2024 Memecoin Spending Report: Top "Whale" Transaction Fee Exceeds $130 Million, with Raydium and Bot Reaping the Most Benefits
Original Title: "2024 Memecoin Annual Consumption Report: Largest 'Whale' Spends $130 Million in Fees, Raydium and Bot Top Beneficiaries"
Original Author: Tesa, ChainCatcher
In 2024, Memecoin has become the hottest trend in the Crypto world. Soaring from a $200 billion market cap in 2023 to over a trillion dollars in 2024, Memecoin has not only solidified its position in the crypto market but has also outperformed benchmark indices of mainstream cryptocurrencies like Bitcoin and Ethereum, becoming the most dazzling asset class of the year.
Within this trading frenzy, numerous 'Whale' players emerged. They paid substantial fees in Memecoin transactions, directly driving the prosperous development of chains like Solana and filling the coffers of Memecoin infrastructure platforms such as Raydium, Jito, and Pump.fun.
Recently, ChainCatcher, in collaboration with the Memecoin intelligent trading platform Tesa and the Memecoin project Evan the Hobo, released the "2024 Memecoin Annual Consumption Report." This report provides a deep analysis of the consumption data of Memecoin players with transaction amounts exceeding $1,000 on the Solana chain in 2024, starting from fee distribution, comprehensively presenting the consumption behavior of Memecoin users this year and the benefit situation of various platforms.
If you wish to inquire about an individual's 2024 Solana consumption report, please refer to this link: https://report.tesa.top/
Key Data Overview
1. Total Memecoin Transaction Fees on the Solana Chain: Over $30.93 Billion.
2. Revenue Situation of Major Core Platforms:
· DEX such as Raydium: Earned $17 Billion in Fees, accounting for 56%.
· Trading Bots: Accumulated $7.5 Billion in Fees, representing 24%, with Photon leading with a 33% share.
· MEV Infrastructure Jito: Earned $3.4 billion, accounting for 11%.
· Pump.fun: Earned $2.4 billion, accounting for 8%.
1. User Concentration: The top 10% of users contributed 90% of the fees, with whale users averaging a high consumption of $13,000.
2. Top Users: The largest "whale" on Raydium spent nearly $130 million in a year.
Memecoin Fee Total and Distribution
1. Total Fee Amount Exceeding $30 Billion
As the most popular Memecoin public chain in 2024, Solana's on-chain fee data has become a microcosm of the entire Memecoin market consumption. By analyzing about 4 million Solana user addresses with transaction amounts exceeding $1,000 in 2024, the total fees generated by Memecoin transactions on the Solana chain amounted to a staggering $30.93 billion, demonstrating Solana's dominant position in Memecoin transactions.
2. DEX Raydium and Other DEXs as the Biggest Beneficiaries, Earning Over $17 Billion in Fees
The over $30 billion in fees contributed by Memecoin users mainly flowed to four major platforms: decentralized exchanges (DEXs) like Raydium, trading bots (such as Photon), MEV Infrastructure Jito, and the one-click token issuance platform Pump.fun.
Among them, DEXs like Raydium took the lead with over $17 billion in fee revenue, accounting for 56% of the total, with Raydium alone capturing an 80% share of fees among all DEXs. Trading bots followed with $7.5 billion, representing 24%.
Jito, providing priority transaction (anti-front-running) services, earned $3.4 billion, accounting for 11% due to its exclusive ability. Pump.fun, on the other hand, simplified the token issuance process and gained $2.4 billion, representing 8%.

3. Photon Accounts for Over 33% of Total Transaction BOT Fees and Emerges as the Most Popular BOT
Among various transaction BOTs, Photon stands out by earning a total of $250 million in fees in 2024, representing 33.3% of all transaction BOT fees. Following closely behind are Trojan and Bullx, earning $123 million and over $94 million in fees, accounting for 16.2% and 12.4%, respectively.
Additionally, other BOTs also generated substantial revenue: PepeBoost earned $65.1 million, representing 8.6%; BonkBot earned $63.17 million, representing 8.3%; GMGM and BananaGun earned $23.76 million and $20.53 million, accounting for 3.1% and 2.70%, respectively.
Meanwhile, the data provider of this report, Tesa meme trading platform, offers users a different choice. In contrast to traditional BOTs that charge a 1% transaction fee, Tesa reduces user transaction costs through a subscription model. Furthermore, Tesa has launched the CEX Listing Sniper feature.

4. Whale Users Spent an Average of $13,000 in Transaction Fees for Memecoin Trades in 2024
In 2024, Memecoin players showed significant differences in average transaction fee expenditures across major platforms:
· Raydium: $445.45 per user
· Transaction BOT: $193.89 per user
· Jito: $87.07 per user
· Pump.fun: $63.13 per user

Users are categorized into three groups based on the amount of transaction fees:
1. Whale Users (top 5% highest fees): Avg. annual expenditure as high as $13,000.
2. Regular Users (in the 20%-30% fee range): Avg. expenditure $171.28.
3. Newbie User (25% with the lowest fees): Average spending per person is only $17.67.
In terms of platform preference, Raydium and Trading BOT have become the main fee expenditure places for whale users and regular users, while Newbie Users tend to choose Trading BOT and Pump.fun.

5. The Largest "Whale" User on a Single Platform Spent $129 Million in Fees
In 2024, the Memecoin market saw the emergence of a true "whale" user. Among them, user address MfDuWeq on platforms like Raydium paid a staggering $129 million in fees in one year, far ahead of other platforms.
In contrast, the highest fee expenditures on other platforms were relatively "moderate":
· Trading BOT: $1.43 million
· Jito: $6.1399 million
· Pump.fun: $2.3992 million
This significant difference further highlights Raydium's dominant position in the Memecoin trading market.

II. Memecoin User Expenditure Concentration and Cross-Platform Characteristics
1. Top 10% of Users by Spending Contribute Over 90% of Fees
Memecoin users' spending behavior exhibits a clear "80-20 rule": a few top users contribute the majority of fees. The specific data is as follows:
· The top 1% of users contributed 67.46% of the fees, with an average fee amount of $53,000 per person;
· The top 10% of users contributed 90.97%, with an average fee amount of around $7,182 per person;
· The top 20% of users contributed 95.24%. The average fee amount per person is approximately $3,760.
This high level of consumption concentration indicates that the fee income in the Memecoin market mainly relies on a small number of high-spending users, while the fee expenditure of the majority of regular users is relatively low.

2. Raydium has the highest consumption concentration, Pump.fun relatively lower
Among Raydium, Trading BOT, Jito, and Pump.fun, Raydium has the highest consumption concentration. Data shows that the top 1% of users contributed $1.358 billion in fees, accounting for 79.88% of the total $1.7 billion in fees, with an average fee per person reaching $34,700; while the average fee per person for users ranking in the 2-20% range is below $800, and the long-tail users ranking beyond 20% have an average fee per person of less than $100. This also reflects Raydium's high dependence on top users.

In contrast, for Jito, the top 1% of users in fee ranking contributed $186 million in fees, accounting for 54.55%, although the concentration is lower than Raydium, it still exceeds half. There is also a significant difference in the average fees between Jito's top users and long-tail users, with the top 1% of users around $4,759, while users in the 2%-10% range drop to $300, and long-tail users ranking beyond 10% have an average fee per person of less than $50.

The consumption concentration at the top end for Trading BOT and Pump.fun is relatively lower:
· Trading BOT: The top 1% of users contributed $313 million, accounting for 41.24%.
· Pump.fun: The top 1% of users contributed $96.62 million, accounting for 39.07%.
This difference indicates that different platforms have significant differences in user structure and profit models.

In terms of average fees per person, there is also a significant difference between top users and long-tail users on Trading BOT and Pump.fun. The top 1% of users on Trading BOT have an average fee per person of $7,990, while users in the 2%-10% range are less than $1,000, and users beyond the 20% range are all below $60.
The average fee per user in the top 1% on Pump.fun reached $2467, while users ranked 2%-10% paid less than $300, and those ranked after 20% paid less than $50.

3. Raydium Has the Highest Utilization Rate, with Over Half of Users Relying on Trading Bots
Within the Solana DEX ecosystem, despite Raydium's higher transaction fee (0.25%) compared to Meteora's (0.16%), Raydium still attracts the vast majority of users due to its strong market dominance. Statistical data shows:
· Out of approximately 4 million Solana addresses, around 89.27% (3.4968 million addresses) have used Raydium.
· In contrast, the total utilization rate of Meteora and other DEXs is only 35.53% (1.3917 million addresses).
This phenomenon indicates that Memecoin users, when choosing a trading platform, do not solely consider fees but also value factors such as liquidity, user experience, and platform stability.

Furthermore, the use of trading bots is also widespread:
· Over 2.11 million addresses utilize trading bots, with a usage rate of 53.83%.
· In comparison, the utilization rates for Pump.fun and Jito are 46.43% and 45.01%, respectively, still below the halfway mark.
These data reflect users' high reliance on efficient and convenient trading tools, while also showcasing Raydium's absolute market dominance.
4. Over Half of Bot Users Use Only a Single Bot Platform
Within the trading bot market, user choices exhibit noticeable concentration. The data shows:
· 66% (1.3995 million) of bot user addresses use only a single trading bot.
· 34% (712,400) of users choose to use multiple BOT trades.
This percentage indicates that users have high loyalty to the selected BOT platform, or due to the lack of significant differentiation between platforms, users, once they choose a BOT, lack the motivation to switch or engage in multi-platform trading.

5. Users Not Using BOTs Have Significantly Higher Transaction Volume
Compared to users using trading BOTs, users not using BOTs have an average transaction volume several times higher:
· Users using BOTs: Average transaction volume is $93,500.
· Users not using BOTs: Average transaction volume reaches $678,800.
This data may reflect that the BOT user group consists mainly of regular users and newbies, while high-volume whale users tend to prefer manual operation or use efficient tools to seek more precise control.

6. Whale Users Prefer Photon, Regular Users Lean Towards Trojan
Users with different spending levels show significant differences in choosing trading BOTs:
Whale Users (Top 5%)
· Photon is the most popular trading BOT, contributing 38.9% of transaction fees.
· Trojan follows closely, with a share of 15.02%.
This choice indicates that whale users prefer to use the powerful and stable Photon BOT.
Regular Users (Ranked 20%-30%)
· Trojan is the top choice for regular users, accounting for 19.27% of total transaction fees.
· Photon and Bullx rank second and third with 17.34% and 14.71%, respectively.
The choice of regular users is becoming more diverse, demonstrating widespread acceptance of different BOT features.
Newbie Users (Bottom 25%)
· The choice of newbie users is relatively dispersed, with Trojan, Photon, PepeBoost, and Bullx being the main trading BOTS, each contributing over 10% of the fees.
This distribution reflects that newbie users tend to try out multiple tools when using BOTS, rather than concentrating on a single platform.

III. 2024 Memecoin Annual Consumption TOP 10 Address Analysis
1. 5 Addresses with Fees Exceeding Ten Million Dollars, with the Highest Spending Reaching 133 Million Dollars
In the 2024 Memecoin transactions, the total fees of the Top 10 user addresses show a high level of consumption concentration, with 5 addresses having total fees exceeding 10 million dollars:
· MfDuWe: 133 million dollars (Fee Rate 0.3%, Total Transaction Amount 448.55 billion dollars).
· kpqUj8: 19.86 million dollars.
· YubQzu: 18.2 million dollars.
· HBGdum: 11.9 million dollars.
· 7vi5dy: 11.89 million dollars.

2. Comparison of Highest and Lowest Fee Users
· The address with the highest fee, MfDuWe, demonstrates a large transaction volume and expenditure, with its fee representing 0.3% of the total transaction amount.
· In contrast, the fee rates of addresses 13g21m and 89VB5U are only 0.005%, the lowest level.
This data clearly reflects the consumption difference among different users in the Memecoin market, as well as the significant contribution of top users to the overall fee revenue.
3. Total Fee Amount from Top 10 Addresses on Platforms such as Raydium, Jito, Pump.fun
The Top 10 user addresses on the Raydium platform show a high fee contribution, with each address's annual fee spending exceeding $10 million. These users almost entirely concentrate all fee spending on the Raydium platform. Details of the Top 10 addresses:

For Jito, the fee amounts from the Top 10 addresses range from $1.2 million to $6.2 million. Details of the Top 10 addresses:

For Pump.fun, the fee amounts from the Top 10 addresses range from $500,000 to $2.4 million. Details of the Top 10 addresses:
4. Total Fee Details of Various Bot Fee Top 10

4. If you need to check your personal 2024 Memecoin spending statement, please refer to:
https://report.tesa.top/
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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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