EVM is not yet online, how to evaluate the future of Hyperliquid?

By: blockbeats|2024/12/16 18:15:01
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Original title: The Bull Case for Hyperliquid Hyperliquid
Original author: fmoulin7, Crypto Kol
Original translation: zhouzhou, BlockBeats

Editor's note:Hyperliquid attracts users through low fees and strong incentives, and is expected to provide incentives of nearly $1 billion in the first year, with an inflation rate of 11.65%. After the launch of EVM, it may become an important platform for new DeFi protocols to drive the growth of HYPE demand. The platform makes profits through transaction fees and token auctions, and fee allocation is automatically executed, supporting staking rewards, platform operations and token destruction. Increased capital inflows, especially through Kucoin, will drive HYPE prices if more market funds can be attracted. However, centralization and EVM transition risks may affect user experience, and investors need to be cautious and do research.

The following is the original content (the original content has been reorganized for easier reading and understanding):

Hyperliquid is a perpetual trading protocol built on its own L1, which aims to replicate the user experience of centralized trading platforms, while providing a fully on-chain order book and decentralized trading, supporting spot, derivatives, and pre-listed market transactions.

This article will focus more on Hyperliquid's market opportunities and the basic bullish logic of HYPE.

At present, HYPE's trading price has exceeded $20, becoming a top 30 asset with a market value of $7.5 billion and a fully diluted valuation (FDV) of more than $20 billion. So, where does Hyperliquid's popularity come from? What is the bullish logic?

Next we will discuss:

Trading platform opportunities

EVM ecosystem opportunities

Income composition, valuation and comparative analysis

Risk

1. Trading platform opportunities
Hyperliquid dominates the field of perpetual decentralized trading platforms, accounting for more than 50% of trading volume in the past month.

EVM is not yet online, how to evaluate the future of Hyperliquid?

As of now, Hyperliquid's open interest (OI) accounts for about 10% of Binance.

A few things to note here:

As the bull run deepens and market volatility increases (the crypto volatility index is currently only 64), open interest (OI), trading volume, funding rates, and liquidations are expected to continue to grow.

The share of DEXs vs. CEXs for perpetual swaps may increase, just as AMMs and Uniswap have contributed to the growth of DEX vs. CEX share in spot trading.

With lower fees and stronger incentives than its CEX competitors, Hyperliquid has a great opportunity to attract more users and capital away from CEXs. The Token Generation Event (TGE) and the rapid rise in HYPE prices have undoubtedly become the strongest marketing campaign.

Regarding the incentive mechanism, although the specific structure has not yet been disclosed, it is easy to speculate that perpetual swaps and spot trading volume may be incentivized (or already incentivized), after all, more than 40% of the token supply is reserved for community rewards. Here are the details of the initial airdrop:

Assuming 10% of the reserved supply is used for incentives in the first year, the situation will be as follows:

At current prices, nearly $1 billion in incentives will be distributed in the first year, which is far more than the amount distributed at the $2 opening price during the airdrop. The resulting incentive inflation rate is about 11.65% (including staking rewards, which may need to be calculated separately).

More users will bring more trading volume, revenue, destruction and buybacks, so in this case, the actual dilution cost to token holders caused by incentives will be less than 11.65%.

The team can also choose higher inflation rates and incentive levels to attract more users. This is exactly the difference in HYPE's fully diluted valuation (FDV) dynamics mentioned by blknoiz06.

Brief summary of the perpetual contract sector:

Growing market (cyclical + DEX gradually dominates CEX)

Hyperliquid market share is expected to grow (relying on incentives)

In addition:

The spot market may also continue to grow, and Hyperliquid is expected to become a top 3 spot DEX in the short term. Yesterday's trading volume was about $500 million, enough to make Hyperliquid the fifth-largest spot DEX in the entire chain.

With the addition of EVM, more interesting assets may enter the spot market for trading, such as new issuance of utility tokens and native assets (such as native USDC and SOL/ETH/BTC spot trading pairs).

More trading tools are being developed based on Hyperliquid's open infrastructure and builder codes. There are already many cool applications launched by teams such as InsilicoTrading, KatoshiAI and pvp dot trade, and more products will be released in the future to improve the user experience and attract more traffic to the exchange.

The above factors are already very bullish in themselves.
Exchanges and stablecoins are the most profitable and valuable businesses in the crypto space. Competing directly with mainstream players (Binance, Coinbase, Bybit, OKX) for perpetual contracts and spot trading is bullish in itself.

The most optimistic scenario is:

1. Major trading platforms use Hyperliquid as a decentralized backend;

2. Trading platforms hedge by including HYPE in their balance sheets (Refer to ThinkingUSD proposal).

While the possibility of achieving these two points in the short term is unclear, who would have thought that Trump would buy $ENA? Everything is possible.

2. EVM Ecosystem Opportunities

What is HyperEVM?


Description from hyperdrivedefi: "The Hyperliquid stack consists of two chains, Hyperliquid L1 and HyperEVM (EVM). The two chains exist as a unified state under the same consensus mechanism, but run in independent execution environments.

L1 is a permissioned chain that runs native components such as perpetual contracts and spot order books, and is designed to meet the high performance requirements required to run these native components. L1 provides API programmability, and operations submitted through the API must be signed like transactions submitted to the EVM chain.

EVM is a general EVM-compatible chain that supports common tools of Ethereum. EVM It is permissionless and anyone can deploy smart contracts that can also directly access on-chain perpetual contracts and spot liquidity on L1."

HyperEVM is scheduled to launch in the coming months and many teams are already preparing for it. Why is this bullish?

The new home of DeFi?


Many DeFi teams are preparing to launch with the EVM. Most of the "well-known" DeFi protocol types (AMMs, lending, liquidity pledge, CDPs) are expected to be launched with the launch of the EVM.

These projects will improve overall capital efficiency by allowing HYPE holders to use HYPE as collateral in lending and money market protocols.

As existing protocols are applied, it will be interesting to see whether putting order book liquidity directly on-chain will unlock new DeFi primitives. I would not be surprised if brand new DeFi primitives appear first on Hyperliquid.

For example, ethena labs will reduce its reliance on centralized trading platforms, which will improve its system resilience and potentially diversify and reduce counterparty risk by partially integrating Hyperliquid in its hedging process. 【Reference link】

The market needs "utility projects"

Whether it is the AI craze on Base and Solana, the performance of Hyena, or the trading volume of $HFUN and $FARM on Hyperliquid, market participants are showing that they are eager to see projects with real value.

With many DeFi projects coming soon, Hyperliquid is likely to become a platform for the rise of "utility projects" in the near to medium term. At the same time, there is a high probability that the AI infrastructure currently built on Solana by AI16Z, Zerebro, etc. may be extended to Hyperliquid.

Hyperliquid's unique features

Hyperliquid natively supports the creation of vaults. These strategies running on vaults are able to take advantage of the same advanced features as DEX, such as efficient liquidation of ultra-leveraged accounts and high-throughput market-making strategies. Anyone can deposit money into the treasury to get a share of the profits, including DAOs, protocols, institutions or individuals. The owner of the treasury can get 10% of the total profits.

This primitive provides an ideal competitive scenario for AI agents to attract capital.

Why is the launch of EVM a bullish signal?

The launch of EVM will bring more fee income, which can be used for staking rewards, token destruction, etc. Take Base as an example, it has generated $15 million in fees in the past 30 days. I think HyperEVM's activity may be on par with Base in the next few months.

EVM also unlocks more use cases for the HYPE token within the ecosystem. HYPE will become a necessary asset to pay gas fees, and can also be used for lending, staking, locking positions to earn income, etc. This will significantly increase buying demand.

We can refer to the examples of SOL in 2024 (Meme) and ETH in 2020 and 2021 (DeFi and NFT) - on-chain activities directly drive demand for native assets.

Higher market value utility projects + more native asset bridging options (such as native USDC, spot BTC, SOL, ETH, etc.) will drive spot trading volume up, thereby bringing more revenue.

As more teams go online on EVM, the auction price of token codes (tickers) will continue to rise, further increasing revenue.

In addition, EVM will make Hyperliquid an "official" L1 network in the minds of more people and attract more attention to its ecosystem. This may release capital currently on the sidelines to enter the market.

Revenue Breakdown, Valuation and Comparable Companies

How does Hyperliquid make money?

Hyperliquid's profit sources mainly include platform fees and token code (ticker) auctions.

Platform Fees:

Ticker Auctions:

Hyperliquid earns revenue through ticker auctions. In these auctions, projects bid to purchase specific tickers, which are key identifiers for them to display and trade on the platform. As more projects go live on the EVM, the ticker auctions will become more competitive and prices will gradually rise, bringing more revenue to Hyperliquid.

This is how fees flow on-chain:

As of writing, the rescue fund holds 10,761,181.28 HYPE (over 3% of circulating supply) and 3,143,786.73 USDC. The insurance fund has also accumulated 7,071,990.99 USDC that has not yet been transferred to the rescue fund. In total, over $10 million in USDC has not yet been put on the market to buy HYPE.

So, how much revenue does Hyperliquid have? In the past 30 days, Hyperliquid has generated approximately $26.5 million in USDC revenue. Revenue from auctioned tokens accounted for $2 million of that, with the rest coming from platform fees. These revenues were primarily redistributed to the insurance fund.

In addition, since HYPE went live, approximately 79,600 HYPE tokens have been burned by transaction fees, which are denominated in HYPE. At today's prices, this equates to approximately $1.75 million in additional revenue. Therefore, Hyperliquid's total revenue in the past 30 days is over $28 million, which equates to over $336 million per year.

Currently, only 3 first-level blockchains (L1) have more revenue than Hyperliquid: Ethereum, Solana, and Tron, which have much higher market caps. In fact, Hyperliquid's yield (annualized revenue/circulating market cap) is far ahead and the highest among all L1 and L2 platforms.

Potential Revenue Growth

Where can it go next? The main drivers of revenue include:

Platform fees

Auctions

Future revenue mechanisms (EVM fees?)

Let’s analyze each of these factors one by one.

Platform fees
Trading volumes in December are already on par with November. If trading volumes remain at similar levels in the second half of the month, this would represent a 100% month-on-month increase.

Auction
Recently, auction prices have soared, showing a sharp upward trend.

Auction

The latest round of auctions settled today at a price close to $500,000.

As more projects look to secure their spot (there are only 282 spots available per year), auction prices are likely to continue to rise.

EVM Fees
Base has generated roughly $15M in fees over the last 30 days. According to DeFiLlama, Hyperliquid has surpassed Base in TVL over the last 24 hours, and given current trends, it is possible that economic activity on the EVM will be comparable to or even higher than Base by the time Hyperliquid goes live.

Scenarios and Valuations
Based on the above, we can come up with a Base Scenario and a Bull Scenario. This post is about the Bull Scenario, so there is no Bear Scenario, but the risks are discussed in the last section.

Base scenario

Volume is one-third higher than last 30 days

Auction price remains stable

EVM activity is similar to Base

Bull scenario

Volume is twice as high as last 30 days

Auction price doubles and then remains stable ($1 million per auction round)

EVM activity is twice as high as Base

In the Base scenario, 30-day revenue is $59 million, while in the Bull scenario it is $102 million. To arrive at a valuation, we can use different price-to-earnings (PE) multiples, which are based on observations of the main first-level chains (L1) and combined with annualized revenue.

Next, we calculate the market value for the base case and bull case scenarios based on revenue and PE multiples. To arrive at the price of HYPE, we use the current circulating supply, plus an inflation rate of 11.6% (for incentives and rewards), which was calculated in Part I.

Under these conditions, we can see HYPE’s price range from $41.93 (base case, lowest multiple) to $651.48 (bull case, highest multiple).

Given HYPE’s relative immaturity and higher risk relative to Solana and Ethereum, it makes sense that HYPE’s P/E ratio should be on the lower end. Additionally, HYPE’s revenue is primarily derived from decentralized exchanges (DEXs), which Solana and Ethereum do not capture. Therefore, it is logical that HYPE’s P/E ratio is closer to DeFi protocols.

That being said, Hyperliquid’s current P/E ratio may be low given the P/E ratios of other first-level chains (L1) and second-level chains (L2). A “reasonable” scenario might be:

· 40x P/E

· Between the base case and the bull case: $1 billion in annualized revenue

This would bring the valuation to $40 billion ($100 billion fully diluted) and HYPE’s price to just over $100.

Comparison with the previous cycle
While a $40 billion market cap and a $100 billion fully diluted valuation may seem high, bull markets tend to be even crazier.

In 2021:

· BNB market cap grew from $5 billion to $100 billion (20x)

· ADA market cap grew from $5 billion to $95 billion (19x)

· SOL market cap grew from $86 million to $77 billion (900x)

· AVAX market cap grew from $282 million to $30 billion (100x)

· MATIC market cap grew from $85 million to $20 billion (235x)

· FIL’s fully diluted valuation reached $373 billion, 16x today’s HYPE valuation.

Capital Inflows

We have seen a large amount of capital inflow into Hyperliquid.


While the number of holders is increasing, the current number of HYPE holders is still relatively small, especially considering that HYPE is currently only listed on Kucoin.

Comparison data:

HYPE: 60,000 holders

KMNO: 55,000 holders

WIF: 211,000 holders

BONK: 861,000 holders

In an old Messari report, robustus calculated that the "capital inflow multiple" for an asset could be as high as 10x, meaning that a net inflow of $1 billion could increase an asset's market cap by $10 billion. While this cannot be calculated exactly, it is particularly important given HYPE's potential as the third most active L1. If HYPE could get 5% of Solana’s market cap and 1% of Ethereum’s market cap as inflows, this would represent a $10 billion inflow and have a huge impact on price.

We have partially seen this inflow since the TGE, but as fiskantes said, there is still a lot of capital on the sidelines waiting for the release of HyperEVM and the transition to decentralized validators before it will be allocated to HYPE.

Risks


While this article paints a fairly optimistic picture for the future of Hyperliquid, it is not without risks.

One major risk is the validator set, which is currently completely centralized (4 validators operated by a team based in Tokyo). Although the testnet is now live and has a decentralized validator set (over 60 validators), including some experienced validators (such as Chorus One, ValiDAO, B Harvest, Nansen, etc.), the transition is still risky. If performance degrades, user experience and trust will be threatened.

Another risk is the unrealization of the EVM ecosystem. High-quality projects need to be on the EVM for the ecosystem to thrive. If most of the projects are low-quality or simply copied from other chains, less capital and activity will be attracted. Therefore, attracting high-quality developers rather than speculative developers will be key.

On the EVM side, we may see HYPE become more and more capital efficient (such as liquidity staking, lending, etc.). Depending on what is built and its interaction with L1, we may see some new risks that are not present in existing DeFi protocols and may pose a threat to HYPE or the entire trading platform.

Regulatory risks remain, but as Fiskantes said (again, quoting), geo-fencing and Trump administration policies can reduce these risks.

Like all assets, especially as a trading platform, HYPE's performance should be highly correlated with the overall market. The team needs to deliver results before the market reaches weakness.

The crypto market is uncertain and everything can go to zero. I own HYPE, the above is not financial advice, investors please do your own research (DYOR).

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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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