曼昆区块链法律服务

2024年以来，RWA（Real-World Assets，现实世界资产）成为Web3和传统金融数字化领域的热点话题。从房地产Token、票据、供应链金融，到债券和基金份额Token化，越来越多的项目方和资本开始寻找全球范围内合规落地的渠道。

时间来到2025年3月17日，迪拜金融服务管理局（DFSA）发布了《Tokenisation Regulatory Sandbox Guide》，首次明确将代币化纳入监管重点，并推出创新测试许可机制（ITL），释放出一条现实、清晰且具备实际可操作性的合规路径。
目前，意向申请窗口已开放，仅为2025年3月17日至4月24日期间。因此，对于计划出海的RWA项目方而言，这条路径，正是当前阶段值得重点关注与把握的重要选项。
DFSA代币化沙盒释放哪些信号？
此次指南明确指出，DFSA将Tokenised Investments纳入监管体系，并将代币具体区分为：
Security Token（证券型代币）Derivative Token（衍生品型代币）
这样一来，代币化资产将不再处于监管灰色地带，迪拜市场内的RWA项目，尤其是房地产、供应链金融、票据、

行业回顾：从繁荣到监管趋严
2017年，牛律师刚开始接触加密货币，也加入了不少社群。那时，行业正迎来一个新的暴发期，各类监管政策尚未出台，市场充满机遇。社群内容也是百花齐放，有的普及区块链底层知识，有的教授“搬砖”套利，还有的直接教人如何买卖加密货币。的确，这些社群给了许多新人学习机会，帮助他们提升投资技能。很多人都是在这样的背景下从小白变成一个个老“韭菜”。
然而，转眼间，那段日子似乎已经成为历史，行业环境已然大变。随着国内监管趋严，许多曾经风光无限的币圈大佬逐渐隐退，社群活跃度大幅下降。尽管如此，仍然有不少社群在运营，有人提供投资建议、推荐项目，甚至传授“撸毛”策略、冲土狗币的方法。但在当前监管政策下，这类行为存在极高的法律风险，甚至可能面临刑事责任。
2021年发布的《关于进一步防范和处置虚拟货币交易炒作风险的通知》明确禁止“为虚拟货币交易提供信息中介”服务，根据法律释义，该行为是指通过平台、社群、网站、App或其他渠道，为虚拟货币（如比特币、以太坊、USDT等）的买卖、交易、撮合等行为提供信息发布、展示、推广、咨询等服务。这类行为在本质上并未直接参与虚拟货币交易，但为交易双方提

When we talk about domestic Web3 entrepreneurship, we always talk about the 924 document of 2021, and emphasize that providing virtual currency financial services within the country is an illegal financial activity, which will constitute a crime and be subject to criminal liability in accordance with the law.
However, we will also find that in recent years, there has been a model between Hong Kong and Shenzhen called "front shop and back factory", that is, setting up projects/companies in Hong Kong, facing supervision and overseas capital; organizing development and some operational links in Shenzhen, enjoying strong technology research and development and low costs.
This makes people wonder: Is this model really compliant? If it is compliant, does it mean that I can set up a project in Hong Kong and then operate it in the mainland?

In the past year, although BTC still attracted much attention, the mainstream of the virtual currency market was filled with various MEMECoins. These currencies, which were hyped up by "stalks" and emotions, attracted a large amount of speculative capital at an alarming rate. However, today, with the decline of the overall market value of virtual currencies and the acceleration of supervision in the global mainstream market, the global virtual currency market seems to have begun to calm down.
On March 14, 2025, Maria Shen, partner of Electric Capital, said that in the future Web3 will pay more attention to practicality and sustainability, and features such as clear supervision and consumer friendliness will also become trends.

What happened with the FTX collapse?
Some friends may still be confused about the 'FTX explosion'; don't worry, I'll briefly outline the background first. Those familiar with the event can jump to the next section 👇.
In November 2022, the cryptocurrency industry was rocked by a massive event: the world's second-largest exchange, FTX, announced bankruptcy without warning. Founded by the 'genius' Sam Bankman-Fried (SBF), the platform was once a dazzling star in the industry, valued at $32 billion, but collapsed overnight due to fund misappropriation and management chaos, leaving hundreds of thousands of users and over $10 billion in debt. SBF was ultimately sentenced to 25 years in prison by a U.S. court, while the FTX liquidation team staged a 'comeback,' miraculously recovering $14.5 billion to $16.3 billion, promising to do their best to compensate clients. This 'explosion' shocked the world and left the 8% share of Chinese users in a dilemma—due to regulatory restrictions, they were blocked from compensation.

The reason for choosing to explore this topic is my attraction to this survey data.

This survey from Bitpanda shows that women exhibit a unique style in cryptocurrency investment, which leads me to ponder a question: In our consistent perception, successful investors seem to be mostly male, but is this simply the result of 'survivorship bias'? The large base of male investors naturally makes successful cases more visible to us, while could it be that female investors, due to their smaller numbers, are underestimated in their potential?
According to a Cointelegraph report in March 2025 (citing data from Bitget CEO Gracy Chen), globally, female cryptocurrency holders account for about 26%, making up roughly a quarter of the total investor population. Data from multiple sources indicates that the proportion of women in the cryptocurrency investment sector fluctuates between approximately 20% to 35%. Although the proportion of female investors is not high, their performance may be better than we imagine.

The Web3 industry has been filled with opportunities and challenges since its inception.
We are not only witnesses but also deep participants. Faced with the dual impact of regulatory adjustments and market changes, more and more practitioners are beginning to rethink:
🔹 Can it continue?
🔹 How to avoid pitfalls and ensure safety and compliance?
In consultations, we have seen too many similar dilemmas:
⚠️ Web3 practitioners have an incomplete understanding of the industry, and projects fail due to compliance issues right after they start;
⚠️ Companies want to go overseas but do not understand different countries' regulatory requirements, leading to strategic mistakes and business obstacles;

Recently, Wu said that blockchain conducted an in-depth interview with Mr. Leung from InvestHK, discussing the directions of Hong Kong's development in Web3 and cryptocurrencies. From policy support to market feedback, as well as capital flow and attempts at Real-World Assets (RWA) tokenization, it systematically showcased Hong Kong's layout in this emerging field.
As a lawyer who has long focused on the Web3 industry, Lawyer Honglin is often asked, 'Can Hong Kong really become the global center for Web3?' The answer to this question is not simple, as it involves not only the policy environment and market attractiveness but also capital flow, regulatory frameworks, talent reserves, and the interaction between Hong Kong and global financial markets. Mr. Leung's interview provides many thought-provoking perspectives, and I also want to analyze the key contents of this interview based on my professional experience and discuss the current situation and possible future directions of Hong Kong's Web3 ecosystem.

With the arrival of the concluding chapter of this series, we have systematically sorted through the high-frequency crimes that practitioners in the cryptocurrency field may be involved in, such as pyramid schemes, illegal operations, and money laundering. As the final piece of this series, this article will focus on the often-overlooked but extremely 'harmful' crime of illegal use of information networks (hereinafter referred to as 'non-credibility crime')—although it is a minor crime, it often becomes the prosecutor's preferred charge and may serve as a 'breaking the ice tool' for criminal cases.
Typical Case Insights
Case One: The Tragedy of Information Platforms
A certain Web3 Chinese information website is a blockchain data display platform that primarily provides data analysis, market analysis, and ranking services for cryptocurrency trading platforms, with over 200,000 daily active users. A certain project party paid for rankings and promotions on this platform, then the project collapsed and was identified as implementing a 'pig-butchering' scam, after which employees of the information website were detained by the police for suspected 'non-credibility crimes'.

According to Foresight News, NetEase Qingliu Studio reported that Wang Shuiming, who was arrested in connection with the largest money laundering case in Singapore, has been arrested in Montenegro and may be extradited back to China. Wang Shuiming's partner Su Weiyi was confirmed to be the mastermind of the Hong Kong cryptocurrency platform scam AAX. In July 2024, Su Weiyi was arrested by the Hong Kong police.

AAX Platform Events
Atom Asset (AAX) is one of the largest cryptocurrency exchanges in Hong Kong, with more than 2 million users. On November 13, 2022, just two days after cryptocurrency exchange FTX filed for bankruptcy, AAX also stopped withdrawals and cleared all social channels due to counterparty risk exposure. Initially, AAX attributed the freeze to security measures in response to suspected malicious attacks.

Remote work, free collaboration, crypto payments... The working model of the Web3 industry has blurred the definition of 'workers'. In traditional industries, whether you are a formal employee or a temporary worker is often determined by the contract. However, in Web3, many practitioners who hold 'freelancer' contracts live the life of formal employees.
Must adhere to fixed working hours
Under company management, receive monthly salaries and performance bonuses
Participate in team meetings and comply with corporate culture
More complex is the situation of contributors in decentralized organizations (DAOs), who have neither contracts nor HR contacts but still work long-term for projects and rely on token rewards for income.

Recently, another incident has caused a stir! According to user @R10coin_ on platform X, football superstar Ronaldinho appears to have 'failed' — he first signed a $6 million token cooperation agreement with a team, received a $3 million deposit, and then turned around and sold his X account for $5 million to a Shenzhen 'token factory', helping them promote another cryptocurrency. What’s more outrageous is that this Shenzhen company is accused of releasing dozens of 'meme coins' every month, using exaggerated advertising to fool investors, then pumping and dumping, harvesting everything in just an hour and running away. This plot is even more thrilling than 'dribbling through defenders' on the field!

The cryptocurrency market has been turbulent recently. The MEME market was turbulent some time ago, and a large number of Web3 users suffered heavy losses. Recently, the protagonist has become the well-known virtual asset exchange Bybit. According to the monitoring of the on-chain detective ZachXBT, Bybit had a suspicious fund outflow of more than US$1.46 billion at midnight on February 21. Subsequently, ZachXBT confirmed that the incident was a security incident.

*Image source: ZachXBT TG Channel
With such a huge amount of stolen funds, some people predict that the incident may have a significant negative impact on the virtual asset market. But according to CoinMarketCap data, the overall market sentiment index has not experienced any significant fluctuations.

A good Web3 project relies on a large user base. Therefore, many project parties adopt recruitment commission methods to quickly attract users. But does this involve legal risks? If so, could it lead to administrative penalties or criminal penalties?
In this article, Lawyer Mankun conducts an in-depth analysis of the classic case recorded in the People's Court Case Database: the EOS ecological platform case, providing an in-depth analysis of the compliance boundaries for Web3 projects touching on pyramid selling crimes.

Why is providing virtual currency appreciation services classified as pyramid selling?
The EOS ecological platform was a Web3 project that attracted 450,000 members and involved over 500 million in funds, but the platform was ultimately identified by the court as a pyramid selling organization. The person in charge was found guilty of organizing and leading pyramid selling activities, all assets involved were confiscated, and 9 core team members were sentenced to 2 to 5 years.

Lawyer Mankun also remembers that in August 2024, the Hong Kong Monetary Authority announced the launch of the Ensemble project sandbox, aimed at promoting the integration of virtual assets and traditional financial products, leading the integration and innovation of the RWA track in Hong Kong.
By February 2025, as one of the first-phase trial participants in the Ensemble project sandbox, China Asset Management (Hong Kong) announced that its constructed tokenized retail money market fund had been approved by the Hong Kong Securities and Futures Commission (SFC) and officially went live at the end of February.

As the first of its kind in the Asia-Pacific region, it not only marks the further penetration of virtual assets into the traditional financial sector but also represents the latest progress of the Hong Kong Ensemble project sandbox, providing new thinking directions for regulators, fund management companies, and investors on how to use blockchain to enhance the transparency and liquidity of financial products while ensuring compliance.

Recently, the Jiangsu High Court released a typical foreign-related case, where a Singapore investor cooperated with a Chinese citizen to invest in cryptocurrency, and the court ruled 'contract invalid, risk self-borne,' resulting in the Singapore investor losing millions of principal.
Now let's break down what this case is all about:
In 2019, Singapore citizen Mr. Pan collaborated with Chinese citizen Mr. Tian to invest in a project called 'MFA Blockchain.' The parties agreed that Mr. Pan would provide funding, and Mr. Tian would be responsible for technology and operations. After the project started, Mr. Pan actually invested 15.74 million yuan. However, as time went on, seeing no return of funds, Mr. Pan started to feel anxious and urged Mr. Tian to return the funds. Initially, Mr. Tian procrastinated, citing market value pressure, but under Mr. Pan's repeated urging, Mr. Tian gradually returned 10.6 million yuan, yet 5.15 million yuan remained unpaid.

On February 19, 2025, the Hong Kong Securities and Futures Commission (SFC) released the latest regulatory roadmap 'A-S-P-I-Re' for the virtual asset market, aiming to further improve virtual asset market regulation, introduce more types of virtual asset products and functions, and balance innovation and risk management in Hong Kong's Web3 industry.

The roadmap proposes that the Hong Kong Securities and Futures Commission will proceed with five major pillars: market access (Access), safeguards (Safeguards), product innovation (Products), infrastructure development (Infrastructure), and relationship management (Relationships), as well as twelve actions, including but not limited to optimizing the licensing system, promoting OTC and custody service regulation, researching the allowance for professional investors to trade derivatives and staking, and positioning Hong Kong as a compliant and trustworthy virtual asset liquidity center.

According to a report by Fox News journalist Eleanor Terrett on January 25, the U.S. Senate Banking Committee announced it would hold a hearing on February 5 (U.S. time) to discuss the phenomenon of banks 'debanking' crypto companies. Prior to this, the U.S. House Committee on Oversight and Government Reform had already sent letters to several crypto company executives requesting explanations on this issue.
In recent years, 'debanking' has gradually become a key feature of the crypto industry. From payment interruptions to financing bottlenecks, and the transformation of custody services, in the current disconnection between traditional financial institutions and the Web3 industry, crypto companies are trying to find a path to 'liberate' themselves from traditional finance and complete decentralization.

On February 12, 2025, OKX released an 'exciting' announcement: OKX's announcement regarding the launch of Pi (Pi Network) spot trading.

According to the announcement, Pi Network, a highly controversial and large community crypto project in China, is finally set to officially launch its mainnet after 6 years. It is believed that once this announcement is made, a large number of domestic users will cheer with joy. Finally, they will no longer have to rely on love to generate power!
However, Pi Network is rarely mentioned in mainstream Web3 circles.
Regarding this mainnet launch, the well-known Web3 media 'Planet Daily' published an article ('The King of Pyramid Schemes' Pi Mainnet Countdown, 60 Million People Brainwashed for Six Years Are About to 'Realize Their Dreams'?), which pointed out: After six years of sharpening, is it a sword or a sickle? The launch day of Pi becomes the 'ultimate test of IQ tax.' Previously, related information found in mainstream media is often linked to regulatory news and keywords like 'pyramid scheme.'