Topic Summary: "Policy Interpretation of Virtual Currency and Stablecoins under the New Regulations of Thirteen Departments": In order for our brothers to quickly understand, we have compiled the following ten question and ten answer policy interpretations based on key dimensions such as policy core points, regulatory logic, and industry impact: Question 1: What is the core characterization of stablecoins in the new regulations of the thirteen departments in 2025? Answer: Compared to the 2021 regulatory conference, four new participating units, namely the Central Financial Office, the National Development and Reform Commission, the Ministry of Justice, and the State Administration for Financial Regulation, have been added this time, effectively adding three core departments. The joining of the Central Financial Office is of great significance, as it is under the jurisdiction of the Central Financial Commission, marking the rise of virtual currency regulation from departmental coordination to top-level coordination. It means that virtual currency risks have been included in the core scope of national financial security, and the subsequent law enforcement coordination will be greatly strengthened. Question 2: Compared to the past, what changes have been made to the participating departments in this new regulation, and what signals have been sent? Answer: The regulatory scope covers the entire lifecycle, including the issuance, trading, custody, settlement, marketing and promotion of virtual currencies and stablecoins. The core standard for illegal identification is "domestic affiliation". As long as the business has some domestic connections, such as users within the country, servers within the country, funds from within the country, or technical teams within the country, it is considered illegal financial activity. Question 3: What are the regulatory scope of virtual currencies and stablecoins under the new regulations, and what are the key criteria for illegal identification? Answer: The new regulations emphasize that stablecoins currently cannot effectively meet customer identification, anti money laundering, and other requirements. There are three major risks at the core, namely money laundering risk, fundraising fraud risk, and illegal cross-border fund transfer risk. In practice, stablecoins have become the core settlement tool for "running point platforms" and "cross-border gambling" cases in many places, and their cross-border circulation characteristics are often used to evade foreign exchange controls. Question 4: What are the core risks of stablecoins identified in the new regulations? Answer: The only way out is to completely go out to sea and not have any connection with the territory. According to legal professionals, four "all overseas" requirements must be met, namely, the subject must be all overseas (the company is registered overseas without any domestic branches), the users must be all overseas (no services are provided to domestic users), the funds must be all overseas (accounts, reserve fund custody, etc. are all overseas), and the operation must be all overseas (servers and teams are all overseas, and domestic network resources are not used). Question 5: What are the new regulations for practitioners engaged in virtual currency and stablecoin business? What core requirements need to be met? Answer: The core stems from three major practical needs. Firstly, it is to maintain currency sovereignty. Virtual currencies (especially stablecoins) have a substitution relationship with legal tender, and currency sovereignty is the core of national financial stability. The promotion of digital RMB also replaces stablecoins; Secondly, to prevent systemic risks, virtual currencies may transmit risks through financial and social channels, while stablecoins also face the risk of a run on their reserves due to lack of transparency; Thirdly, we must adhere to the bottom line of capital controls. The cross-border boundaryless nature of virtual currencies will impact foreign exchange management. From 2023 to 2024, the number of related illegal fund transfer cases will increase by 40% year-on-year, with a total amount involved exceeding 50 billion yuan. Question 6: Why does the new regulation emphasize the principle of "stricter than looser" for virtual currencies, and what is the underlying logic? Answer: Non compliant. The new regulation covers the entire chain of virtual currency related businesses, and even if only providing technical services such as stablecoin underlying technology development, it is also included in the regulatory exclusion zone. Previously, some technical teams attempted to evade regulation by only focusing on technology and not participating in operations, and this grey path has been completely blocked under the new regulations. Question 7: Under the new regulations, is it compliant to only provide stablecoin underlying technology development without participating in operation? Answer: There are likely to be three types of supporting documents in the future. One possibility is to release documents related to criminal cases involving virtual currencies in the form of meeting minutes, but determining the value of virtual digital currencies will be a core challenge; Secondly, regarding the legal documents on the disposal of virtual currencies, the two high schools have conducted long-term research and the possibility of issuing them is extremely high; Thirdly, the Ministry of Justice may introduce relevant legal policies to improve the legal basis for qualitative and sentencing in virtual currency cases. Question 8: After the implementation of the new regulations, what supporting laws or policy documents may be introduced in the future? Answer: Although personal private trading of stablecoins is not directly prohibited, providing trading intermediaries for others, promoting stablecoins, and other behaviors may be considered illegal financial activities. At the same time, it should be clarified that virtual currency trading contracts are not protected by law, and any losses incurred in participating in transactions must be borne by individuals themselves, further escalating the related risks compared to the past. Question 9: What are the risk warnings for individuals participating in virtual currency and stablecoin related activities under the new regulations? Answer: Although personal private trading of stablecoins is not directly prohibited, providing trading intermediaries for others, promoting stablecoins, and other behaviors may be considered illegal financial activities. At the same time, it should be clarified that virtual currency trading contracts are not protected by law, and any losses incurred in participating in transactions must be borne by individuals themselves, further escalating the related risks compared to the past. Question 10: Is individual cryptocurrency trading illegal? Is it illegal for individuals to sell and sell? Why are people caught as soon as they trade? Answer: Make it clear to my brothers that buying and selling virtual currencies is not illegal in itself. The national policy is very clear: virtual currencies are not legal tender and are neither encouraged nor protected. Ordinary players can buy and sell normally, even if they accidentally receive stolen money. As long as they are not aware of it, it is not considered a crime. But why are people still being caught? Here are three common situations that brothers can compare and see: 1. The transaction price is abnormal, for example, if the market price is 7.2, you will sell in large quantities at 6.7 or 6.8, or charge a high price at 7.5, and the price is obviously abnormal; 2/Helping someone withdraw cash, the other party asks you to buy virtual currency and withdraw the exchanged RMB to them, and also charges a so-called "loss fee"; 3/It's not just about investing, but about "moving bricks" - whether it's over-the-counter trading or platform operators, this nature has changed. Do you think that if money were so easy to earn, you would have become a financial capitalist long ago, and you would still be laying bricks here? In short, for individual players who play around, normal buying and selling is a controllable risk; But once you cross the line and treat this as a business, the legal risk is much greater than the market risk.