From P2P to RWA: Financial Innovation and Inclusive Model Restructuring in the Virtual Asset Era

By: blockbeats|2025/03/26 10:15:03
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Original Title: "From P2P to RWA: Financial Innovation and Inclusive Model Reconstruction in the Virtual Asset Era"
Original Author: Yekai (WeChat/Twitter: YekaiMeta)

Introduction

Recently, several RWA projects have been related to P2P and consumer finance, so I will take this opportunity to summarize some design ideas.

As an important model of Internet finance, P2P has its innovative rationale as well as driving force and limitations.

What we are considering is: can RWA, as blockchain-driven financial innovation, reconstruct the P2P model to promote inclusive finance development?

From an inclusive perspective, can small and medium-sized enterprise assets, individual assets, and retail investors be combined with AI intelligent agents and smart devices to achieve permissionless RWA asset intelligent issuance and transaction investment matching?

From P2P to RWA: Financial Innovation and Inclusive Model Restructuring in the Virtual Asset Era

Currently, in the first stage of RWA (Real World Asset Tokenization), financial market products such as funds, bonds, and stocks mainly target the institutional market, and the participation and actions of these institutions are crucial. However, in the long term, individual retail users will be more suitable for RWA, so the second stage will further target the retail market, possibly leaning towards something like T-P2P (Tokenization of P2P), becoming an effective new financial tool for retail investors, small and medium-sized enterprises, and individual assets.

Because traditional RWAs are often assets in the institutional market such as bonds, stocks, oil and gas, commodities, and precious metals, these assets are usually difficult for ordinary individual investors to participate in. However, drawing from the P2P (peer-to-peer) model, these traditional assets can be made more inclusive through RWA tokenization, breaking the traditional investment threshold, allowing everyone to participate.

Part One: Development Background and Market Pain Points of Internet Finance P2P

1. Development Background of P2P

People have a strong aversion to P2P mainly because P2P platforms used to frequently default and face regulatory compliance issues. This situation is not a problem with the P2P model itself but is due to the combined effect of multiple factors: imperfect risk management, irregular platform operations, lack of effective regulation, intense competition, and immature business models, among others. The accumulation of these issues eventually led to the collapse of the P2P platform's funding chain, undermining investor trust and hindering the industry's healthy development.

If these issues can be addressed, strengthening regulation, enhancing platform transparency, and improving risk control measures can ensure that P2P platforms operate reasonably within a compliant and ethical framework. We need to recognize the pain points of the traditional financial system: In some aspects, the traditional financial system cannot fully meet the needs of consumers and businesses, especially for those who have difficulty accessing banking services, such as underserved populations and small and micro-enterprises.

· High Costs and Inefficiency: Traditional financial institutions (such as banks), acting as intermediaries, often charge high fees and have slower processing speeds. Especially in lending services, cross-border payments, or small-value transactions, intermediary fees and processing times become significant obstacles. The P2P model, by eliminating intermediaries, reduces transaction costs and improves efficiency.

· Financial Services Inequality: Many residents in many countries or regions, especially in developing countries, often cannot access traditional bank financial services. P2P platforms break the limitations of the traditional financial system, enabling more people to participate in financial services. For example, a P2P lending platform can provide loan services to users without bank accounts. Market Demand Changes As the global economy continues to evolve, changes in market demand have also driven the rapid development of P2P.

Personalized and Flexible Financial Needs: Consumers and small businesses have increasingly diverse financial service needs, and traditional bank products are often rigid and cannot fully meet market demands. The flexibility and personalization of P2P lending, P2P payments, and other services fill this gap.

• Low-Interest Rate Environment: The low-interest rate policies of central banks worldwide have resulted in low returns on traditional investment channels, especially when deposit rates are close to zero, and China's savings rates are continuously decreasing. In this environment, P2P platforms provide investors with higher return opportunities while offering borrowers relatively low financing costs.

2. P2P Market Pain Points

We will not delve into the details of the P2P market but have summarized several core market pain points in combination with the previous background of platform crises and regulatory purges as a reference for learning.

• Information Asymmetry: There is a lack of transparent information sharing between borrowers and investors, leading to credit risk accumulation. One of the primary reasons for platform crises is self-lending and self-investment.

• Risks of Fund Pool Models: Some P2P platforms have misappropriated funds in their operations.

• High Default Rates and Inadequate Risk Control: The platform's credit assessment mechanism is immature, leading to high default risks.

• Lack of Compliance: The lack of global P2P regulation or its lagging behind has led to frequent industry collapses.

• Lack of Liquidity: Investor funds are often locked up, and the exit mechanism is not flexible enough.

Part Two: A Comparative Analysis of P2P and RWA

Can the P2P (Peer-to-Peer) financial lending model and RWA tokenization learn from each other and progress? What are their similarities and innovations?

1. Similarities

• Shared Goal: Both aim to break traditional financial barriers and ultimately serve small investors and asset borrowers.

• Inclusivity: By innovating to lower the participation threshold, they increase funding and investment opportunities.

• Disintermediation: Reduce the high cost of traditional financial institutions as intermediaries and simplify processes through technological means (one through Internet technology, the other through blockchain technology).

2. Innovations

• Technological Foundation: P2P is based on the Internet and platform algorithms, while RWA relies on blockchain technology.

• Transparency: P2P has lower information transparency, whereas RWA provides full-chain transparency through the blockchain.

• Liquidity: P2P has poorer liquidity, and RWA improves asset liquidity through asset tokenization and decentralized trading platforms.

• Risk Management: P2P relies on centralized risk control teams, while RWA automatically enforces risk control rules through smart contracts and transparent on-chain mechanisms.

P2P (Peer-to-Peer) and RWA (Real World Assets) as two distinct financial models have significant differences in target customer base, product form, investment return, trading market, and liquidity.

We conduct a comprehensive comparative analysis of P2P and RWA from these 5 angles to help understand the core differences between the two and their respective strengths and limitations.

1. Target Customer Base

P2P

• Mainly Targeting Small and Medium Investors and Borrowers: The core customer base of P2P platforms is often those who cannot access loans through traditional financial channels, such as small and medium-sized enterprises or individuals, while also attracting retail investors seeking high returns.

• Underserved Financially: Particularly suitable for those excluded from the traditional financial system, such as individuals with poor credit or no bank account.

• Users with High Risk Tolerance: P2P platforms attract investors willing to take on higher risk due to their high-interest rates.

RWA

• Targeting a Diverse Investor Base: RWA platforms mainly cater to institutional investors from the traditional financial markets, large enterprises, and new types of investors seeking asset tokenization. Through tokenization, ordinary investors can also participate.

• Investors with Strong Financial Capacity and Risk Management Awareness: Investors usually need a certain level of capital and risk appetite, especially in asset tokenization selection and market volatility management.

• Cross-Border Investors: The RWA model is particularly suitable for investors seeking cross-border investment, asset diversification, higher liquidity, or digital asset investors, and Crypto Funds.

2. Product Forms

P2P

• Loan Products: The main products of P2P platforms are loan services, usually short-term or medium-term loans. Investors can invest in different loan projects based on their risk appetite.

• Unsecured/Secured Loans: Most P2P platforms offer both unsecured and secured loans, with borrowers deciding whether to provide collateral based on their credit and asset situation.

RWA

• Tokenized Asset Products: RWA platforms create a new form of assets by tokenizing traditional assets (such as bonds, stocks, mineral resources, real estate, etc.). Investors can invest in tokenized assets using fiat currency or stablecoins and enjoy the returns from these assets.

• Financial Derivatives and Derivative Products: In addition to basic tokenized assets, an RWA platform can also offer more complex financial products through derivatives (such as collateralized lending, DeFi, etc.) to meet the needs of sophisticated investors.

3. Return on Investment

P2P

• High Returns: P2P platforms typically offer higher returns compared to traditional bank savings or bonds. The annualized return rate is generally between 8% - 15%, depending on the borrower's credit rating and the loan project's risk.

• High Risk High Return: P2P platforms experience significant return rate fluctuations due to the varying risk profiles of borrowers. Loan defaults or delinquencies can impact the overall return.

RWA

• Stable Income: Tokenized assets on RWA platforms typically offer a more stable annualized return rate, especially for fixed income products such as bonds, real estate, etc. The annual return rate is usually around 6% - 8%, and is generally influenced by market risk and asset quality with minimal fluctuations.

• High Return Potential: Through the tokenization of high-return assets (such as corporate bonds, real estate, etc.), investors may benefit from participating in the secondary market liquidity and secondary market premiums of RWA assets, achieving returns higher than traditional investments. The overall yield sometimes can reach 10% - 20% or higher (depending on secondary market conditions and asset quality).

4. Trading Market

P2P

• Closed Trading Market: P2P platforms typically operate as a closed market where internal matching trades occur. Transactions between borrowers and investors can only take place within the platform, and the platform needs to manage the matching system.

• Geographic Restrictions: The trading market of P2P platforms is often subject to legal and policy restrictions of the country/region, especially in cross-border transactions involving complex compliance issues.

RWA

• Globalized Trading Market: Trading of RWA tokenized assets usually occurs across multiple platforms and may even support international transactions. Investors can trade through decentralized trading platforms (such as DeFi) and licensed virtual asset trading platforms or cryptocurrency exchanges.

• Asset Liquidity Enhancement: The RWA platform supports transactions between traditional assets and crypto assets, enabling assets with originally low liquidity (such as real estate, bonds, etc.) to circulate and be traded globally, even across fiat and digital currencies.

5. Liquidity

P2P

• Low Liquidity: The liquidity of P2P platforms is relatively low, and investors often need to wait for the borrower's repayment or the end of the loan term to reclaim their funds. When the investment project has a long-term setting, liquidity issues become more prominent.

• Limited Exit Mechanism: The exit mechanism provided by P2P platforms usually relies on the platform's secondary market or investor trading demand, but these markets have poor liquidity.

RWA

• High Liquidity: Through asset tokenization, the RWA platform significantly enhances the liquidity of traditional assets. After asset tokenization, if a well-designed secondary market and aftermarket exist, transactions can occur across chain and cross-platform, offering higher liquidity than traditional financial markets.

• Flexible Exit Mechanism: Investors can exit through the RWA trading platform or decentralized exchanges at any time, and even automatically exit investments under specific conditions through smart contracts (OTC or Swap), enhancing fund liquidity and market participation.

After a comprehensive comparative analysis, it is concluded that P2P and RWA each have their advantages. P2P is more suitable for small investors seeking high-risk, high-return investments, while RWA provides institutional investors and cross-border investors with a more stable, higher liquidity, and more transparent asset investment platform. Combined with blockchain technology, the RWA model can better meet modern investors' needs for liquidity, returns, and compliance, theoretically becoming an upgraded version of the P2P model.

Part III: Proposed Solution – How Can RWA Restructure the P2P Model in the Virtual Asset Era?

In the era of virtual assets, RWA (Real World Assets) has redefined the boundaries of financial services through asset tokenization, smart contracts, and blockchain technology, making it possible to be designed as an upgraded version of the P2P model.

The key innovations of RWA are: Firstly, it expands the traditional single-lending model into a diversified asset investment platform, tokenizing diversified assets such as bonds, stocks, real estate, and minerals, effectively lowering the investment threshold and achieving true inclusive finance. Secondly, it introduces a DAO mechanism to replace the centralized control of traditional platforms with community governance, enhancing governance transparency and investor trust;

At the same time, through blockchain technology to comprehensively record transaction information and asset details, it thoroughly solves the information asymmetry problem of traditional P2P; furthermore, through DeFi platforms to achieve multi-platform circulation and secondary market trading of tokenized assets, significantly enhancing asset liquidity, addressing the traditional P2P exit dilemma; smart contract technology automates the execution of lending agreements, asset collateralization, and default processing, significantly improving risk control effectiveness and reducing risks from manual operations; finally, RWA's cross-border tokenization design ensures that global investors can participate in compliance, effectively overcoming the geographical restrictions of traditional P2P.

Therefore, RWA not only innovates asset forms and governance structures but also represents a comprehensive upgrade of the traditional P2P model, ushering in a new chapter of inclusive finance in the era of virtual assets. Learning from the P2P model, transforming RWA into digital inclusive financial products, in the first phase of the institutional market, based on RWA products such as bonds and stocks, how to learn from the P2P (peer-to-peer) model, through RWA tokenization intermediation, to achieve the RWA of the second stage—retail individual investors, making traditional assets more inclusive and accessible to everyone, allowing everyone to participate and benefit, and constructing a feasible path for digital inclusive financial product development.

1. Asset Tokenization: Transforming Traditional Assets into Digital Assets

• Tokenizing RWA Assets: Tokenize traditional RWA assets (such as bonds, equities, precious metals, etc.), with each RWA token representing a relatively low-granularity value of the asset unit, allowing investors to purchase these RWA tokens with small amounts of funds without requiring a large amount of capital or complex financial knowledge.

• Debt Asset Tokenization: Convert corporate bonds, government bonds, etc., into tokens, enabling investors to purchase and share the bond's yield with minimal amounts of funds.

• Commodity Asset Tokenization: For example, tokenizing bulk commodities such as gold, oil, etc., allows ordinary investors to participate in the returns of these assets by purchasing these tokens.

• Stock and Equity Tokenization: Tokenizing shares of public or private companies into small units, making it easier for ordinary investors to invest at a lower cost.

2. Decentralized Finance Platform (DeFi): Enhancing Transparency and Liquidity

• Decentralized Exchange Platform: Drawing on the decentralized concept of the P2P model and combining it with the blockchain-based DeFi model, allowing investors to directly engage in trading RWA tokens on the platform. Transactions are automatically executed through smart contracts, ensuring transparency and efficiency.

• Market Liquidity: The decentralized exchange platform (DEX) will serve as a trading platform for RWA tokenized assets. Investors can enter or exit the market at any time, free from traditional market constraints. Liquidity pools and Automated Market Makers (AMM) will provide sufficient liquidity for RWA tokens, ensuring the smooth operation of the market.

• Lending Platform: Through smart contracts, investors can not only invest in purchasing RWA tokens but also utilize the lending feature to collateralize RWA assets for liquidity, thereby increasing capital efficiency.

3. Distributed Scenario Investment: Distributed Asset Pool and Micro Investment Threshold

• Fractionalized Investment Products: Leveraging tokenization technology, large assets (such as real estate, minerals, energy, etc.) are divided into smaller units, creating micro-investment products. Each token has a very low face value (e.g., a few dollars), allowing the general public to invest with small amounts of funds.

• Distributed Scenario Products: The most common scenarios in consumer finance are mobile consumer loans and used car consumer loans, where the assets are characterized by decentralization and small amounts, but all have smart devices like mobile locks or car locks (BOM) and DePIN conditions. This enables on-chain RWA distributed asset pools and distributed capital pools, allowing ordinary retail investors to participate in the investment pool in small, distributed amounts, while large Crypto Funds can also underwrite.

• Regular Income Distribution: Investors receive regular income distributions based on the amount of RWA tokens they hold. For example, users holding RWA tokens receive proportionate rental income, dividends, or loan interest from the RWA assets.

• Lowering Investment Thresholds: This fractionalized investment approach allows any ordinary investor to participate in assets that are typically only accessible to institutions with very small amounts of money.

4. AI Smart Entity Automated Issuance and Asset Management

• Automated Issuance by AI Smart Entities: Small and medium-sized enterprises and individual assets, which cannot issue independently due to scale and issuance costs, can leverage an RWA asset management platform that integrates AI agents and DePIN smart device technology. Based on permissionless consensus protocols, this platform uses AI agent functionality to automate Launchpad, issue distributed assets, and validate nodes.

• Intelligent Algorithmic Asset Management of Distributed Asset Pools: Since it involves decentralized, small-denomination, various types of assets, and may even consist mostly of non-standard assets, there needs to be a distributed asset protocol and AI Agent to support asset classification, dynamic pricing, intelligent Total Asset Management (TAM), intelligent matching of investments, etc.

• AI Agent's AMM and Liquidity Pool: Smart matching trading and smart trading agents on non-trading platforms, even arbitrage trading robots, enabling decentralized small-denomination assets and funds to leverage digital currencies (such as USDT/USDC) and opportunities for inclusive finance achieved through social investment platforms, AI Agents, etc.

5. Community-Driven and Collective Wisdom: Enhancing User Engagement

• Decentralized Community Governance: Truly implement the community governance mindset from P2P into RWA investment products, allowing RWA token holders to actively participate in decision-making and governance. For example, investors can vote through a DAO (Decentralized Autonomous Organization) to decide on the management, appreciation, and distribution strategies of certain RWA assets. Community members can share investment information with each other, helping newcomers better understand the market.

• Community Incentive Mechanism: By incentivizing users to participate and promote the platform through social sharing, referrals, etc. The "social referral" model in P2P can be reused here, where an RWA asset management platform can incentivize investors to share information and onboard new users through a reward mechanism (such as an RWA Asset Management Platform Token).

6. Risk Control and Compliance: Ensuring Investment Security

• Smart Contracts and Risk Management: Implement automated risk control mechanisms through smart contracts. Each RWA token will have risk control rules, such as credit assessment of borrowers and investors, asset collateralization, and liquidation rules, all of which can be automatically enforced through smart contracts, thus reducing default risks.

• Tiered Risk and Reward Products: To meet the risk tolerance of different investors, an RWA asset management platform can design different levels of investment products. For example, basic-level investors can choose low-risk assets (such as government bonds or high-quality corporate bond tokens), while high-risk investors can opt for high-return digital securities or equity tokens.

• Compliance and Regulation: An RWA asset management platform needs to adhere to relevant financial regulations to ensure the compliance of asset tokenization, trading, cross-border payments, etc., to prevent exploitation by malicious actors and safeguard users' legal rights.

7. Payments and Settlement: Bridging Digital and Fiat Currencies

• Fiat and Digital Asset Bridge: To ensure the inclusivity of the platform, it is necessary to facilitate the circulation between fiat currency and digital assets on the platform. Users can purchase RWA tokens using fiat currency (such as USD, RMB, etc.) or convert cryptocurrencies (such as Bitcoin, Ethereum, etc.) into RWA assets.

• Multi-Currency Support: The platform can support the exchange of various digital currencies with fiat currency based on RWA assets, enhancing the platform's cross-border liquidity. Especially when facing cross-border investments, it provides convenient payment solutions.

Design Summary: The RWA product design in digital inclusive finance draws on the P2P model, combining blockchain technology and RWA tokenization. This design enables ordinary people to participate in traditional asset investment that was previously difficult to access, reducing investment barriers, improving transparency and liquidity, while ensuring compliance and risk control mechanisms. This not only provides ordinary investors with more diverse investment opportunities but also drives the decentralized development of global finance, achieving true digital inclusive finance. This "T-P2P" digital inclusive finance product based on RWA tokenization, DePIN smart devices, AI Agents, smart contracts, and decentralized governance can break the boundaries of traditional investment, allowing more people to equally participate, invest, and trade in a globalized market.

Part Four: Challenges and Feasibility Analysis of RWA

When analyzing the feasibility of RWA as an alternative and upgrade to the P2P era of virtual assets, we must also address the many challenges RWA currently faces. There is still a long way to go. Potential Challenges

1. Regulatory Barriers: Tokenizing cross-border assets involves complex legal and tax compliance issues. Regulatory framework disparities across different countries create regulatory uncertainties for globally tokenized RWA assets.

2. Technical Implementation: While blockchain technology has provided new opportunities for RWA tokenization, the high cost and complexity of combining technologies such as Layer2, distributed protocols, DePIN, and AI Agents remain obstacles to large-scale implementation. The widespread adoption and performance optimization of technology will be crucial in achieving this goal.

3. User Education: The general public has a low understanding of blockchain technology and RWA tokenization products. Extensive education and promotion efforts are needed to help investors understand the risks and opportunities of emerging technologies and investment models.

4. Market Acceptance: As a new investment and financing model, the ability of RWA to attract traditional financial users is still uncertain. Its acceptance and prevalence need to gradually establish trust through practice and market validation. Feasibility analysis, combined with case studies and data analysis, shows that RWA has significant technological advantages, economic benefits, and regulatory potential over traditional P2P models.

Compared to the P2P model, RWA can provide higher transparency, better risk management mechanisms, and more efficient asset liquidity, especially with unique advantages in cross-border and cross-chain transactions. In terms of economic benefits, RWA has optimized asset management and revenue distribution through tokenization and smart contracts, significantly reducing operational costs. Furthermore, in global compliance, RWA has greater potential than the P2P model, able to provide global investors with compliant, transparent financial services, thereby enhancing market attractiveness and user engagement.

Final Conclusion: Can RWA Replace and Redefine the P2P Era of Virtual Assets?

• Comprehensive View: RWA not only addresses the pain points of P2P platforms but also achieves further innovation in inclusive finance through blockchain technology. Its advantages in transparency, liquidity, risk management, and diversified investment opportunities can allow ordinary investors to access more financial assets.

• Future Outlook: The widespread adoption of RWA requires the collective drive of technology, regulation, and user education. If existing challenges can be overcome, RWA is poised to become the "new P2P" of the virtual asset era, creating a more fair, open, and efficient new financial ecosystem for global users.

#ARAW Always RWA Always Win!

By 2025, the RWA market will quickly find its place in rapid growth. WeChat cannot answer questions one by one. After the core disciple class, there will be a partner class and a listed company research camp. If you have needs or questions, you can bring them to the classroom for serious learning and interactive discussions and scenario simulations. Friends who are interested in understanding RWA and initiating RWA projects are welcome to reply "Course" or "Sign Up" in the official account to join the course preparation group, or long-press the QR code image below to join the RWA course discussion group.

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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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