, including potential criminal penalties. However, the article identifies a potential path for offshore operations. While the warning also states that overseas service providers targeting mainland customers is illegal, purely offshore businesses (with assets, capital, servers, and entities all outside China, and no involvement of RMB) might be feasible, particularly in jurisdictions like Hong Kong or Singapore. This is framed as a strategic "release valve" connecting China's internal economy with external cycles. Theoretically, using an ODI (Overseas Direct Investment) structure to transfer asset rights to an offshore SPV for tokenization is possible. But in practice, this faces major hurdles: complex cross-border asset verification (often viewed as capital flight), strict scrutiny and potential blockage of fund repatriation, and legal risks for individuals within China managing the business. The current environment is a high-pressure period. The pragmatic advice is to avoid any domestic operations, including targeting Chinese residents or using RMB. For existing projects, the best strategy is to pause or fully transition to a complete offshore model. The emphasis is on longevity over speed, advising thorough legal compliance and structure design for any overseas RWA ventures.

深潮12/29 11:33

Thirteen Ministries and Seven Associations Issue Document to Prevent Virtual Currency Risks, Where is the Path for RWA?

深潮12/29 11:33

After HashKey's IPO: Behind the Glory, How to Balance the Two Bowls of "Coin" and "Stock"?

Following its listing on the Hong Kong Stock Exchange on December 17, 2025, HashKey Group became the first licensed digital asset trading platform to go public in the city. While many view the IPO as a milestone suggesting a future akin to Coinbase, the reality is more complex. Listing marks not an endpoint, but a turning point—introducing new challenges like stock price stability and regulatory compliance in the public markets. HashKey’s stock performance has been cautious, with prices hovering near or below the IPO price, reflecting market wait-and-see sentiment. Unlike Coinbase, whose valuation closely tracks trading volumes and market cycles, HashKey operates as a multi-service compliant platform—covering trading, custody, asset management, and institutional services—making its revenue model slower and less directly tied to market volatility. A core challenge lies in balancing two distinct valuation mechanisms: its publicly traded stock and its native ecosystem token, HSK. While HashKey states that HSK is a utility token for gas fees, structurally separate from the stock, the two assets operate under different market logics—equity markets prioritize transparency, disclosure, and predictability, while crypto markets are driven by narrative, sentiment, and liquidity. This dual structure introduces inherent tensions: How should the company manage disclosures that may affect both markets differently? Could actions meant to support one asset—like stock buybacks or token burns—be perceived as market manipulation? How can it prevent insider information from affecting the 24/7 crypto market? The article argues that sustainable balance isn’t about synchronizing stock and token prices, but about establishing consistent rules and transparent governance. HashKey must demonstrate it can uphold rigorous disclosure standards, avoid conflicts of interest, and maintain trust across both traditional and crypto investor bases—all under the scrutiny of securities law. Ultimately, HashKey’s journey will set a precedent for how Web3 firms can mature within traditional regulatory frameworks, balancing innovation with accountability. Its success will be measured not by short-term price action, but by its ability to navigate this complex dual identity with integrity and clarity.

深潮12/29 11:27

After HashKey's IPO: Behind the Glory, How to Balance the Two Bowls of "Coin" and "Stock"?

深潮12/29 11:27

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