RIP Alipay in Cambodia: The Rise and Fall
Original Article Title: "The Rise and Fall of Wisepay: The 'Cambodian Alipay', Perished Last Night"
Original Article Author: sleepy.txt, Dongcha Beating
December 1, 2025, Phnom Penh.
The breeze by the Mekong River was still hot and humid, but for the hundreds of thousands of Chinese people in the area, this winter was much colder than usual.
This day was destined to be engraved into the collective memory of Cambodian Chinese merchants.
In the morning, Sihanouk Boulevard. The once-revered financial icon, Wisepay's headquarters building, which was thought to be "never sleeping," lost its heartbeat overnight. The roaring sound of cash transport vehicles coming and going was gone, replaced by a cold "Withdrawal Suspension Notice" posted on the glass door and the hundreds of gradually stiffening Oriental faces in front of the main entrance out of fear.
History always rhymes. This scene seemed to transport people back to the eve of the Gold Yuan's collapse in Shanghai in 1948, or the Beijing Financial Street swept by the P2P crisis in 2018.
The collapse was not without warning signs. Over the past 48 days and nights, rumors of the impending collapse of this financial giant known as the "Cambodian Alipay" had spread like a plague in Phnom Penh's underground banks and Telegram groups. From the joint US-UK sanctions against the Prince Group, to the seizure of $15 billion in crypto assets, to the sharp discount of the stablecoin USDH issued by Wisepay in the black market, all signals pointed to the same outcome—liquidity drought.
Wisepay's shutdown was not just the sudden death of a company but also the end of a distorted era of commerce.
Over the turbulent past six years, it had been the most critical capillary of Cambodia's underground economy. It connected the casinos in Phnom Penh, the industrial parks in Sihanoukville, and even the fraud terminals on the other side of the ocean, building an offshore financial island seemingly impervious to the SWIFT system.
Its fall not only froze the assets and lives of tens of thousands of Chinese merchants but also heralded the complete bankruptcy of the "grassroots logic."
The fantasy that one could ignore rules by relying on technological advantages, or that one could evade bullets by hiding in the jungle, finally collided heavily with the geopolitical and regulatory iron plates.
This was a belated settlement, as well as a black coming-of-age ceremony tinged with blood that the generation of Chinese internet grassroots who ventured overseas had to go through.
The Lost Paradise of Tech Elites
If we replay the rise of Huiwang, we will find that its starting point was not evil, but the worship of efficiency to the extreme.
Let's turn back the clock to 2019. That year, China's Internet traffic dividend peaked, and the stock game began. "Going global" became the grand narrative of the tech elites from major companies seeking a new continent. A group of tech middle managers and product managers from major tech companies, carrying the most advanced code architecture and the vision of inclusive finance, landed at Phnom Penh Airport.
At that time, Cambodia's financial ecosystem was still in the Jurassic era.
Bank branches were scarce, operational efficiency was low, and foreign exchange controls were strict. For hundreds of thousands of Chinese merchants engaged in trade, catering, and construction in Phnom Penh, fund circulation was a nightmare. They either carried heavy US dollar cash on the street or endured the high exchange rates of underground money changers.
This kind of backwardness, in the eyes of Chinese Internet people accustomed to mobile payments, was not just a pain point but also a ubiquitous flow and significant arbitrage opportunity.
Using China's mature mobile payment technology to launch a "decimation" on Cambodia's traditional finance became the unspoken action plan of that generation of tech elites venturing abroad.
They did achieve it, and they did it beautifully. At the beginning of Huiwang Pay's launch, it used a kind of "brutal aesthetics" to conquer the market with convenience: a fully Chinese interface, 24/7 online customer service, instant settlement, replicating Alipay's silky-smooth user experience down to the pixel.

However, the real killer move was its extremely low entry threshold. In a country that originally required layers of approval, Huiwang did not require cumbersome identity authentication or tax verification. With just a mobile phone number, funds could flow freely in Phnom Penh's underground network.
This set of tactics was hugely successful in business. In just two years, Huiwang penetrated all aspects of life for Chinese people in Phnom Penh. From buying a cup of milk tea to paying project fees, it became the de facto "Chinese Central Bank" in Cambodia.
However, the neutrality of technology is often the biggest lie in the modern business world.
As these product managers who believed in "user experience first" ran wild in Phnom Penh, they quickly ran into a temptation that was unimaginable domestically—a vast wave of black-hat and gray-hat industries.
In the compliant business world, the core barrier for payment institutions is risk control; however, in Phnom Penh, the most profitable customers were gambling groups and fraud parks, and the service they needed most was precisely "risk-free."
For these behemoths, the fee rate is not important; what is important is concealment and security. They do not need a compliant e-wallet; what they need is an underground river that can instantly launder billions of dollars of black money.
This is a classic business ethics dilemma: when the growth KPI clashes with the compliance bottom line, who should technology bow to?
Huiwang chose to bow to growth.
They began to "optimize" the money laundering process with an internet-centric mindset. To retain these elite clients, they proactively removed facial recognition and relaxed transfer limits. In their logic, this was still "serving users" and "addressing pain points." They used "technology is innocent" to self-hypnotize, believing they were just building roads, with no concern for whether the trucks on the road were transporting goods or dirty money.
It was this "technological tool rationality" alienation that transformed Huiwang from a convenient payment tool into Southeast Asia's largest money laundering hub.
They thought they were the Jack Ma of Phnom Penh, using technology to transform business; little did they know that in the jungle without rules, they ultimately lived as Du Yuesheng by the Mekong River.
But this was only the beginning of their fall. Once the payment channels were opened, these clever individuals found another even more lucrative and darker track—introducing the "e-commerce escrow transaction" model into the human trafficking chain.
The Sinister SKU
In all internet business textbooks, the "platform model" is seen as the ultimate evolution of business. After Huiwang opened up the underlying infrastructure of payments, its ambition naturally extended to the transaction link.
In the jungle of Phnom Penh filled with fraud and violence, the scarcest resource is not the dollar, nor the headcount, but "trust."
This is a typical dark forest where the snakehead takes money but does not deliver people, the park takes people but does not pay, and the money laundering intermediary absconds with the funds. The high risks of eating each other alive greatly hinder the transaction efficiency of the dark industry.
For those product managers, this is not evil at all; it is clearly a perfect "trust mechanism optimization scenario."
In 2021, "Huiwang Guarantee" emerged out of nowhere.
Its product logic was simply a perfect replica of Taobao's; the buyer (fraudulent park) entrusted funds to the platform, the seller (human trafficker) shipped the goods, the buyer confirmed receipt after inspection, and the platform disbursed the loan and deducted a commission.
This set-up, used in Hangzhou to allow consumers to buy dresses with confidence, was used in Sihanoukville to buy and sell "frontend developers."
In the thousands of active Telegram groups of Huiwang Guarantee day and night, people were completely objectified into cold, hard SKUs.
Each supply and demand message in the group has been meticulously standardized and packaged, much like a Singles' Day product detail page:
「Proficient in Java, two years of experience at a top-tier company, obedient and compliant, passport in hand, all yours for a fixed price of 20,000 U.」
「Seeking to buy: European and American market promotion team, self-owned resources, price negotiable, escrow available.」
For the tech personnel maintaining systems in air-conditioned rooms, this is merely lines of code and data. They don't need to see how those individuals known as 'merchandise' are stuffed into vans, they don't need to hear the cries of agony under the stun baton; they only need to focus on the backend, each order and transaction volume, and the constantly rising GMV.
According to data from blockchain analysis company Elliptic, since 2021, the platform has facilitated transactions worth at least $24 billion through cryptocurrency. This is not just a number; it is the sum total of countless individual fates converted into chips.
Even more chilling is the frenzied iteration of product features.
To meet the park's demand for pursuing escapees, Huibang Guarantee has even spawned a 'bounty' business.
In those secretive groups, violence is no longer rampant barbarism but a priced and value-added service that can be ordered with a click: 「Capture a fleeing programmer, bounty of 50,000 USDT; provide effective localization, bounty of 10,000 USDT.」
This unrestrained expansion ultimately drew the gaze of the hunters. In February 2025, under pressure from the U.S. FBI, Telegram shut down Huibang Guarantee's main channel. This should have been a devastating blow, but the black market's resilience exceeded everyone's imagination.

Just a week later, hundreds of thousands of users seamlessly migrated to another chat app called Potato Chat through alternate links, like a tidal wave.
Telegram is known as the 'paper airplane' in the circle, while Potato Chat is referred to as the 'potato.' Compared to an airplane flying in the sky, the potato is deeply buried underground, more clandestine, and harder to be targeted by regulatory radar.
In this mass migration, the Huibang Group not only played a guiding role but also operated behind the scenes. They not only invested in 'Potato,' achieving a business reincarnation, but also developed an independent communication app called ChatMe, attempting to build a completely closed-loop, self-sufficient digital underworld kingdom.

This guerrilla warfare tactic of cunning rabbits is not just a mockery of regulation, but also a profound arrogance.
They firmly believe that as long as the code is written fast enough, they can outsmart the law; as long as the servers are hidden deep enough, they can build a lawless land outside of real-world rules. But they forget that even the servers of the dark web ultimately need electricity.
While they are busy changing identities in the virtual world, in the real world, an iron net targeting the money chain is quietly tightening.
Symbiosis Mode
In the chess game of finance, the highest power has never been about how many chips you have, but about having the power to define the chips.
The operators at Huwang keenly realize that no matter how many identities they change, as long as they still use USDT, their lifeline is always held by the Americans across the ocean, because Tether can cooperate with the FBI at any time to freeze on-chain assets with a single click.
So, they decide to establish their own Federal Reserve on the Mekong River.
In September 2024, Huwang officially issued the stablecoin USDH.
In the provocative official promotional material, the core selling point of USDH is blatantly defined as "assets cannot be frozen" and "not subject to traditional regulation." This is essentially a rallying cry to the global dark industry—a place where there is no FBI, no anti-money laundering laws, a place that is an absolutely free financial utopia.

To promote this digital IOU issued by a private company, Huwang launched a financial product within various large industrial parks that made Wall Street blush—a deposit in USDH with an annualized return of 18% and a total return of 27% at maturity.
Then, a highly ironic scene unfolded. Those scam artists who were crazily rug pulling around the world, lured by this 18% high-interest rate, eventually willingly deposited the hard-earned illicit funds back into Huwang's liquidity pool.
In the underground world of Phnom Penh, those self-proclaimed clever rug pull operators failed to realize that in the face of the larger rug pull at Huwang, they themselves had also become "piglets" waiting to be slaughtered.
Where does this kind of "independent nation-building" arrogance come from?
If we look at the board of directors of Huwang Pay, a prominent name stands out: Hun To.
What does this name mean in Cambodia? He is the nephew of former Prime Minister Hun Sen and the cousin of current Prime Minister Hun Many. According to a report by the U.S. Department of the Treasury, this figure who moves in the core of power in Phnom Penh is not only a director of Huwang but also the umbilical cord connecting this company to the highest power in Cambodia.

This is the most secretive "symbiotic model" in the Southeast Asian cybercriminal underworld.
The Chinese team is responsible for providing the technology. They use code from tech giants to build a payment system, utilize e-commerce logic to manage human trafficking, and employ blockchain technology to evade regulation. The local elites are responsible for providing the licensing rights. They offer legitimate bank licenses, turn a blind eye to the guarded compounds, and even ensure that the police ignore cries for help from within the high walls.
Technology provides efficiency, while power provides security. It is precisely because of this top-level "umbrella of protection" that they dare to publicly offer bounties for capturing individuals and even dare to issue a private currency challenging the dominance of the US dollar. For them, the law is not an untouchable red line but rather a commodity that can be purchased in bulk through interest-driven transactions.
This naked exchange of interests often masquerades under a cloak of heartwarming charity.
In Chinese-language newspapers in Cambodia, you can often see this scene: a senior executive from Huawang adorned with a ribbon, receiving an honor certificate from the elite, donating a large sum of money to a impoverished school, all the while beaming with a compassionate smile.
Simultaneously, in the Huawang guarantee group chat, money laundering transactions dripping with blood are frantically filling the screen.
The morning hosts an evil trading platform, while the afternoon hosts a charitable charity banquet.
This extreme sense of duality is not hypocrisy but a necessary means of survival. Just as back in the day Du Yuesheng in Shanghai established the position of "social virtuoso" through running schools and maintaining public order, along the Mekong River, "charity" is a special tax paid to the core of power, a whitening agent to cleanse one's identity, and most importantly, the lubricant that sustains the operation of this vast symbiotic entity.
This carefully woven web of political-business relationships once brought Huawang a sense of security for several years. They once believed that as long as they had secured their relationships in Phnom Penh, they could operate on the edge of the rule of law.
Until October 2025, when a butterfly from across the ocean began to flap its wings.
The sanction storm that started in Washington not only overturned the seemingly indestructible umbrella of protection but also directly shattered the fragile cornerstone of this "shadow central bank."
When Grassroots Wisdom Meets the Financial Iron Curtain
In the traditional logic of China's county-level economy, there are usually two ways to deal with trouble: either pull strings or change identities.
As the crisis began to emerge, Huawang's operators attempted to use the same old tricks. Even after their banking license was revoked in March 2025, they naively tried to distract by rebranding as "H-Pay" and claiming to "expand into Japan and Canada."
In their cognitive inertia, as long as the gold-edged panda statue is still standing, as long as the Hun Sen family's stake remains, this is once again a minor issue that can be easily resolved with money.

But this time, their opponent is no longer a local police officer accepting bribes, but the heavily armed U.S. national machinery.
On October 14, 2025, a massive black swan event occurred. The U.S. Department of Justice announced the seizure of $15 billion in cryptocurrency owned by Chen Zhi, under the Prince Group.
This sent shockwaves throughout Southeast Asia. Keep in mind that Cambodia's GDP in 2024 was only around $46 billion. This was not just an asset seizure; it was akin to directly draining one-third of the underground economy of this country.
For Huixiang, the Prince Group was not only its largest client but also the source of its liquidity. With the source dried up, downstream activities were bound to perish.
What added to their despair was the nature of the strike.
For a long time, the dark web had a near-superstitious misunderstanding of USDT, considering it to be "decentralized" and beyond legal control. However, USDT is, in reality, highly centralized. While the FBI cannot directly command Tether, as a business entity eager to access the mainstream financial system, Tether must strictly adhere to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) sanctions list.
When U.S. regulatory bodies issue a long-arm jurisdiction injunction, no SWAT teams are needed, nor lengthy transnational litigations. Tether's backend will freeze the related addresses. The hundreds of millions of dollars on-chain instantly become untransferable "dead money."
This was a form of warfare they had never comprehended. This group of clever individuals who rose to prominence by exploiting legal loopholes, the smartest thing they had ever done was to find a way around obstacles. But this time, their opponent tore down the load-bearing walls directly.
In the dust of the collapsing building, the ones who suffocated first were always the bottom-rung ants.
At the end of Huixiang's ecosystem, there is a large group of participants — the liquidity providers. In Phnom Penh, they are the human cash delivery motorcycles; in mainland China, they are the rent-a-house teams conducting transfers from obscure locations. They earn a meager one-tenth of a percent through exchange rate differentials but bear the highest risk in the entire system.
In the past, they were the most sensitive nerve endings of Huixiang's machine; now, they have become the most direct cannon fodder in the card-blocking operation.
In the Telegram "Frozen Friends Chat Group," there are thousands of desperate pleas every day. Their entire bank accounts are frozen, they are listed on a fraud punishment list, unable to even take a high-speed rail or plane, and they may even face the criminal risk of being arrested upon returning to their home country.
Once part of a fleet that made a fortune in a day, they have now become inmates in a high-risk cage. They hold USDH that they cannot sell, their domestic accounts are frozen, and they are trapped in a foreign land.
A Generation's Funeral
When the glass door of the PlusToken headquarters was posted with a notice, it wasn't just a company that fell but an era.
It was a requiem for the era of Chinese Internet companies venturing abroad, a historical footnote filled with fantasies and ambitions.
Within that specific time window, some entrepreneurs venturing abroad carried a "big baby mentality" into the Southeast Asian jungle. They desired both the windfall and freedom of lawless lands and the rules and security of the civilized world; they believed only in relationships and technology, yet had no reverence for the law.
They believed technology to be a neutral tool, unaware that a tool in the hands of those without boundaries would become a weapon of evil; they thought of globalization as escaping from one cage to the wilderness, not realizing that globalization meant moving from one set of rules to another more stringent set of rules.
The rise and fall of PlusToken are a modern fable about the "banality of evil."
Initially, they just wanted to create a user-friendly payment tool to solve the pain points of currency exchange; later, for growth, they turned into accomplices of the gray industry; then, in pursuit of windfall profits, they became architects and participants of sin.
The moment a person decides to establish order for evil, they are doomed not to turn back.
Years later, as the new generation of entrepreneurs venturing abroad sit in a gleaming new office in Phnom Penh, discussing ESG and compliant listings over Starbucks, perhaps no one will remember how much evil flowed through the city's underground cables.
Nor will anyone remember how many self-righteous "Du Yueshengs" were buried in the night on the Mekong River.
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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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