Web3 Lawyer Decodes: What kind of RWA do people understand?

Source: encryption salad

Recently, discussions about RWA projects have been heated in various Web3 communities. Industry observers often assert online that "RWA will reshape the new financial ecology of Hong Kong," believing that with the existing regulatory framework of the Hong Kong Special Administrative Region, this track will usher in breakthrough development. During the exchanges and discussions with colleagues, the encryption salad found that everyone has been fiercely debating the so-called "compliance" issue recently, and their understanding of the question "what is compliance" varies, leading to a situation where each side has its own reasoning. This phenomenon actually stems from the existing differences in understanding the concept of RWA.

Therefore, it is necessary for the encryption salad to discuss the concept of RWA from the perspective of a professional legal team, and to clarify the compliance red lines of RWA.

1. How should the concept of RWA be defined?

(1) Background and Advantages of RWA Projects

Currently, RWA is becoming the focus of market discussions and is gradually forming a new wave of development. This phenomenon is primarily based on the following two major backgrounds:

The first reason is that the advantages of the token itself can compensate for the shortcomings of traditional financing.

Traditional financial markets have long faced inherent shortcomings such as high entry barriers, long financing cycles, slow financing speeds, and complex exit mechanisms. However, token financing can effectively bypass these defects. Compared to traditional IPOs, RWA has the following significant advantages:

1. Fast financing speed: As the circulation of tokens is based on blockchain technology and typically occurs in decentralized intermediary trading institutions, it avoids obstacles such as foreign investment access restrictions, industry policy constraints, and lock-up period requirements that traditional financial projects may encounter. At the same time, it significantly compresses the review process that would originally take months or even years, greatly enhancing the financing speed.

2. Asset Diversification: Traditional IPOs have a single asset type, only supporting equity issuance, which imposes strict requirements on the issuing entity's revenue stability, profitability, and asset-liability structure. However, for RWA, the suitable types of assets are more diverse, encompassing various non-standard assets, which not only expands the range of financeable assets but also shifts the focus of credit assessment to the quality of underlying assets, significantly lowering the qualification threshold for the issuing entity.

3. Relatively low financing costs: Traditional IPOs require long-term cooperation from multiple intermediaries such as investment banks, auditors, and law firms, with the total cost of the listing process potentially exceeding millions or even tens of millions. This incurs substantial expenses. However, RWA issues tokens through decentralized exchanges, eliminating a significant portion of intermediary costs, while also reducing another substantial amount of labor costs through the use of smart contracts.

In summary, RWA has taken the spotlight of financing projects with its unique advantages, while the Web3 world and the cryptocurrency sphere particularly need funding and projects from the traditional real world. This has led to the current situation where, whether it's companies aiming for substantial business transformation or simply wanting to capitalize on the "trend" and gain exposure, both leading projects in the niche fields of listed companies and a variety of startup projects at the grassroots level are actively exploring the potential applications of RWA.

Second, Hong Kong's "compliance" has added fuel to the heat.

In fact, the development of RWA overseas has been underway for a while. This wave of enthusiasm has come fiercely because a series of regulatory innovations were approved in Hong Kong, and several benchmark projects were implemented, providing domestic investors with compliant channels to participate in "RWA" for the first time. The "compliant" RWA that can be accessed by Chinese people has been realized. This groundbreaking progress has not only attracted native encryption assets but has also prompted traditional projects and funds to begin paying attention to the investment value of RWA, ultimately driving the market enthusiasm to new heights.

However, do users who want to experience RWA really understand what RWA is? There are numerous RWA projects with various underlying assets and operational structures; can everyone distinguish their differences? Therefore, we believe it is necessary to clearly define what compliant RWA is through this article.

People generally believe that RWA is a financing project that tokenizes underlying real-world assets through blockchain technology. However, when we delve into the underlying assets of each project and trace back the operational process, we find that the underlying logic of these projects is actually different. We conducted a systematic study on this issue and summarized the following understanding of the concept of RWA:

We believe that RWA is actually a broad concept and does not have a so-called "standard answer." The process of asset tokenization achieved through blockchain technology can all be referred to as RWA.

(2) Elements and Characteristics of RWA Projects

Real RWA projects need to have the following characteristics:

1. Based on real assets

The authenticity of the underlying assets and whether the project can establish a transparent and acceptable off-chain asset verification mechanism audited by a third party are key criteria for determining whether the project's tokens will achieve effective value recognition in reality. For example, PAXG issues tokens that are anchored to gold in real-time, with each token backed by 1 ounce of physical gold. The gold reserves are managed by a third-party platform and are subject to quarterly audits by a third-party auditing firm, and it even supports redeeming the corresponding amount of physical gold with tokens. This highly transparent and regulated asset verification mechanism allows the project to gain investors' trust and provides a foundation for effective valuation within the real financial system.

2. Asset Tokenization on Chain

Asset tokenization refers to the process of converting real-world assets into digital tokens that can be issued, traded, and managed on-chain through smart contracts and blockchain technology. The value flow and asset management processes of RWA are executed automatically through smart contracts. Unlike traditional financial systems that rely on intermediary institutions for transactions and settlements, RWA projects can leverage smart contracts to achieve transparent, efficient, and programmable execution of business logic on the blockchain, thereby significantly enhancing asset management efficiency and reducing operational risks.

Asset tokenization endows RWA with key characteristics of being divisible, tradable, and highly liquid. After asset tokenization, assets can be split into smaller tokens, lowering the investment threshold, changing the way assets are held and circulated, and allowing retail investors to participate in investment markets that were previously high-threshold.

3. Digital assets have ownership value

The tokens issued by RWA projects should belong to digital assets with property attributes. Project parties should clearly distinguish between data assets and digital assets: data assets are collections of data owned by enterprises that can create value. In contrast, digital assets are the value itself and do not require data for repricing. To illustrate, when you design a painting, upload it to the blockchain, and generate an NFT, this NFT is a digital asset because it can be verified and traded. However, the large amount of feedback from users regarding this painting, browsing data, click rates, and other data belongs to data assets. You can analyze data assets to determine user preferences, improve your work, and adjust its price.

4. The issuance and circulation of RWA tokens comply with legal regulations and are subject to administrative supervision

The issuance and circulation of RWA tokens must operate within the existing legal framework; otherwise, it may not only lead to project failure but also trigger legal risks. Firstly, real-world assets must be genuine and legal, with clear and undisputed ownership, so that they can serve as the basis for token issuance. Secondly, RWA tokens typically possess rights to income or asset rights, making them easily classified as securities by regulatory authorities in various countries. Therefore, compliance with local securities regulations must be conducted prior to issuance. The issuing entity must also be a qualified institution, such as one holding an asset management or trust license, and must complete KYC and anti-money laundering procedures. Once in circulation, the trading platforms for RWA tokens also need to be regulated, typically requiring them to be compliant exchanges or secondary markets with financial licenses, and trading on decentralized platforms is not allowed. Additionally, continuous information disclosure is necessary to ensure that investors can access the true state of the assets linked to the tokens. Only under such a regulatory framework can RWA tokens be issued and circulated legally and safely.

In addition, the compliance management of RWA has typical cross-jurisdictional characteristics. Therefore, it is necessary to build a systematic compliance framework that covers the legal norms of the asset location, the flow of funds, and various regulatory authorities. Throughout the entire lifecycle of asset on-chain, cross-chain, and token cross-border and cross-platform circulation, RWA must establish a compliance mechanism that includes multiple aspects such as asset confirmation, token issuance, fund flow, revenue distribution, user identification, and compliance auditing. This involves not only legal consulting and compliance design but may also require the introduction of third-party trust, custody, auditing, and regulatory technology solutions.

(3) Types and Regulation of RWA Projects

We found that there are two parallel types in the RWA projects that meet the requirements:

1. Narrow Definition of RWA: Physical Assets on Chain

We believe that the narrow definition of RWA specifically refers to projects that tokenize real assets on-chain with authenticity and verifiability, which is also the common understanding of RWA among the general public. Its application market is the most extensive, such as projects that anchor tokens to real-world assets like real estate and gold.

2. STO (Security Token Offering): Financial Assets on the Blockchain

Apart from the narrowly defined RWA projects, we have found that a large number of RWA projects currently existing in the market are STOs.

(1) Definition of STO

Depending on the underlying assets, operational logic, and token functions, existing tokens in the market can be roughly divided into two main categories: Utility Tokens and Security Tokens. STO refers to the financialization of real assets and the issuance of tokenized shares or certificates in the form of Security Tokens on the blockchain.

(2) Definition of Security Tokens

Compared to functional tokens, security tokens are, in simple terms, on-chain financial products driven by blockchain technology that are subject to securities regulations, similar to electronic stocks.

(3) Regulation of Security Tokens

Under the regulatory framework of mainstream encryption asset-friendly countries such as the United States and Singapore, once a token is classified as a security token, it will be subject to the constraints of traditional financial regulatory agencies (such as the Securities and Exchange Commission), and the design of the token, trading models, etc. must comply with local securities regulations.

From an economic perspective, the core objective of financial products is to coordinate the supply and demand relationship between financing parties and investors; however, from a legal and regulatory standpoint, some countries focus more on protecting investor interests, while others tend to encourage the smoothness and innovation of financing activities. This difference in regulatory stance is reflected in the specific rules, compliance requirements, and enforcement strength within each country's legal system. Therefore, when designing and issuing RWA products, it is essential to consider not only the authenticity and legality of the underlying assets but also to conduct a comprehensive review and compliance design of key aspects such as product structure, issuance methods, circulation paths, trading platforms, investor access thresholds, and capital costs.

It is particularly noteworthy that once the core appeal of a certain RWA project comes from its high leverage and high return expectations, and positions "hundredfold, thousandfold returns" as its main selling point, then regardless of its superficial packaging, its essence is highly likely to be classified as a securities product by regulatory agencies. Once identified as a security, the project will face a much stricter and more complex regulatory system, significantly increasing its subsequent development path, operational costs, and even legal risks.

Therefore, when discussing the legal compliance of RWA, we need to deeply understand the connotation of "securities regulations" and the regulatory logic behind it. Different countries and regions have different definitions and regulatory focuses regarding securities. The United States, Singapore, and Hong Kong have all defined the criteria for the identification of security tokens. It is not difficult to find that the identification method is essentially to determine whether the token meets the local securities regulations' criteria for "securities". Once it meets the securities conditions, it is categorized as a security token. Therefore, we have organized the relevant provisions from key countries (regions) as follows:

A. Mainland China

In the regulatory framework of Mainland China, the Securities Law of the People's Republic of China defines securities as stocks, corporate bonds, depositary receipts, and other negotiable instruments recognized by the State Council that can be issued and traded, and also includes the listing and trading of government bonds and securities investment fund shares under the regulation of the Securities Law.

(The above image is taken from the Securities Law of the People's Republic of China)

B. Singapore

Although Singapore's "Guide to Digital Token Offerings" and "Securities and Futures Act" do not directly mention the concept of "security tokens," they provide a detailed list of different circumstances under which tokens may be deemed as "capital market products":

(The above image is taken from the "Digital Token Issuance Guide" )

C. Hong Kong, China

The Securities and Futures Commission of Hong Kong has specific enumerated regulations regarding the positive and negative lists of securities in the Securities and Futures Ordinance.

(The above image is taken from the Securities and Futures Ordinance )

The regulation defines "securities" to include "shares, equity shares, notes, bonds" structured products, without limiting their existence to traditional carriers. The SFC has clearly pointed out in its circular on intermediaries engaged in activities related to tokenized securities that the nature of its regulatory objects is essentially traditional securities packaged as tokens.

D. United States

The U.S. Securities and Exchange Commission (SEC) stipulates that any product that passes the Howey Test will be classified as a security. Any product recognized as a security must be regulated by the SEC. The Howey Test was established as a legal standard by the U.S. Supreme Court in the 1946 case of SEC v. W.J. Howey Co., used to determine whether a transaction or scheme constitutes an "investment contract," thereby subjecting it to the regulation of U.S. securities law.

The Howey Test outlines four conditions under which a financial product is deemed to be a "security." The application of the Howey Test in digital assets is specified in the SEC's publication titled "Framework for 'Investment Contract' Analysis of Digital Assets." We will conduct a detailed analysis on this matter next:

• The Investment of Money（金钱投入）

Refers to investors investing money or assets into a project in exchange for certain rights or expected returns. In the digital asset field, whether using fiat currency or encryption to purchase tokens, as long as there is a value exchange, it can usually be considered to meet this standard. Therefore, most token issuances basically comply with this condition.

• Common Enterprise

A "joint venture" refers to a close binding of interests between investors and the issuer, typically manifested as the investor's returns being directly related to the project's operational effectiveness. In token projects, if the returns for token holders depend on the business development of the project party or the operational results of the platform, it meets the characteristics of a "joint venture," and this condition is also relatively easy to establish in practice.

• Reasonable Expectation of Profits Derived from Efforts of Others

This point is key in determining whether a token will be classified as a security token. This condition refers to the situation where if the investor purchases the product with the expectation of future appreciation of the product or obtaining other economic returns, and such returns do not come from their own use or operational activities, but rather rely on the overall development of a project created by the efforts of others, then such a product may be considered a "security."

In the context of RWA projects, if the purpose of an investor purchasing tokens is to obtain future appreciation or economic returns, rather than benefits derived from personal use or operational activities, then the token may possess a "profit expectation," thereby triggering the determination of securities attributes. This is especially true when the token's profits are highly dependent on the professional operations of the issuer or project team, such as liquidity design, ecological expansion, community building, or cooperation with other platforms; this characteristic of "relying on the efforts of others" further enhances its potential for securitization.

RWA tokens that have sustainable value in the true sense should be directly anchored to the real returns generated by underlying real-world assets, rather than relying on market speculation, narrative packaging, or platform premiums to drive their value growth. If the value fluctuations of the token primarily stem from the "recreation" by the backing team or platform operations, rather than from the returns of the assets themselves, then it does not possess the characteristics of "narrow RWA" and is more likely to be classified as a security token.

The U.S. SEC has introduced the Howey Test in the regulation of encryption tokens, meaning it no longer relies on the form of the token to determine regulatory attitudes, but instead shifts to a substantive review: focusing on the actual functions of the token, its issuance method, and investor expectations. This change marks a trend towards stricter and more mature legal positioning of U.S. regulatory agencies regarding encryption assets.

2. What is the legal logic of the "compliance" layering of RWA projects?

Having discussed so much about the concepts and definitions of RWA, let's return to the core question raised at the beginning of the article, which is also a focal point of common interest in the industry:

As RWA has developed to this day, which types of RWA can be considered truly "compliant" RWA? How can we satisfy the compliance of RWA projects in practice?

First of all, we believe that compliance means being regulated by local regulatory authorities and adhering to the provisions of the regulatory framework. In our understanding, the compliance of RWA is a layered system.

Layer One: Sandbox Compliance

This specifically refers to the Ensemble sandbox project designed by the Hong Kong Monetary Authority (HKMA), which is currently the narrowest and most regulatory pilot nature definition of "compliance." The Ensemble sandbox encourages financial institutions and technology companies to explore technological and model innovations in tokenization applications through projects such as RWA in a controlled environment to support its leading digital Hong Kong dollar project.

The Hong Kong Monetary Authority (HKMA) has demonstrated a high level of emphasis on the sovereignty of future monetary systems in promoting the central bank digital Hong Kong dollar (e-HKD) and exploring regulation of stablecoins. The competition between central bank digital currencies and stablecoins is essentially a redefinition and contestation of "monetary sovereignty." The sandbox provides a certain degree of policy space and flexibility for project parties, which is conducive to promoting exploratory practices of bringing real assets onto the blockchain.

At the same time, the Monetary Authority is actively guiding the development of tokenized assets, attempting to expand their applications in payment, settlement, financing, and other real-world scenarios within a compliance framework. Several technology and financial institutions, including Ant Group, are members of the sandbox community, participating in the construction of the digital asset ecosystem. Projects entering the regulatory sandbox, to a certain extent, signify a higher level of compliance and policy recognition.

However, from the current situation, such projects are still in a closed operating state and have not yet entered the broader secondary market circulation stage, indicating that there are still practical challenges in asset liquidity and market connection. Without a stable funding supply mechanism and efficient secondary market support, the entire RWA token system struggles to form a true economic closed loop.

Layer 2: Hong Kong Administrative Regulatory Compliance

As an international financial center, Hong Kong Special Administrative Region has been continuously promoting institutional exploration in the virtual asset field in recent years. As the first region in China to explicitly promote the development of virtual assets, especially tokenized securities, Hong Kong has become a target market for many mainland project parties due to its open, compliant, and clear regulatory environment.

By reviewing the relevant circulars and policy practices issued by the Hong Kong Securities and Futures Commission, it is not difficult to find that the core of Hong Kong's regulation of RWA is actually to incorporate it into the framework of STO for compliance management. Furthermore, the Securities and Futures Commission has established a relatively complete licensing system for Virtual Asset Service Providers (VASP) and Virtual Asset Trading Platforms (VATP), and is preparing to issue the second virtual asset policy declaration to further clarify its regulatory attitude and basic principles when virtual assets are combined with real assets. Under this institutional framework, tokenization projects involving real assets, especially RWA, have been included in a higher level of compliance regulatory category.

Based on the current RWA projects that have been established in Hong Kong and have a certain market influence, most of these projects exhibit clear securities attributes. This means that the tokens they issue involve ownership, income rights, or other transferable rights of real assets, which can constitute "securities" as defined under the Securities and Futures Ordinance. Therefore, these types of projects must be issued and circulated through the method of Security Token Offerings (STO) in order to obtain regulatory approval and achieve compliant market participation.

In summary, Hong Kong's regulatory positioning on RWA has become relatively clear: any mapping of real assets with securities attributes on the blockchain should fall within the STO regulatory framework. Therefore, we believe that the current path for RWA development promoted by Hong Kong is essentially a specific application and practice of the tokenization of securities (STO) pathway.

Layer Three: Clear Regulatory Framework for Encryption-Friendly Areas

In regions where there is an open attitude towards virtual assets and relatively mature regulatory mechanisms, such as the United States, Singapore, and some European countries, a more systematic compliance path has been established for the issuance, trading, and custody of encryption assets and their mapping to real-world assets. If RWA projects in such regions can legally obtain the necessary licenses and comply with information disclosure and asset compliance requirements, they can be regarded as compliant RWAs operating under a clear regulatory framework.

Fourth Layer: "Comprehensive Compliance"

This is the compliance in the broadest sense, which is opposed to "non-compliance". It specifically refers to RWA projects in certain offshore jurisdictions where the government temporarily maintains a "laissez-faire" attitude towards the virtual asset market, and has not been explicitly identified as non-compliant or illegal. Its business model has a certain degree of compliance space under the local legal framework. Although the scope and concept of this compliance are relatively vague and do not yet constitute a complete legal confirmation, it falls under the business status of "what is not prohibited by law is permissible" before legal regulations become clear.

In reality, we can observe that the vast majority of RWA projects find it difficult to comply with the first two types of regulations. Most projects choose to attempt the first three paths—namely, relying on the lenient policies of certain encryption "friendly" jurisdictions to try to bypass sovereign regulatory boundaries and achieve formal "compliance" at a lower cost.

As a result, RWA projects seem to be "falling like dumplings" continuously, but the point in time when they can truly generate substantial financial value has yet to arrive. The fundamental turning point will depend on whether Hong Kong can clearly explore the secondary market mechanism for RWA—especially how to open up the channels for cross-border capital circulation. If RWA trading remains confined to a closed market targeting local retail investors in Hong Kong, both asset liquidity and the scale of funds will be extremely limited. To achieve a breakthrough, it is essential to allow global investors to invest in Chinese-related assets through compliant mechanisms, indirectly "buying the dip in China" in the form of RWA.

Hong Kong's role here can be compared to the significance of Nasdaq for global tech stocks in the past. Once the regulatory mechanisms mature and the market structure becomes clear, when Chinese people want to "go overseas" for financing and foreigners want to "buy the dip" on Chinese assets, the first stop will definitely be Hong Kong. This will not only be a regional policy dividend but also a new starting point for the reconstruction of financial infrastructure and capital market logic.

In summary, we believe that the compliance of RWA projects should be carried out within the current framework, and all projects must maintain policy sensitivity. Once there are legal adjustments, urgent adjustments must be made. Given that the current regulatory environment is not yet fully clear and the RWA ecosystem is still in the exploratory stage, we strongly recommend that all project parties actively carry out "self-compliance" work. Although this means investing more resources and incurring higher time and compliance costs at the early stages of the project, in the long run, it will significantly reduce systemic risks in terms of legal, operational, and even investor relations.

Among all potential risks, the fundraising risk is undoubtedly the most lethal hidden danger for RWA. Once a project design is deemed illegal fundraising, it will face significant legal consequences regardless of whether the assets are genuine or the technology is advanced, posing a direct threat to the survival of the project itself and delivering a heavy blow to the assets and reputation of the enterprise. During the development of RWA, there will inevitably be differences in compliance definitions across different regions and regulatory environments. For developers and institutions, it is essential to formulate detailed phased compliance strategies in conjunction with their own business types, asset attributes, and regulatory policies of the target market. Only under the premise of ensuring controllable risks can RWA projects be steadily advanced.

3. Legal Advice on RWA Projects **

In summary, as a legal team, we systematically outline the core aspects that need to be focused on from a compliance perspective during the promotion of the RWA project across the entire chain.

1. Choose a policy-friendly jurisdiction

Under the current global regulatory landscape, the compliance advancement of RWA projects should prioritize jurisdictions with clear policies, mature regulatory systems, and an open attitude towards virtual assets, which can effectively reduce compliance uncertainty.

2. The underlying assets must have real redeemable capabilities

Regardless of how complex the technical architecture is, the essence of the RWA project is to map the rights of real assets onto the chain. Therefore, the authenticity of the underlying assets, the reasonableness of the valuation, and the enforceability of the redemption mechanism are all core factors that determine the project's credibility and market acceptance.

3. Obtain Investor Recognition

The core of RWA lies in asset mapping and rights confirmation. Therefore, whether the final buyer or user of off-chain assets recognizes the rights represented by on-chain tokens is the key to the project's success or failure. This is not only related to the individual willingness of investors but also closely related to the legal attributes of the tokens and the clarity of rights.

While RWA project parties promote compliance processes, they must also confront another core issue: investors must be informed. In reality, many projects package risks in complex structures, failing to clearly disclose the status of underlying assets or the logic of token models, which leads investors to participate without a full understanding. Once fluctuations or risk events occur, it not only triggers a market trust crisis but may also attract regulatory attention, making the situation more difficult to handle.

Therefore, establishing a clear mechanism for investor screening and education is crucial. RWA projects should not be open to all groups, but should consciously introduce mature investors with a certain level of risk tolerance and financial understanding. In the early stages of a project, it is especially necessary to set certain thresholds, such as a professional investor certification mechanism, participation limits, and risk disclosure briefings, to ensure that entrants are "informed and voluntary" and truly understand the asset logic, compliance boundaries, and market liquidity risks behind the project.

4. Ensure that the institutional operators in the link comply with regulations

In the entire process of RWA, it often involves multiple stages such as fundraising, custody, valuation, tax processing, and cross-border compliance. Each stage corresponds to regulatory agencies and compliance requirements in reality, and project parties must complete compliance declarations and regulatory connections within the relevant legal framework to minimize legal risks. For example, in the part involving fundraising, special attention should be paid to whether it triggers compliance obligations related to securities issuance, anti-money laundering, and so on.

5. Preventing Post-Compliance Risks

Compliance is not a one-time action. After the RWA project is implemented, it must continuously face changes in the dynamic regulatory environment. How to prevent potential administrative investigations or compliance accountability in the post-factum dimension is an important guarantee for the sustainable development of the project. It is recommended that the project party establish a professional compliance team and maintain a communication mechanism with regulatory agencies.

6. Brand Reputation Management

In the highly sensitive virtual asset industry regarding information dissemination, RWA projects need to pay attention to public opinion management and market communication strategies. Building a transparent, trustworthy, and professional project image helps enhance public and regulatory trust, creating a favorable external environment for long-term development.

4. Conclusion

In the current process of continuous integration between virtual assets and the real economy, various RWA projects have different intentions and mechanisms, encompassing both technological innovations and financial experiments. The capabilities, expertise, and practical paths of different projects vary greatly, warranting our careful study and categorization.

Through extensive research and project participation, we have also deeply realized that for market participants, the biggest challenge often lies not in the technical aspect, but in the uncertainty of the system, especially the unstable factors in administrative and judicial practices. Therefore, what we need more is to explore "practical standards"—even if we do not have legislative and regulatory power, promoting the formation of industry standardization and compliance in practice is still valuable. As long as there are more participants, mature paths, and regulatory agencies that have established sufficient management experience, the system will gradually improve. Within the framework of the rule of law, facilitating cognitive consensus through practice and promoting institutional evolution through consensus is indeed a "bottom-up" positive institutional evolution for society.

But we must also keep the compliance alarm ringing. Respecting the existing judicial and regulatory framework is the basic premise of all innovation activities. Regardless of how the industry develops or how technology evolves, the law remains the bottom-line logic for safeguarding market order and public interest.

Special statement: This only represents the personal views of the author of this article and does not constitute legal advice or legal opinions on specific matters.