2024 Crypto ETF Landscape Review: AUM Surpasses $120 Billion; Shifting from the Fringe to the Mainstream
Original Article Title: "2024 Crypto Spot ETF Landscape Review: 1 Year, $400 Billion"
Original Article Author: Fairy, ChainCatcher
2024 was a historic year for the cryptocurrency market. Over the past decade, the U.S. Securities and Exchange Commission had rejected at least 30 Bitcoin spot ETF applications, but on January 11, 2024, a historic turning point was reached. The U.S. Bitcoin spot ETF was officially approved for listing, achieving a record $46 billion in trading volume and $6.28 billion in net inflows on its first day. Subsequently, several countries including Hong Kong and Australia also launched Bitcoin spot ETFs, further driving the global legitimization of crypto assets. As of the time of writing, the U.S. crypto ETF's assets under management have surpassed $1,223.9 billion, with Hong Kong reaching $4.67 billion.
2024 was the year crypto assets truly shifted towards mainstream assets. According to the latest 13-F filings, all types of institutions are now holders of crypto ETFs, including endowments, pension funds, hedge funds, investment advisers, and family offices. In this wave of mainstreaming crypto assets, ETFs for other digital assets such as Solana and XRP have also gradually come into the public eye, further laying the groundwork for the developments in 2025.
This article will review the key milestones of the 2024 crypto spot ETFs, analyze in detail the market performance of crypto ETFs over this year, and provide an outlook on the 2025 development prospects of crypto ETFs.
Key Milestone Review: The Birth Year of Crypto Spot ETFs
Bitcoin Spot ETF 2024 Time Retrospect
Let's rewind to the early hours of January 11, 2024. The entire cryptocurrency industry held its breath as global investors anxiously awaited the final decision on the U.S. Bitcoin spot ETF. Finally, the words "formal approval" appeared, and the Bitcoin spot ETF successfully emerged, fulfilling everyone's years of anticipation.
On its first day, the Bitcoin spot ETF traded over $46 billion, with a net inflow of $6.28 billion. Within the first three days of listing, the trading volume had already approached $100 billion.
On January 19, just one week after trading began, the U.S. Bitcoin ETF's AUM had already surpassed the Silver ETF, becoming the second-largest ETF commodity category in the U.S.
With the United States approving a Bitcoin spot ETF, Hong Kong did not want to fall behind. On April 15, Hong Kong provisionally approved BTC and ETH spot ETFs; on April 24, Hong Kong Bitcoin spot ETF and Ethereum spot ETF were officially approved; on April 30, 6 virtual asset spot ETFs were listed on the Hong Kong Stock Exchange and opened for trading.
On the first day, the Hong Kong cryptocurrency spot ETF raised approximately HKD 2 billion, with a calculated net asset value of USD 293 million. The total trading volume of the 6 ETFs on the first day was approximately HKD 87.58 million (about USD 12.70 million).
The launch of Hong Kong's cryptocurrency spot ETF has had a profound impact on the Chinese financial landscape and is also an important step towards further legitimizing cryptocurrencies globally. The Hong Kong crypto ETF uses a physical creation and redemption mechanism, providing a channel for converting crypto assets into traditional financial assets.
Subsequently, various countries have gradually begun to approve and trade Bitcoin spot ETFs. On June 4, Australia's first Bitcoin spot ETF officially started trading, and the Thai Securities and Exchange Commission also approved the first local Bitcoin spot ETF.
By September 23, the US SEC approved the listing of the BlackRock Bitcoin ETF on Nasdaq, and on October 19, the SEC approved the trading of various Bitcoin spot ETF options. The range of Bitcoin-related derivatives has further expanded, bringing options products to the market that combine compliance and trading depth. Bitcoin ETF options allow investors to engage in term-based portfolio allocations, particularly suited for long-term investments, injecting more regulatory compliance and trading depth into the market.

Ethereum Spot ETF 2024 Retrospective
In 2024, the Ethereum spot ETF saw a series of significant developments globally. From Hong Kong to the United States, and then to Australia, multiple regions around the world were actively advancing the approval and listing of Ethereum spot ETFs. Ethereum, as the "Number Two" of the crypto market, officially stepped in front of traditional investors.
On April 24, the Hong Kong Bitcoin spot ETF and Ethereum spot ETF were officially approved, marking the first landing of an Ethereum spot ETF on a major exchange. The Hong Kong Ethereum spot ETF saw a net inflow of 14,200 ETH on the first day, with a trading volume of USD 2.99 million.
On May 24, the US SEC approved the 19b-4 filing of the first Ethereum spot ETF. This filing was a key step in the legal trading of the Ethereum spot ETF in the US market, opening the door for Ethereum spot products to formally enter the US market.
On July 23, the crypto market once again witnessed a historic moment as the U.S. SEC officially approved the Ethereum spot ETF. The Ethereum spot ETF saw a first-day trading volume of over $1.019 billion, with a net inflow of $106.6 million.
On November 8, the U.S. SEC once again delayed its decision on the New York Stock Exchange's listing of Ethereum spot ETF options. The filing stated that the delay is to conduct further analysis and gather public input, particularly on whether the proposed rule changes comply with the Securities Exchange Act.

Further Look Back at Crypto-Related ETFs in 2024
Following the approval of Bitcoin and Ethereum spot ETFs, the Solana spot ETF also saw significant progress in 2024. On June 20, the first North American Solana spot ETF application was submitted, marking the official entry of Solana ETF into the public eye. Subsequently, 21 Shares and VanEck also submitted applications for Solana ETF to the SEC.
On August 8, the Brazilian Securities and Exchange Commission approved the world's first Solana spot ETF, followed by the approval of a second Solana ETF on August 21. This groundbreaking move in Brazil brought more optimism to crypto supporters.
Applications for Solana spot ETFs in the U.S. are ongoing. On November 22, Cboe submitted applications for 4 Solana spot ETF listings to the SEC, and on December 4, Grayscale sought to convert its Solana Trust Fund into a spot ETF and list it on the NYSE. However, shortly after, sources revealed that the SEC had informed at least two Solana spot ETF applicant institutions that their submitted 19b-4 filings would be rejected. This news indicates that the U.S. remains cautious towards Solana spot ETFs.
In addition to Solana, XRP is also a focus of institutional attention. Currently, Bitwise, 21 Shares, and WisdomTree have submitted XRP spot ETF applications in the U.S.
Furthermore, various types of crypto-related ETFs have been launched or entered the application stage in November and December, ranging from single crypto assets to multi-asset portfolios, from index-based to yield-based. This trend signifies the crypto market's gradual move towards mainstream adoption and further demonstrates its increased integration with the traditional financial system. Crypto assets are gradually evolving into one of the core assets recognized by global investors.

How Did ETFs Perform This Year?
The total assets under management of ETFs listed in the U.S. have surpassed $10 trillion, with $400 billion allocated to the cryptocurrency space. Cryptocurrency ETFs currently represent 0.4% of the overall ETF market. However, according to K 33 Research data, the net inflow of Bitcoin spot ETFs in 2024 accounted for 3.5% of all net inflows into U.S. ETFs in 2024, a proportion significantly higher than traditional asset classes.
Since the launch of Bitcoin ETFs, their liquidity is 4.5 times that of gold ETFs adjusted for inflation. Although the cumulative flow still lags behind gold, the asset under management of U.S. Bitcoin ETFs has exceeded that of gold.
Furthermore, the BTC holdings of U.S. Bitcoin spot ETFs have surpassed 1.13 million coins, surpassing Satoshi Nakamoto's Bitcoin holdings, becoming the world's largest "Bitcoin holder." These achievements undoubtedly demonstrate that Bitcoin spot ETFs are the "most successful ETF ever."
As of December 24, the total cumulative net inflows of U.S. Bitcoin spot ETFs reached $35.49 billion, with a total net asset value of $110 billion. Among them, the net asset value of BlackRock's BIT accounts for nearly 50%, reaching $53.7 billion. It is noteworthy that BIT's asset size is now equivalent to the sum of 50 ETFs focused on Europe (region + single country), and these European ETFs have been in existence for 20 years.

Bitcoin Spot ETF Net Inflows vs. Bitcoin Price Chart, Source: sosovalue
The U.S. Ethereum spot ETF previously had a mediocre performance, but since November, its inflow and liquidity have increased significantly.
On November 13, ETF issuer Bitwise announced the acquisition of Ethereum staking service provider Attestant. On November 20, 21Shares announced the addition of staking functionality to its Ethereum Core ETP product and renamed it "Ethereum Core Staking ETP" (ETHC). With the news of Trump's victory, the market's expectation for the introduction of staking functionality in the Ethereum spot ETF has grown stronger.
As of December 24, the total cumulative net inflows of the U.S. Ethereum spot ETF reached $2.51 billion, with a total net asset value of $12.35 billion. On December 5, the net inflow reached $428 million, setting a record.
In the United States Ethereum Spot ETF, the highest net asset value is held by Grayscale's ETHE, reaching $4.91 billion, followed by BlackRock's ETF with a net asset value of $3.65 billion. Together, they account for 69.3% of the total assets of the US Ethereum Spot ETF.

Ethereum Spot ETF Net Inflows vs. Bitcoin Price Chart, Source: sosovalue
Which Cryptocurrency ETFs Will Be Approved in 2025?
Multiple Solana ETF applications will face their first review period from January 23 to 25, 2025. However, according to FOX Business reporter Eleanor Terrett, the US Securities and Exchange Commission (SEC) has notified at least two SOL spot ETF applicant institutions that their submitted 19b-4 filings will be rejected. Meanwhile, sources familiar with the matter have revealed that during the current government's tenure, the SEC may not approve any new cryptocurrency ETF applications.
Bloomberg Senior ETF Analyst Eric Balchunas expects issuers to resubmit applications after the appointment of the new SEC Chairman Paul Atkins. Paul Atkins serves as Co-Chair of the Digital Chamber's Token Alliance, focusing on researching and advancing the digital asset industry. His appointment may bring new possibilities for the approval of Solana ETFs.
Bitwise has its first review period for 10 cryptocurrency index ETFs submitted to the SEC on January 18, 2025. This ETF includes a variety of mainstream crypto assets currently in the market, including BTC, XRP, Solana, Cardano, Uniswap, Polkadot, Chainlink, Ethereum, Avalanche, and Bitcoin Cash.
The Bitwise Bitcoin and Ethereum ETFs will have their first review period on January 30, 2025. This ETF is a proposed spot cryptocurrency index fund composed of BTC and ETH, aiming to "provide investors with a balanced exposure to the world's two largest cryptocurrencies in an easily accessible form."

In addition, the following cryptocurrency ETFs are also awaiting approval:
XRP ETF
· Bitwise XRP ETF
· Canary XRP ETF
· 21 Shares Core XRP Trust
· Wisdomtree XRP Fund
Litecoin ETF
· Canary Litecoin ETF
HBAR ETF
· Canary HBAR ETF
In addition to ETFs, approval for Ethereum spot ETF options will also take place in 2025. Bloomberg ETF analyst James Seyffart said the SEC's final decision could come around April 9, 2025. However, the SEC is not the sole decision-making body, as approval from the OCC and CFTC is also required.
Outlook for 2025
In 2025, more cryptocurrency assets may enter the ETF space. Despite ongoing regulatory challenges, the continued involvement of institutional investors and the gradual maturation of the market will provide further impetus for the future development of the cryptocurrency industry. We can anticipate that cryptocurrency assets will no longer be merely speculative tools, but will become a significant part of global investment portfolios, driving deep integration between traditional finance and digital assets.
Below are predictions from industry insiders and KOLs on the development of cryptocurrency ETFs in 2025:
Forbes Prediction: Staking will be incorporated into an Ethereum ETF for the first time in 2025. ETFs for other cryptocurrencies (such as Solana) will be launched soon, and there may be the introduction of weighted cryptocurrency index ETFs.
Framework Co-Founder Vance Spencer's Prediction: Listing plans for ETFs of cryptocurrencies other than Bitcoin and Ethereum will be delayed until 2026.
Messari Research Prediction: ETF inflows will continue to rise in 2025, especially as Grayscale's GBTC pivots to positive net flows, making the launch of a Solana spot ETF in the next year or two seem inevitable.
Coinbase states: Looking ahead, industry focus is on the possibility of ETF issuers expanding the assets underpinning ETFs to include more tokens like XRP, SOL, LTC, and HBAR, but we believe these potential approvals may only benefit a limited group of assets.
ETF issuer VanEck predicts: The new SEC leadership (or possibly the CFTC) will approve several new US spot cryptocurrency exchange-traded products (ETPs), including the VanEck Solana product. The Ethereum ETP will feature staking, further enhancing its utility for holders, while both Ethereum and Bitcoin ETPs support in-kind creation/redemption. The path will be cleared for banks and brokers to custody spot cryptocurrency whether the US Securities and Exchange Commission or Congress repeal SEC Rule SAB 121.
ETF issuer Bitwise forecasts: Bitcoin ETF inflows in 2025 will surpass those of 2024. Trillions of dollars managed by the company will begin to flow into Bitcoin ETFs.
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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk
Foreword: Today, the People's Bank of China's website published the "Notice of the People's Bank of China, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration for Market Regulation, China Banking and Insurance Regulatory Commission, China Securities Regulatory Commission, State Administration of Foreign Exchange on Further Preventing and Dealing with Risks Related to Virtual Currency and Others (Yinfa [2026] No. 42)", the latest regulatory requirements from the eight departments including the central bank, which are basically consistent with the regulatory requirements of recent years. The main focus of the regulation is on speculative activities such as virtual currency trading, exchanges, ICOs, overseas platform services, and this time, regulatory oversight of RWA has been added, explicitly prohibiting RWA tokenization, stablecoins (especially those pegged to the RMB). The following is the full text:
To the people's governments of all provinces, autonomous regions, and municipalities directly under the Central Government, the Xinjiang Production and Construction Corps:
Recently, there have been speculative activities related to virtual currency and Real-World Assets (RWA) tokenization, disrupting the economic and financial order and jeopardizing the property security of the people. In order to further prevent and address the risks related to virtual currency and Real-World Assets tokenization, effectively safeguard national security and social stability, in accordance with the "Law of the People's Republic of China on the People's Bank of China," "Law of the People's Republic of China on Commercial Banks," "Securities Law of the People's Republic of China," "Law of the People's Republic of China on Securities Investment Funds," "Law of the People's Republic of China on Futures and Derivatives," "Cybersecurity Law of the People's Republic of China," "Regulations of the People's Republic of China on the Administration of Renminbi," "Regulations on Prevention and Disposal of Illegal Fundraising," "Regulations of the People's Republic of China on Foreign Exchange Administration," "Telecommunications Regulations of the People's Republic of China," and other provisions, after reaching consensus with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, and with the approval of the State Council, the relevant matters are notified as follows:
(I) Virtual currency does not possess the legal status equivalent to fiat currency. Virtual currencies such as Bitcoin, Ether, Tether, etc., have the main characteristics of being issued by non-monetary authorities, using encryption technology and distributed ledger or similar technology, existing in digital form, etc. They do not have legal tender status, should not and cannot be circulated and used as currency in the market.
The business activities related to virtual currency are classified as illegal financial activities. The exchange of fiat currency and virtual currency within the territory, exchange of virtual currencies, acting as a central counterparty in buying and selling virtual currencies, providing information intermediary and pricing services for virtual currency transactions, token issuance financing, and trading of virtual currency-related financial products, etc., fall under illegal financial activities, such as suspected illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures business, illegal fundraising, etc., are strictly prohibited across the board and resolutely banned in accordance with the law. Overseas entities and individuals are not allowed to provide virtual currency-related services to domestic entities in any form.
A stablecoin pegged to a fiat currency indirectly fulfills some functions of the fiat currency in circulation. Without the consent of relevant authorities in accordance with the law and regulations, any domestic or foreign entity or individual is not allowed to issue a RMB-pegged stablecoin overseas.
(II)Tokenization of Real-World Assets refers to the use of encryption technology and distributed ledger or similar technologies to transform ownership rights, income rights, etc., of assets into tokens (tokens) or other interests or bond certificates with token (token) characteristics, and carry out issuance and trading activities.
Engaging in the tokenization of real-world assets domestically, as well as providing related intermediary, information technology services, etc., which are suspected of illegal issuance of token vouchers, unauthorized public offering of securities, illegal operation of securities and futures business, illegal fundraising, and other illegal financial activities, shall be prohibited; except for relevant business activities carried out with the approval of the competent authorities in accordance with the law and regulations and relying on specific financial infrastructures. Overseas entities and individuals are not allowed to illegally provide services related to the tokenization of real-world assets to domestic entities in any form.
(III) Inter-agency Coordination. The People's Bank of China, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of virtual currency-related illegal financial activities.
The China Securities Regulatory Commission, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of illegal financial activities related to the tokenization of real-world assets.
(IV) Strengthening Local Implementation. The people's governments at the provincial level are overall responsible for the prevention and disposal of risks related to virtual currencies and the tokenization of real-world assets in their respective administrative regions. The specific leading department is the local financial regulatory department, with participation from branches and dispatched institutions of the State Council's financial regulatory department, telecommunications regulators, public security, market supervision, and other departments, in coordination with cyberspace departments, courts, and procuratorates, to improve the normalization of the work mechanism, effectively connect with the relevant work mechanisms of central departments, form a cooperative and coordinated working pattern between central and local governments, effectively prevent and properly handle risks related to virtual currencies and the tokenization of real-world assets, and maintain economic and financial order and social stability.
(5) Enhanced Risk Monitoring. The People's Bank of China, China Securities Regulatory Commission, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration of Foreign Exchange, Cyberspace Administration of China, and other departments continue to improve monitoring techniques and system support, enhance cross-departmental data analysis and sharing, establish sound information sharing and cross-validation mechanisms, promptly grasp the risk situation of activities related to virtual currency and real-world asset tokenization. Local governments at all levels give full play to the role of local monitoring and early warning mechanisms. Local financial regulatory authorities, together with branches and agencies of the State Council's financial regulatory authorities, as well as departments of cyberspace and public security, ensure effective connection between online monitoring, offline investigation, and fund tracking, efficiently and accurately identify activities related to virtual currency and real-world asset tokenization, promptly share risk information, improve early warning information dissemination, verification, and rapid response mechanisms.
(6) Strengthened Oversight of Financial Institutions, Intermediaries, and Technology Service Providers. Financial institutions (including non-bank payment institutions) are prohibited from providing account opening, fund transfer, and clearing services for virtual currency-related business activities, issuing and selling financial products related to virtual currency, including virtual currency and related financial products in the scope of collateral, conducting insurance business related to virtual currency, or including virtual currency in the scope of insurance liability. Financial institutions (including non-bank payment institutions) are prohibited from providing custody, clearing, and settlement services for unauthorized real-world asset tokenization-related business and related financial products. Relevant intermediary institutions and information technology service providers are prohibited from providing intermediary, technical, or other services for unauthorized real-world asset tokenization-related businesses and related financial products.
(7) Enhanced Management of Internet Information Content and Access. Internet enterprises are prohibited from providing online business venues, commercial displays, marketing, advertising, or paid traffic diversion services for virtual currency and real-world asset tokenization-related business activities. Upon discovering clues of illegal activities, they should promptly report to relevant departments and provide technical support and assistance for related investigations and inquiries. Based on the clues transferred by the financial regulatory authorities, the cyberspace administration, telecommunications authorities, and public security departments should promptly close and deal with websites, mobile applications (including mini-programs), and public accounts engaged in virtual currency and real-world asset tokenization-related business activities in accordance with the law.
(8) Strengthened Entity Registration and Advertisement Management. Market supervision departments strengthen entity registration and management, and enterprise and individual business registrations must not contain terms such as "virtual currency," "virtual asset," "cryptocurrency," "crypto asset," "stablecoin," "real-world asset tokenization," or "RWA" in their names or business scopes. Market supervision departments, together with financial regulatory authorities, legally enhance the supervision of advertisements related to virtual currency and real-world asset tokenization, promptly investigating and handling relevant illegal advertisements.
(IX) Continued Rectification of Virtual Currency Mining Activities. The National Development and Reform Commission, together with relevant departments, strictly controls virtual currency mining activities, continuously promotes the rectification of virtual currency mining activities. The people's governments of various provinces take overall responsibility for the rectification of "mining" within their respective administrative regions. In accordance with the requirements of the National Development and Reform Commission and other departments in the "Notice on the Rectification of Virtual Currency Mining Activities" (NDRC Energy-saving Building [2021] No. 1283) and the provisions of the "Guidance Catalog for Industrial Structure Adjustment (2024 Edition)," a comprehensive review, investigation, and closure of existing virtual currency mining projects are conducted, new mining projects are strictly prohibited, and mining machine production enterprises are strictly prohibited from providing mining machine sales and other services within the country.
(X) Severe Crackdown on Related Illegal Financial Activities. Upon discovering clues to illegal financial activities related to virtual currency and the tokenization of real-world assets, local financial regulatory authorities, branches of the State Council's financial regulatory authorities, and other relevant departments promptly investigate, determine, and properly handle the issues in accordance with the law, and seriously hold the relevant entities and individuals legally responsible. Those suspected of crimes are transferred to the judicial authorities for processing according to the law.
(XI) Severe Crackdown on Related Illegal and Criminal Activities. The Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, as well as judicial and procuratorial organs, in accordance with their respective responsibilities, rigorously crack down on illegal and criminal activities related to virtual currency, the tokenization of real-world assets, such as fraud, money laundering, illegal business operations, pyramid schemes, illegal fundraising, and other illegal and criminal activities carried out under the guise of virtual currency, the tokenization of real-world assets, etc.
(XII) Strengthen Industry Self-discipline. Relevant industry associations should enhance membership management and policy advocacy, based on their own responsibilities, advocate and urge member units to resist illegal financial activities related to virtual currency and the tokenization of real-world assets. Member units that violate regulatory policies and industry self-discipline rules are to be disciplined in accordance with relevant self-regulatory management regulations. By leveraging various industry infrastructure, conduct risk monitoring related to virtual currency, the tokenization of real-world assets, and promptly transfer issue clues to relevant departments.
(XIII) Without the approval of relevant departments in accordance with the law and regulations, domestic entities and foreign entities controlled by them may not issue virtual currency overseas.
(XIV) Domestic entities engaging directly or indirectly in overseas external debt-based tokenization of real-world assets, or conducting asset securitization activities abroad based on domestic ownership rights, income rights, etc. (hereinafter referred to as domestic equity), should be strictly regulated in accordance with the principles of "same business, same risk, same rules." The National Development and Reform Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other relevant departments regulate it according to their respective responsibilities. For other forms of overseas real-world asset tokenization activities based on domestic equity by domestic entities, the China Securities Regulatory Commission, together with relevant departments, supervise according to their division of responsibilities. Without the consent and filing of relevant departments, no unit or individual may engage in the above-mentioned business.
(15) Overseas subsidiaries and branches of domestic financial institutions providing Real World Asset Tokenization-related services overseas shall do so legally and prudently. They shall have professional personnel and systems in place to effectively mitigate business risks, strictly implement customer onboarding, suitability management, anti-money laundering requirements, and incorporate them into the domestic financial institutions' compliance and risk management system. Intermediaries and information technology service providers offering Real World Asset Tokenization services abroad based on domestic equity or conducting Real World Asset Tokenization business in the form of overseas debt for domestic entities directly or indirectly venturing abroad must strictly comply with relevant laws and regulations. They should establish and improve relevant compliance and internal control systems in accordance with relevant normative requirements, strengthen business and risk control, and report the business developments to the relevant regulatory authorities for approval or filing.
(16) Strengthen organizational leadership and overall coordination. All departments and regions should attach great importance to the prevention of risks related to virtual currencies and Real World Asset Tokenization, strengthen organizational leadership, clarify work responsibilities, form a long-term effective working mechanism with centralized coordination, local implementation, and shared responsibilities, maintain high pressure, dynamically monitor risks, effectively prevent and mitigate risks in an orderly and efficient manner, legally protect the property security of the people, and make every effort to maintain economic and financial order and social stability.
(17) Widely carry out publicity and education. All departments, regions, and industry associations should make full use of various media and other communication channels to disseminate information through legal and policy interpretation, analysis of typical cases, and education on investment risks, etc. They should promote the illegality and harm of virtual currencies and Real World Asset Tokenization-related businesses and their manifestations, fully alert to potential risks and hidden dangers, and enhance public awareness and identification capabilities for risk prevention.
(18) Engaging in illegal financial activities related to virtual currencies and Real World Asset Tokenization in violation of this notice, as well as providing services for virtual currencies and Real World Asset Tokenization-related businesses, shall be punished in accordance with relevant regulations. If it constitutes a crime, criminal liability shall be pursued according to the law. For domestic entities and individuals who knowingly or should have known that overseas entities illegally provided virtual currency or Real World Asset Tokenization-related services to domestic entities and still assisted them, relevant responsibilities shall be pursued according to the law. If it constitutes a crime, criminal liability shall be pursued according to the law.
(19) If any unit or individual invests in virtual currencies, Real World Asset Tokens, and related financial products against public order and good customs, the relevant civil legal actions shall be invalid, and any resulting losses shall be borne by them. If there are suspicions of disrupting financial order and jeopardizing financial security, the relevant departments shall deal with them according to the law.
This notice shall enter into force upon the date of its issuance. The People's Bank of China and ten other departments' "Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation" (Yinfa [2021] No. 237) is hereby repealed.

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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk
Foreword: Today, the People's Bank of China's website published the "Notice of the People's Bank of China, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration for Market Regulation, China Banking and Insurance Regulatory Commission, China Securities Regulatory Commission, State Administration of Foreign Exchange on Further Preventing and Dealing with Risks Related to Virtual Currency and Others (Yinfa [2026] No. 42)", the latest regulatory requirements from the eight departments including the central bank, which are basically consistent with the regulatory requirements of recent years. The main focus of the regulation is on speculative activities such as virtual currency trading, exchanges, ICOs, overseas platform services, and this time, regulatory oversight of RWA has been added, explicitly prohibiting RWA tokenization, stablecoins (especially those pegged to the RMB). The following is the full text:
To the people's governments of all provinces, autonomous regions, and municipalities directly under the Central Government, the Xinjiang Production and Construction Corps:
Recently, there have been speculative activities related to virtual currency and Real-World Assets (RWA) tokenization, disrupting the economic and financial order and jeopardizing the property security of the people. In order to further prevent and address the risks related to virtual currency and Real-World Assets tokenization, effectively safeguard national security and social stability, in accordance with the "Law of the People's Republic of China on the People's Bank of China," "Law of the People's Republic of China on Commercial Banks," "Securities Law of the People's Republic of China," "Law of the People's Republic of China on Securities Investment Funds," "Law of the People's Republic of China on Futures and Derivatives," "Cybersecurity Law of the People's Republic of China," "Regulations of the People's Republic of China on the Administration of Renminbi," "Regulations on Prevention and Disposal of Illegal Fundraising," "Regulations of the People's Republic of China on Foreign Exchange Administration," "Telecommunications Regulations of the People's Republic of China," and other provisions, after reaching consensus with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, and with the approval of the State Council, the relevant matters are notified as follows:
(I) Virtual currency does not possess the legal status equivalent to fiat currency. Virtual currencies such as Bitcoin, Ether, Tether, etc., have the main characteristics of being issued by non-monetary authorities, using encryption technology and distributed ledger or similar technology, existing in digital form, etc. They do not have legal tender status, should not and cannot be circulated and used as currency in the market.
The business activities related to virtual currency are classified as illegal financial activities. The exchange of fiat currency and virtual currency within the territory, exchange of virtual currencies, acting as a central counterparty in buying and selling virtual currencies, providing information intermediary and pricing services for virtual currency transactions, token issuance financing, and trading of virtual currency-related financial products, etc., fall under illegal financial activities, such as suspected illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures business, illegal fundraising, etc., are strictly prohibited across the board and resolutely banned in accordance with the law. Overseas entities and individuals are not allowed to provide virtual currency-related services to domestic entities in any form.
A stablecoin pegged to a fiat currency indirectly fulfills some functions of the fiat currency in circulation. Without the consent of relevant authorities in accordance with the law and regulations, any domestic or foreign entity or individual is not allowed to issue a RMB-pegged stablecoin overseas.
(II)Tokenization of Real-World Assets refers to the use of encryption technology and distributed ledger or similar technologies to transform ownership rights, income rights, etc., of assets into tokens (tokens) or other interests or bond certificates with token (token) characteristics, and carry out issuance and trading activities.
Engaging in the tokenization of real-world assets domestically, as well as providing related intermediary, information technology services, etc., which are suspected of illegal issuance of token vouchers, unauthorized public offering of securities, illegal operation of securities and futures business, illegal fundraising, and other illegal financial activities, shall be prohibited; except for relevant business activities carried out with the approval of the competent authorities in accordance with the law and regulations and relying on specific financial infrastructures. Overseas entities and individuals are not allowed to illegally provide services related to the tokenization of real-world assets to domestic entities in any form.
(III) Inter-agency Coordination. The People's Bank of China, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of virtual currency-related illegal financial activities.
The China Securities Regulatory Commission, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of illegal financial activities related to the tokenization of real-world assets.
(IV) Strengthening Local Implementation. The people's governments at the provincial level are overall responsible for the prevention and disposal of risks related to virtual currencies and the tokenization of real-world assets in their respective administrative regions. The specific leading department is the local financial regulatory department, with participation from branches and dispatched institutions of the State Council's financial regulatory department, telecommunications regulators, public security, market supervision, and other departments, in coordination with cyberspace departments, courts, and procuratorates, to improve the normalization of the work mechanism, effectively connect with the relevant work mechanisms of central departments, form a cooperative and coordinated working pattern between central and local governments, effectively prevent and properly handle risks related to virtual currencies and the tokenization of real-world assets, and maintain economic and financial order and social stability.
(5) Enhanced Risk Monitoring. The People's Bank of China, China Securities Regulatory Commission, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration of Foreign Exchange, Cyberspace Administration of China, and other departments continue to improve monitoring techniques and system support, enhance cross-departmental data analysis and sharing, establish sound information sharing and cross-validation mechanisms, promptly grasp the risk situation of activities related to virtual currency and real-world asset tokenization. Local governments at all levels give full play to the role of local monitoring and early warning mechanisms. Local financial regulatory authorities, together with branches and agencies of the State Council's financial regulatory authorities, as well as departments of cyberspace and public security, ensure effective connection between online monitoring, offline investigation, and fund tracking, efficiently and accurately identify activities related to virtual currency and real-world asset tokenization, promptly share risk information, improve early warning information dissemination, verification, and rapid response mechanisms.
(6) Strengthened Oversight of Financial Institutions, Intermediaries, and Technology Service Providers. Financial institutions (including non-bank payment institutions) are prohibited from providing account opening, fund transfer, and clearing services for virtual currency-related business activities, issuing and selling financial products related to virtual currency, including virtual currency and related financial products in the scope of collateral, conducting insurance business related to virtual currency, or including virtual currency in the scope of insurance liability. Financial institutions (including non-bank payment institutions) are prohibited from providing custody, clearing, and settlement services for unauthorized real-world asset tokenization-related business and related financial products. Relevant intermediary institutions and information technology service providers are prohibited from providing intermediary, technical, or other services for unauthorized real-world asset tokenization-related businesses and related financial products.
(7) Enhanced Management of Internet Information Content and Access. Internet enterprises are prohibited from providing online business venues, commercial displays, marketing, advertising, or paid traffic diversion services for virtual currency and real-world asset tokenization-related business activities. Upon discovering clues of illegal activities, they should promptly report to relevant departments and provide technical support and assistance for related investigations and inquiries. Based on the clues transferred by the financial regulatory authorities, the cyberspace administration, telecommunications authorities, and public security departments should promptly close and deal with websites, mobile applications (including mini-programs), and public accounts engaged in virtual currency and real-world asset tokenization-related business activities in accordance with the law.
(8) Strengthened Entity Registration and Advertisement Management. Market supervision departments strengthen entity registration and management, and enterprise and individual business registrations must not contain terms such as "virtual currency," "virtual asset," "cryptocurrency," "crypto asset," "stablecoin," "real-world asset tokenization," or "RWA" in their names or business scopes. Market supervision departments, together with financial regulatory authorities, legally enhance the supervision of advertisements related to virtual currency and real-world asset tokenization, promptly investigating and handling relevant illegal advertisements.
(IX) Continued Rectification of Virtual Currency Mining Activities. The National Development and Reform Commission, together with relevant departments, strictly controls virtual currency mining activities, continuously promotes the rectification of virtual currency mining activities. The people's governments of various provinces take overall responsibility for the rectification of "mining" within their respective administrative regions. In accordance with the requirements of the National Development and Reform Commission and other departments in the "Notice on the Rectification of Virtual Currency Mining Activities" (NDRC Energy-saving Building [2021] No. 1283) and the provisions of the "Guidance Catalog for Industrial Structure Adjustment (2024 Edition)," a comprehensive review, investigation, and closure of existing virtual currency mining projects are conducted, new mining projects are strictly prohibited, and mining machine production enterprises are strictly prohibited from providing mining machine sales and other services within the country.
(X) Severe Crackdown on Related Illegal Financial Activities. Upon discovering clues to illegal financial activities related to virtual currency and the tokenization of real-world assets, local financial regulatory authorities, branches of the State Council's financial regulatory authorities, and other relevant departments promptly investigate, determine, and properly handle the issues in accordance with the law, and seriously hold the relevant entities and individuals legally responsible. Those suspected of crimes are transferred to the judicial authorities for processing according to the law.
(XI) Severe Crackdown on Related Illegal and Criminal Activities. The Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, as well as judicial and procuratorial organs, in accordance with their respective responsibilities, rigorously crack down on illegal and criminal activities related to virtual currency, the tokenization of real-world assets, such as fraud, money laundering, illegal business operations, pyramid schemes, illegal fundraising, and other illegal and criminal activities carried out under the guise of virtual currency, the tokenization of real-world assets, etc.
(XII) Strengthen Industry Self-discipline. Relevant industry associations should enhance membership management and policy advocacy, based on their own responsibilities, advocate and urge member units to resist illegal financial activities related to virtual currency and the tokenization of real-world assets. Member units that violate regulatory policies and industry self-discipline rules are to be disciplined in accordance with relevant self-regulatory management regulations. By leveraging various industry infrastructure, conduct risk monitoring related to virtual currency, the tokenization of real-world assets, and promptly transfer issue clues to relevant departments.
(XIII) Without the approval of relevant departments in accordance with the law and regulations, domestic entities and foreign entities controlled by them may not issue virtual currency overseas.
(XIV) Domestic entities engaging directly or indirectly in overseas external debt-based tokenization of real-world assets, or conducting asset securitization activities abroad based on domestic ownership rights, income rights, etc. (hereinafter referred to as domestic equity), should be strictly regulated in accordance with the principles of "same business, same risk, same rules." The National Development and Reform Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other relevant departments regulate it according to their respective responsibilities. For other forms of overseas real-world asset tokenization activities based on domestic equity by domestic entities, the China Securities Regulatory Commission, together with relevant departments, supervise according to their division of responsibilities. Without the consent and filing of relevant departments, no unit or individual may engage in the above-mentioned business.
(15) Overseas subsidiaries and branches of domestic financial institutions providing Real World Asset Tokenization-related services overseas shall do so legally and prudently. They shall have professional personnel and systems in place to effectively mitigate business risks, strictly implement customer onboarding, suitability management, anti-money laundering requirements, and incorporate them into the domestic financial institutions' compliance and risk management system. Intermediaries and information technology service providers offering Real World Asset Tokenization services abroad based on domestic equity or conducting Real World Asset Tokenization business in the form of overseas debt for domestic entities directly or indirectly venturing abroad must strictly comply with relevant laws and regulations. They should establish and improve relevant compliance and internal control systems in accordance with relevant normative requirements, strengthen business and risk control, and report the business developments to the relevant regulatory authorities for approval or filing.
(16) Strengthen organizational leadership and overall coordination. All departments and regions should attach great importance to the prevention of risks related to virtual currencies and Real World Asset Tokenization, strengthen organizational leadership, clarify work responsibilities, form a long-term effective working mechanism with centralized coordination, local implementation, and shared responsibilities, maintain high pressure, dynamically monitor risks, effectively prevent and mitigate risks in an orderly and efficient manner, legally protect the property security of the people, and make every effort to maintain economic and financial order and social stability.
(17) Widely carry out publicity and education. All departments, regions, and industry associations should make full use of various media and other communication channels to disseminate information through legal and policy interpretation, analysis of typical cases, and education on investment risks, etc. They should promote the illegality and harm of virtual currencies and Real World Asset Tokenization-related businesses and their manifestations, fully alert to potential risks and hidden dangers, and enhance public awareness and identification capabilities for risk prevention.
(18) Engaging in illegal financial activities related to virtual currencies and Real World Asset Tokenization in violation of this notice, as well as providing services for virtual currencies and Real World Asset Tokenization-related businesses, shall be punished in accordance with relevant regulations. If it constitutes a crime, criminal liability shall be pursued according to the law. For domestic entities and individuals who knowingly or should have known that overseas entities illegally provided virtual currency or Real World Asset Tokenization-related services to domestic entities and still assisted them, relevant responsibilities shall be pursued according to the law. If it constitutes a crime, criminal liability shall be pursued according to the law.
(19) If any unit or individual invests in virtual currencies, Real World Asset Tokens, and related financial products against public order and good customs, the relevant civil legal actions shall be invalid, and any resulting losses shall be borne by them. If there are suspicions of disrupting financial order and jeopardizing financial security, the relevant departments shall deal with them according to the law.
This notice shall enter into force upon the date of its issuance. The People's Bank of China and ten other departments' "Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation" (Yinfa [2021] No. 237) is hereby repealed.
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