MancunBlockchainLegal

On May 22, Eastern Time, the price of Bitcoin reached a new all-time high.
At the same time, two things have happened recently: first, the Hong Kong Legislative Council passed the "Stablecoin Regulation Draft", which is expected to take effect within the year; second, on the other side of the globe in the United States, the GENIUS Act, aimed at regulating stablecoins, is also being pushed forward vigorously.
It is reported that stablecoins are virtual assets designed to maintain a relatively stable value against certain assets, usually currencies. The value of stablecoins is pegged to various fiat currencies, such as the US dollar, euro, etc. Common stablecoins include USDT (Tether) and USDC. Previously, the Hong Kong Monetary Authority publicly released the first batch of stablecoin issuer sandbox lists, including JD Group's JD Coin Chain Technology ( Hong Kong ), Yuan Coin Innovation Technology, while Standard Chartered Bank (Hong Kong), Animoca Brands Limited, and HKT chose to apply jointly.
Stablecoin Monitor

Introduction
Since the birth of Bitcoin, its price has surged multiple times, driving a global cryptocurrency craze. At its peak, Bitcoin had broken through $100,000, and the total market capitalization of cryptocurrencies even exceeded the global circulation of US dollars at one point. This was followed by a significant emergence of cryptocurrency trading platforms and the active over-the-counter trading using USDT as a medium.
Under the current policies in our country, some individuals use crypto assets to privately exchange foreign currencies for RMB, profiting from the exchange rate differences and service fees. While this may seem technically harmless, it is actually under legal pressure. Such operations may involve the crime of illegal business operations under Article 225 of the Criminal Law, as well as the crime of money laundering under Article 191.
In this post, the Mankun Law Firm team will combine practical experience to help you analyze: why do cryptocurrency transactions frequently hit the "cross-border currency exchange" high-pressure line? What do you need to pay attention to?
Is cryptocurrency "property" or "data"? How does the law determine this?
1. Titles
Literature in related fields at home and abroad on

Lithuania - The Frontline of the EU Crypto Assets Industry
Against the backdrop of the accelerating formation of a global Crypto Assets regulatory framework, Lithuania is emerging as an important hub for the European Crypto Assets industry with its forward-thinking regulatory approach and efficient compliance system. As one of the first EU member states to establish a legal framework for Crypto Assets, Lithuania has created a "technology-friendly" regulatory environment that meets the compliance requirements of the EU single market while providing a clear development path for innovative enterprises.
(1) The first-mover advantage of the regulatory framework
The regulatory advantages of Lithuania are primarily reflected in the forward-looking nature of its legislation. Even before the formal implementation of the EU's Markets in Crypto-Assets Regulation (MiCA), the country had established a dual licensing system for virtual currency exchange service providers (VCESP) and wallet service providers (VCWSP).
This system not only provides enterprises with clear business boundaries but also through AML/CFT (Anti-Money Laundering / Counter Financing of Terrorism)

Right now, RWA is indeed hot.
From the Hong Kong Web3 Carnival in early April to the recent discussions in the Web3 legal circle, everyone is talking about RWA. There is some reason for this, as RWA is a relatively reliable and secure way of "issuing tokens."
A few days ago, Lawyer Mankun talked with everyone about China's new RWA projects, such as "Mankun Research |

In practice, many people will have such a cognitive misunderstanding: the act of exchanging or introducing foreign currency may be illegal, but it definitely does not constitute a criminal offense; His private exchange behavior is very hidden, and it is easy not to be detected by the judicial authorities; Helping others exchange currency and not making a profit, so it certainly does not constitute an administrative offense or criminal offense; It should not be illegal to sell foreign exchange such as US dollars to others to earn exchange rate differences; I don't care if my family and friends are making money through currency exchange, I just give them my bank card number for free, and I haven't done anything illegal; The customer asked me to help introduce the exchange channel, I happened to know people, so I introduced them to know, and I didn't collect money from it, so there should be no risk; So, are there any legal risks associated with the above behaviors? If it is illegal, how should it be characterized? Is it an administrative offense or a criminal offense? Where is the boundary between the act of exchanging foreign currency and constituting an administrative offense or a criminal offense? On May 8, 2025, the Supreme People's Procuratorate and the State Administration of Foreign Exchange

OTC traders, as core participants in the virtual asset market, focus on providing block trading platforms for high-net-worth clients, institutional investors, and exchanges. Through customized trading mechanisms, OTC traders can ensure that large-scale transactions are completed smoothly without disrupting market prices, while providing clients with higher privacy, transaction security, and liquidity guarantees.
Relevant data shows that in 2024, OTC trading volume will increase by 106% year-on-year, reflecting a significant rise in market activity and industry demand for OTC. Among these, stablecoins dominate—accounting for about 95% of the trading volume, with an annual trading volume growth of 147%. Additionally, in terms of market distribution, Europe dominates institutional OTC trading, with a demand share of 38.5%, followed by North America, Asia, and the Middle East, each accounting for 15.4%.
However, with the expansion of the market, OTC traders are facing a series of compliance challenges.
OTC Business Compliance

On April 25, 2025, the event "How Traditional Payment Transforms into Web3.0: Innovation Path and Compliance Practices" was held in Qianhai, Shenzhen, covering payment innovation, compliance challenges, and "payment + Web3" integration scenarios. Keynote speakers discussed on-chain payments, global regulatory trends, and PayFi practices, highlighting technological changes, compliance requirements, and business opportunities. The event deeply analyzed the future development of Web3 payment and industry hotspots, and built a high-quality communication platform.

In the past few days, discussions on Web3 Chinese social media regarding "some CEXs offering contract experience funds to college students" have continued to escalate. The incident originated from a leaked post published on the X platform, which involved sensitive keywords such as "CEX," "college students," and "gamblers," sparking a large amount of attention and discussion.
Lawyer Mankun found that the mainstream opinion in the comments under the post generally opposed this promotional method, believing that college students have not yet established mature values and risk awareness, and should not be targeted for promotion. For example, the media BlockBeats published an article titled "All trading platforms should immediately stop promoting contract experience funds to college students," directly pointing out that such behavior is essentially "gambling inducement disguised as financial enlightenment"; Yu Sen from Slow Fog Technology also shared in support, advocating for a complete boycott.
However, there are also some voices that express "nothing strange" about this. Some say they encountered similar promotions during their university years, while others believe that college students are adults and have civil rights.