When AI Starts Spending Money: Who Will Underwrite Agent Transactions?

By: blockbeats|2025/12/22 19:00:01
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Original Article Title: Payments in the Agentic Economy
Original Article Authors: Saurabh Deshpande, Oliver Jaros, Decentralised.co
Original Article Translation: AididaoJP, Foresight News

In the article "Internet Pricing," we previously discussed: When payment is frictionless, machines will automatically make payments. Humans have not fully embraced micro-payments because focusing on the measuring process requires effort and attention. But machines are different; they only see 1s and 0s. Their cognitive capacity or task switching does not affect their execution. If breaking down to sub-cent levels can make the process more efficient, they will do so, unlike humans.

In our previous article, we ended with a question: What happens when the agent messes up? The agent's intent is not important. The key is that we cannot oversee the agent step by step.

This leads us to a dilemma: new technology has not inherited a significant advantage of the old infrastructure, such as the ability to reverse payments in case of errors. This article aims to explore this issue. We will discuss what agents need to achieve autonomy, who is building the foundation for it, and why new startups are emerging at the intersection of blockchain payment channels and autonomous agents.

Emerging Standards

Any business activity involves three parties: the buyer, the seller, and the intermediary facilitating the transaction. The intermediary can be a platform like Amazon or a payment processing network like Visa.

When AI Starts Spending Money: Who Will Underwrite Agent Transactions?

Buyer

Consumer applications typically handle funds or transactions and take a cut. But what happens when the consumer is an AI acting on our behalf? Several emerging standards are currently seeking answers to this.

ChatGPT has 700 million active users, all trying to obtain information or services through AI. While we have not yet directly bought and sold goods through an agent interface, we commonly use it to "discover" products. Whether buying running shoes or finding a hotel in El Calafate, I use AI for price comparison. If direct purchases could be made on the same interface, it would undoubtedly be much more convenient. This is precisely the goal of OpenAI partnering with Stripe to introduce the Autonomous Commercial Protocol (ACP).

Source: OpenAI

This is currently the most direct way for agents to handle funds: user full control. After the user places an order, ChatGPT sends the necessary information to the merchant's backend through ACP. The merchant then decides to accept or reject the order, processes the payment through the existing payment service provider, and handles shipping and customer service as usual.

You can think of ACP business as follows: you authorize an intern to spend a fixed budget, and you have the final say in choosing which product/service to purchase from which merchant and completing the payment.

OpenAI and Stripe have ACP, while Google has introduced the Agent Payment Protocol (AP2). Before delving into AP2, let's take a step back. Google aims to address the "interoperability" issue. Currently, AI agents operate independently: Gemini doesn't talk to Claude, and ChatGPT doesn't know what's happening in Perplexity.

Ideally, when tasks become more complex and require collaboration, we hope these agents can communicate using a common language. To achieve this, Google has developed A2A (Agent-to-Agent Protocol), allowing different agents to communicate and coordinate.

But just being able to converse is not enough. Agents also need to be able to use tools, access APIs, and services. The Model Context Protocol (MCP) enables agents to use tools such as Google Calendar, Notion, Figma, and others.

Source: Level Up Coding

The MCP defines a common language. As long as they both "speak" MCP, agents can use any tool without the need for additional custom code. The protocol was created by Anthropic, but the specification is open and is quickly being adopted by various companies. The MCP server essentially acts as a translation layer, positioned in front of a company's existing APIs, exposing services in a standardized format to any MCP-compatible agent.

Returning to AP2, it can be understood simply as follows: MCP gives agents the ability to access data, files, and tools; A2A gives them the voice to communicate with each other; and AP2 provides them with a wallet to securely spend money.

All of these protocols place the user at the center, with agents having limited spending authority. This addresses distribution and process issues, but it still doesn't address: what happens if an agent makes a mistake?

Seller

The story is not only about the buyer. Sellers are also setting new standards, focusing on how machines can pay for access to APIs, data, and content.

Currently, the most discussed standard is the x402 standard, an open protocol developed by Coinbase. It resurrects the long-defined but never used HTTP status code 402 from 1997 — "Payment Required." x402 combines this with stablecoin payments, enabling microtransactions to settle economically, thus giving new life to this status code.

x402 turns an HTTP request into a payment request. Whenever payment is required, the server makes the demand. As the agent has a preset budget, it pays the server and receives the data in the same process. This enables "pay-as-you-go" or "pay-per-call" to become feasible in machine-to-machine transactions.

With x402, the agent can precisely pay for what is needed at the moment. For example, paying 2 cents to read a paid article or paying a fraction of a cent for an API call. Transactions settle on-chain within seconds, without the need to establish a long-term relationship.

Source: Coinbase's x402 Whitepaper

Cloudflare has adopted this concept and built a more specific "pay-per-fetch" system. It also uses HTTP 402 at its core, but the key is Cloudflare's market dominance, with 20% of global internet traffic passing through its network, giving it significant influence.

"Pay-per-fetch" leverages Cloudflare's edge network, requesting payment before providing content to AI crawlers. This turns access to content into a metered force. Publishers are facing a plummet in traffic as people no longer land on websites via search engines but directly consume AI-generated summaries. Through this system, publishers can charge the AI lab every time the crawler accesses content.

Card networks are also attempting to extend existing payment channels to handle agent transactions. Visa has introduced the MCP Server and Acceptor Agent Toolkit. Mastercard has a project called "Agent Pay." Both are in early pilot stages, but their significance lies in Visa and Mastercard's global distribution networks, issuer relationships, and extensive merchant acceptance networks. The basic idea is to register agents, set spending controls, and enable agents to transact on the existing human credit card payment network.

Urgent Need to Fill the Trust Gap

All of the above standards assume that payments will proceed smoothly and the outcomes will meet expectations. Both ACP and AP2 involve human intervention at the checkout stage, providing a certain level of security. The x402 variant deals with machine-to-machine data access, with generally lower risk. The card issuer extends its familiar protection mechanisms, but at the cost of slow settlement and high fees.

For large-scale micropayments, speed is the primary goal. Card payment networks take several days to settle, with merchants paying a percentage of the transaction amount in fees. Cryptocurrency channels settle in seconds and cost less than a cent. However, this efficiency comes with irreversibility—once a cryptocurrency payment is made, it cannot be undone.

Traditional commerce has built a whole infrastructure around "things can go wrong." When an issue arises with a credit card purchase, you have a process to follow: contact the bank, raise a dispute, have the card issuer investigate and possibly withhold funds, and ultimately reach a decision on a refund or support for the merchant. In 2025, there were 261 million disputed transactions worth a total of $340 billion.

However, agents operating on stablecoin channels have none of these protections.

When agents begin to collaborate, the situation becomes more complex. When hundreds or thousands of multilayered agent workflows intertwine, clarifying responsibilities could become a nightmare.

Card issuers will not take on this risk, at least not under their current profit models. Visa and Mastercard's agent initiatives still charge standard interchange fees, and settlements still take days. They could move to instant stablecoin settlements, but that would mean giving up the dispute resolution system that forms the basis of their charges.

The dispute resolution mechanism in traditional finance was not inherent. The first credit card (Diners Club) emerged around 1950, but consumers had to wait another 24 years to gain transaction dispute rights. The modern infrastructure we take for granted today was gradually built up as issues arose.

Autonomous agents don't have as much time to waste. API requests make up 60% of the dynamic HTTP traffic Cloudflare handles. Bots and automated traffic represent nearly half of internet traffic. ChatGPT's 700 million users can now check out directly on Etsy via ACP, and Shopify integration is on the horizon. Transaction volumes already exist, users have the potential demand for agents to handle tasks, and agents for commercial purposes are not far off.

Therefore, we face a choice: continue with the slow settlement of traditional financial infrastructure, or consciously build trust infrastructure to match the swift blockchain settlements. The former will constrain agent potential, while the latter is an opportunity and a natural extension of autonomous agent business development.

So, What's the Specific Process?

As expected, this involves two parts: pre-transaction and post-transaction.

Pre-Transaction: Should Proxy Transactions Be Allowed?

This depends on three factors: identifying the counterparty, fraud detection, and using reputation scores to determine pricing and access rights.

In the U.S., Plaid connects nearly half of bank accounts, verifying millions of accounts daily. When you verify your identity on Venmo, you are using Plaid.

Currently, any agent interacting via API, scraping web pages, or initiating payments lacks peer-to-peer authentication. The server only sees a vague ID (such as a wallet address or API key) and does not know who the caller is. Without a universal cross-service identity, there is no way to build trust, and each interaction starts from a "zero-trust" standpoint.

By 2024, U.S. adults are projected to lose around $47 billion due to identity fraud.

We need a "Know Your Agent" (KYA) layer, similar to what Plaid provides for fintech's identity infrastructure. It should issue persistent and revocable credentials that bind agents to the humans or organizations behind them.

Card networks have spent decades building systems that can identify suspicious patterns from millions of transactions. They understand typical human spending behavior and can flag anomalies in real time. If an agent is compromised and conducts unauthorized transactions across multiple merchants, there is currently no shared fraud graph to detect it.

Visa states that after investing $11 billion in security from 2019 to 2024, their systems prevented $400 billion in fraud attempts. Stripe processes over $1.4 trillion in payments annually and uses this data to train its Radar fraud prevention system. During Black Friday and Cyber Monday in 2024, Radar blocked 20.9 million fraudulent transactions worth $9.17 billion.

Proxy transactions currently lack such fraud detection layers. When a proxy makes an x402 payment, there is no shared system to flag anomalous behavior, such as an unexpected surge in spending or unusual frequency.

Without persistent identity and reputation, each agent interaction starts from scratch. Reputation is deeply embedded in human commerce: the ads you see are based on browsing history, Uber drivers' acceptance is influenced by ratings, and your credit score follows you to every financial institution. This should be true for agents as well.

Post-Transaction: What If Something Goes Wrong?

Chargeback is a card network's way of handling disputes: when a customer disputes a transaction through the bank, funds are pulled back from the merchant. However, this process is often abused. In 2023, chargebacks cost merchants around $117.47 billion. For every $1 lost to chargeback, merchants typically incur an additional $3.75-4.61 in other costs (including fees, lost goods, and administrative expenses).

Source: Coinbase's x402 Paper

Merchants win only 8.1% of actively contested disputes. 84% of customers believe initiating a chargeback with their bank is easier than seeking a refund from the merchant.

Agent-initiated stablecoin transactions settle in seconds and are currently irreversible. Cloudflare has proposed a delayed settlement extension for x402, allowing for a "waiting period" to be set before final fund transfer.

Developers have been working on laying the groundwork for this infrastructure. At the ETHGlobal Buenos Aires hackathon, a team created Private-Escrow x402. Their escrow solution involves: buyers prepaying funds to a smart contract, signing a "payment intent" off-chain at the time of payment. A coordinator batches hundreds of such signatures into a single settlement transaction, reducing Gas fees by 28x.

However, this is just a foundational component that still needs to be productized.

Who Will Build All This?

This reminds me of the era dominated by telecom operators. They had billing relationships with every mobile user but missed out on the value created by smartphones. App distribution and mobile advertising generated billions of dollars in revenue, a domain that could have been captured by telcos.

Payment networks now find themselves in a similar position. Visa and Mastercard have spent decades building the trust infrastructure that the self-sovereign agent economy lacks. However, their business model relies entirely on interchange fees, which are predicated on their control of the payment rails. They invest heavily in maintaining this infrastructure, funded by a few percentage points of transaction volume. Offering consumer protection for stablecoin transactions would essentially mean subsidizing competitors' payment rails with their own revenue.

If payment networks don't act, the next contenders in line are OpenAI, Google, Anthropic, and other AI labs. They all want widespread adoption of their agents. But being centralized identity registries mean that they would be held accountable when agents misbehave. They wouldn't want to be the arbiters of "you booked the wrong hotel."

They would rather have a third party build the identity and recourse infrastructure for them to plug directly into, much like accessing payments or search engines today.

Cloudflare is in a unique position. They have handled massive amounts of web traffic, run bot detection, and have an "AI Audit" tool that allows publishers to track bot visits. Going from "identifying bots" to "verifying proxy identity and reputation" is not a huge technical leap.

But Cloudflare has always touted itself as neutral infrastructure. Once it starts issuing trust scores or arbitrating disputes, it becomes more like a regulatory body — a different business altogether and a different set of responsibilities.

Three Entry Points for Startups

You can't beat OpenAI on model quality, and you can't surpass Cloudflare on traffic. You need to find parts of the technology stack that their business models (at least for now) don't allow them to touch but still hold value. I think there are three entry points: identity, recourse, and attribution.

Proxy identity is the most direct. The registration model has been validated. While Plaid is a classic example, but very apt: they did identity verification for bank accounts. Startups can do the same for proxies: issue credentials, build reputation, and allow merchants to verify reputation before receiving payments. Its moat comes from network effects: once enough merchants verify through your registry, the proxy has to maintain a good reputation record.

Recourse mechanism is more challenging because it requires taking on risk. You can think of it as insurance: charge a small fee for each transaction, and bear the loss in case of issues. Scale is key. Card interchange rates range from 1.5% to 3%, which includes dispute resolution costs. Stablecoin channels cost much lower than this, so a recourse layer can very well offer comparable protection with a 0.5% fee and still have room for profit.

Attribution mechanism is the most forward-looking but will inevitably emerge. When proxies start influencing purchase decisions, brands will pay to impact recommended content. An auction mechanism can be designed. But it has a "cold start" problem, requiring brands, proxies, and merchants to participate in the market together to function, a challenge that the first two entry points do not have.

The importance of these three entry points varies with the development stage of the proxy economy:

· Identity becomes critical when proxies no longer require manual approval per transaction.

· Recourse becomes crucial when proxies start handling real funds.

· Attribution, on the other hand, will only kick in once the volume of transactions between proxies is sufficient to support an advertising market.

This leads to a practical development trajectory:

Source — Chart generated using Claude

Startup to Build Partial Agent Economy Infrastructure

The development of agents can be divided into three stages:

· As an interface for interaction

· Performing under human supervision

· Autonomous exchange with each other

We are currently in the first stage. An example is ChatGPT's Etsy checkout integration: we browse products in a chat interface (though not exclusive), the agent recommends options, but the final decision is made by a human. Trust is fully borrowed from existing infrastructure.

This stage favors existing giants as it is a distribution game to capture user entry points. The value accrues in the hands of players who own the purchasing decision interface.

The hallmark of the second stage is agents gaining more autonomy. Agents no longer just suggest itineraries but directly book flights, rental cars, hotels. We provide goals or constraints, agents execute, and we accept the results.

At this point, the trust layer becomes indispensable. Without recourse mechanisms, users won't authorize agents; without authentication, merchants won't accept agent payments.

This is where the opportunity lies for startups. Existing giants may lack the incentive to build trust infrastructure for stablecoin channels as they have significant room for growth in the current stage (still self-led). OpenAI generated $13 billion in revenue this year. In comparison, Tether made $10 billion in profit in just the first ten months of 2025, with higher annual profit expected.

An identity, recourse, attribution layer will be constructed by new companies dedicated to solving specific issues at the boundary of agent capability and user authorization.

The third stage is the autonomous agent economy. Your agent does not need approval for daily decisions; it can negotiate with other agents, bid on computational resources, participate in ad auctions, settle thousands of small transactions continuously. Stablecoins, due to their ability to handle the volume, speed, and granularity of machine-to-machine transactions, will become the default settlement layer.

The competitive focus in this stage will no longer be the best model or the fastest public chain but who has built the most trusted infrastructure: the agent's "passport," the "court" for dispute resolution, the "credit system" allowing overbalance transactions. These institutions serving software will determine which agents can participate in the economy under what conditions.

Conclusion

We have laid the pipes for agents to "spend" money, but we have not yet constructed the mechanisms to validate whether they "should spend" it. HTTP 402 has been dormant for thirty years, only to be revived by the feasibility of microtransactions. The technical challenges have been resolved. However, the trust infrastructure that underpins human commerce, such as identity verification, fraud detection, and dispute resolution, lacks equivalent agent-friendly versions. We have addressed the easy part. It will take time to enable agents to transact with confidence.

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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk


Foreword: Today, the People's Bank of China's website published the "Notice of the People's Bank of China, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration for Market Regulation, China Banking and Insurance Regulatory Commission, China Securities Regulatory Commission, State Administration of Foreign Exchange on Further Preventing and Dealing with Risks Related to Virtual Currency and Others (Yinfa [2026] No. 42)", the latest regulatory requirements from the eight departments including the central bank, which are basically consistent with the regulatory requirements of recent years. The main focus of the regulation is on speculative activities such as virtual currency trading, exchanges, ICOs, overseas platform services, and this time, regulatory oversight of RWA has been added, explicitly prohibiting RWA tokenization, stablecoins (especially those pegged to the RMB). The following is the full text:


To the people's governments of all provinces, autonomous regions, and municipalities directly under the Central Government, the Xinjiang Production and Construction Corps:


  Recently, there have been speculative activities related to virtual currency and Real-World Assets (RWA) tokenization, disrupting the economic and financial order and jeopardizing the property security of the people. In order to further prevent and address the risks related to virtual currency and Real-World Assets tokenization, effectively safeguard national security and social stability, in accordance with the "Law of the People's Republic of China on the People's Bank of China," "Law of the People's Republic of China on Commercial Banks," "Securities Law of the People's Republic of China," "Law of the People's Republic of China on Securities Investment Funds," "Law of the People's Republic of China on Futures and Derivatives," "Cybersecurity Law of the People's Republic of China," "Regulations of the People's Republic of China on the Administration of Renminbi," "Regulations on Prevention and Disposal of Illegal Fundraising," "Regulations of the People's Republic of China on Foreign Exchange Administration," "Telecommunications Regulations of the People's Republic of China," and other provisions, after reaching consensus with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, and with the approval of the State Council, the relevant matters are notified as follows:


  I. Clarify the essential attributes of virtual currency, Real-World Assets tokenization, and related business activities


  (I) Virtual currency does not possess the legal status equivalent to fiat currency. Virtual currencies such as Bitcoin, Ether, Tether, etc., have the main characteristics of being issued by non-monetary authorities, using encryption technology and distributed ledger or similar technology, existing in digital form, etc. They do not have legal tender status, should not and cannot be circulated and used as currency in the market.


  The business activities related to virtual currency are classified as illegal financial activities. The exchange of fiat currency and virtual currency within the territory, exchange of virtual currencies, acting as a central counterparty in buying and selling virtual currencies, providing information intermediary and pricing services for virtual currency transactions, token issuance financing, and trading of virtual currency-related financial products, etc., fall under illegal financial activities, such as suspected illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures business, illegal fundraising, etc., are strictly prohibited across the board and resolutely banned in accordance with the law. Overseas entities and individuals are not allowed to provide virtual currency-related services to domestic entities in any form.


  A stablecoin pegged to a fiat currency indirectly fulfills some functions of the fiat currency in circulation. Without the consent of relevant authorities in accordance with the law and regulations, any domestic or foreign entity or individual is not allowed to issue a RMB-pegged stablecoin overseas.


(II)Tokenization of Real-World Assets refers to the use of encryption technology and distributed ledger or similar technologies to transform ownership rights, income rights, etc., of assets into tokens (tokens) or other interests or bond certificates with token (token) characteristics, and carry out issuance and trading activities.


  Engaging in the tokenization of real-world assets domestically, as well as providing related intermediary, information technology services, etc., which are suspected of illegal issuance of token vouchers, unauthorized public offering of securities, illegal operation of securities and futures business, illegal fundraising, and other illegal financial activities, shall be prohibited; except for relevant business activities carried out with the approval of the competent authorities in accordance with the law and regulations and relying on specific financial infrastructures. Overseas entities and individuals are not allowed to illegally provide services related to the tokenization of real-world assets to domestic entities in any form.


  II. Sound Work Mechanism


  (III) Inter-agency Coordination. The People's Bank of China, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of virtual currency-related illegal financial activities.


  The China Securities Regulatory Commission, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of illegal financial activities related to the tokenization of real-world assets.


  (IV) Strengthening Local Implementation. The people's governments at the provincial level are overall responsible for the prevention and disposal of risks related to virtual currencies and the tokenization of real-world assets in their respective administrative regions. The specific leading department is the local financial regulatory department, with participation from branches and dispatched institutions of the State Council's financial regulatory department, telecommunications regulators, public security, market supervision, and other departments, in coordination with cyberspace departments, courts, and procuratorates, to improve the normalization of the work mechanism, effectively connect with the relevant work mechanisms of central departments, form a cooperative and coordinated working pattern between central and local governments, effectively prevent and properly handle risks related to virtual currencies and the tokenization of real-world assets, and maintain economic and financial order and social stability.


  III. Strengthened Risk Monitoring, Prevention, and Disposal


  (5) Enhanced Risk Monitoring. The People's Bank of China, China Securities Regulatory Commission, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration of Foreign Exchange, Cyberspace Administration of China, and other departments continue to improve monitoring techniques and system support, enhance cross-departmental data analysis and sharing, establish sound information sharing and cross-validation mechanisms, promptly grasp the risk situation of activities related to virtual currency and real-world asset tokenization. Local governments at all levels give full play to the role of local monitoring and early warning mechanisms. Local financial regulatory authorities, together with branches and agencies of the State Council's financial regulatory authorities, as well as departments of cyberspace and public security, ensure effective connection between online monitoring, offline investigation, and fund tracking, efficiently and accurately identify activities related to virtual currency and real-world asset tokenization, promptly share risk information, improve early warning information dissemination, verification, and rapid response mechanisms.


  (6) Strengthened Oversight of Financial Institutions, Intermediaries, and Technology Service Providers. Financial institutions (including non-bank payment institutions) are prohibited from providing account opening, fund transfer, and clearing services for virtual currency-related business activities, issuing and selling financial products related to virtual currency, including virtual currency and related financial products in the scope of collateral, conducting insurance business related to virtual currency, or including virtual currency in the scope of insurance liability. Financial institutions (including non-bank payment institutions) are prohibited from providing custody, clearing, and settlement services for unauthorized real-world asset tokenization-related business and related financial products. Relevant intermediary institutions and information technology service providers are prohibited from providing intermediary, technical, or other services for unauthorized real-world asset tokenization-related businesses and related financial products.


  (7) Enhanced Management of Internet Information Content and Access. Internet enterprises are prohibited from providing online business venues, commercial displays, marketing, advertising, or paid traffic diversion services for virtual currency and real-world asset tokenization-related business activities. Upon discovering clues of illegal activities, they should promptly report to relevant departments and provide technical support and assistance for related investigations and inquiries. Based on the clues transferred by the financial regulatory authorities, the cyberspace administration, telecommunications authorities, and public security departments should promptly close and deal with websites, mobile applications (including mini-programs), and public accounts engaged in virtual currency and real-world asset tokenization-related business activities in accordance with the law.


  (8) Strengthened Entity Registration and Advertisement Management. Market supervision departments strengthen entity registration and management, and enterprise and individual business registrations must not contain terms such as "virtual currency," "virtual asset," "cryptocurrency," "crypto asset," "stablecoin," "real-world asset tokenization," or "RWA" in their names or business scopes. Market supervision departments, together with financial regulatory authorities, legally enhance the supervision of advertisements related to virtual currency and real-world asset tokenization, promptly investigating and handling relevant illegal advertisements.


  (IX) Continued Rectification of Virtual Currency Mining Activities. The National Development and Reform Commission, together with relevant departments, strictly controls virtual currency mining activities, continuously promotes the rectification of virtual currency mining activities. The people's governments of various provinces take overall responsibility for the rectification of "mining" within their respective administrative regions. In accordance with the requirements of the National Development and Reform Commission and other departments in the "Notice on the Rectification of Virtual Currency Mining Activities" (NDRC Energy-saving Building [2021] No. 1283) and the provisions of the "Guidance Catalog for Industrial Structure Adjustment (2024 Edition)," a comprehensive review, investigation, and closure of existing virtual currency mining projects are conducted, new mining projects are strictly prohibited, and mining machine production enterprises are strictly prohibited from providing mining machine sales and other services within the country.


  (X) Severe Crackdown on Related Illegal Financial Activities. Upon discovering clues to illegal financial activities related to virtual currency and the tokenization of real-world assets, local financial regulatory authorities, branches of the State Council's financial regulatory authorities, and other relevant departments promptly investigate, determine, and properly handle the issues in accordance with the law, and seriously hold the relevant entities and individuals legally responsible. Those suspected of crimes are transferred to the judicial authorities for processing according to the law.


 (XI) Severe Crackdown on Related Illegal and Criminal Activities. The Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, as well as judicial and procuratorial organs, in accordance with their respective responsibilities, rigorously crack down on illegal and criminal activities related to virtual currency, the tokenization of real-world assets, such as fraud, money laundering, illegal business operations, pyramid schemes, illegal fundraising, and other illegal and criminal activities carried out under the guise of virtual currency, the tokenization of real-world assets, etc.


  (XII) Strengthen Industry Self-discipline. Relevant industry associations should enhance membership management and policy advocacy, based on their own responsibilities, advocate and urge member units to resist illegal financial activities related to virtual currency and the tokenization of real-world assets. Member units that violate regulatory policies and industry self-discipline rules are to be disciplined in accordance with relevant self-regulatory management regulations. By leveraging various industry infrastructure, conduct risk monitoring related to virtual currency, the tokenization of real-world assets, and promptly transfer issue clues to relevant departments.


  IV. Strict Supervision of Domestic Entities Engaging in Overseas Business Activities


(XIII) Without the approval of relevant departments in accordance with the law and regulations, domestic entities and foreign entities controlled by them may not issue virtual currency overseas.


  (XIV) Domestic entities engaging directly or indirectly in overseas external debt-based tokenization of real-world assets, or conducting asset securitization activities abroad based on domestic ownership rights, income rights, etc. (hereinafter referred to as domestic equity), should be strictly regulated in accordance with the principles of "same business, same risk, same rules." The National Development and Reform Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other relevant departments regulate it according to their respective responsibilities. For other forms of overseas real-world asset tokenization activities based on domestic equity by domestic entities, the China Securities Regulatory Commission, together with relevant departments, supervise according to their division of responsibilities. Without the consent and filing of relevant departments, no unit or individual may engage in the above-mentioned business.


  (15) Overseas subsidiaries and branches of domestic financial institutions providing Real World Asset Tokenization-related services overseas shall do so legally and prudently. They shall have professional personnel and systems in place to effectively mitigate business risks, strictly implement customer onboarding, suitability management, anti-money laundering requirements, and incorporate them into the domestic financial institutions' compliance and risk management system. Intermediaries and information technology service providers offering Real World Asset Tokenization services abroad based on domestic equity or conducting Real World Asset Tokenization business in the form of overseas debt for domestic entities directly or indirectly venturing abroad must strictly comply with relevant laws and regulations. They should establish and improve relevant compliance and internal control systems in accordance with relevant normative requirements, strengthen business and risk control, and report the business developments to the relevant regulatory authorities for approval or filing.


  V. Strengthen Organizational Implementation


  (16) Strengthen organizational leadership and overall coordination. All departments and regions should attach great importance to the prevention of risks related to virtual currencies and Real World Asset Tokenization, strengthen organizational leadership, clarify work responsibilities, form a long-term effective working mechanism with centralized coordination, local implementation, and shared responsibilities, maintain high pressure, dynamically monitor risks, effectively prevent and mitigate risks in an orderly and efficient manner, legally protect the property security of the people, and make every effort to maintain economic and financial order and social stability.


  (17) Widely carry out publicity and education. All departments, regions, and industry associations should make full use of various media and other communication channels to disseminate information through legal and policy interpretation, analysis of typical cases, and education on investment risks, etc. They should promote the illegality and harm of virtual currencies and Real World Asset Tokenization-related businesses and their manifestations, fully alert to potential risks and hidden dangers, and enhance public awareness and identification capabilities for risk prevention.


  VI. Legal Responsibility


  (18) Engaging in illegal financial activities related to virtual currencies and Real World Asset Tokenization in violation of this notice, as well as providing services for virtual currencies and Real World Asset Tokenization-related businesses, shall be punished in accordance with relevant regulations. If it constitutes a crime, criminal liability shall be pursued according to the law. For domestic entities and individuals who knowingly or should have known that overseas entities illegally provided virtual currency or Real World Asset Tokenization-related services to domestic entities and still assisted them, relevant responsibilities shall be pursued according to the law. If it constitutes a crime, criminal liability shall be pursued according to the law.


  (19) If any unit or individual invests in virtual currencies, Real World Asset Tokens, and related financial products against public order and good customs, the relevant civil legal actions shall be invalid, and any resulting losses shall be borne by them. If there are suspicions of disrupting financial order and jeopardizing financial security, the relevant departments shall deal with them according to the law.


  This notice shall enter into force upon the date of its issuance. The People's Bank of China and ten other departments' "Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation" (Yinfa [2021] No. 237) is hereby repealed.


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This time there is no single triggering factor, but rather market anxiety about asset valuation, with many already skeptical of these valuations being too high, leading to investors choosing to retreat almost simultaneously.

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