1. Mainland China Policy: A comprehensive ban on virtual currency trading and related businesses

Core Attitude: Firmly prevent and control financial risks, maintain the legal status of the Renminbi, and protect public property safety.

1. Prohibition of trading and speculation:

· All virtual currencies (such as Bitcoin, Ethereum, etc.) do not have the same legal status as fiat currency.

· No organization or individual may engage in pricing, buying, selling, or exchanging virtual currencies.

2. Prohibition of financial services:

· Financial institutions and payment institutions (banks, third-party payments) are not allowed to provide any services for virtual currency trading, including accounts, payment settlements, credit, etc.

3. Prohibited related business activities:

· In mainland China, it is strictly prohibited to establish virtual currency exchanges, issue tokens (ICOs), or provide derivative trading, etc.

4. Risk Warning:

· Participating in virtual currency investment and trading activities carries legal risks, and losses must be borne by oneself.

Simple summary: In mainland China, any form of virtual currency commercial transactions and financial services are explicitly prohibited. Although personal possession is not explicitly banned by law, it is not protected by law, and trading channels are completely cut off.

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II. Hong Kong Special Administrative Region Policy: Focused regulation, compliant operation

Core principle: Under the framework of "One Country, Two Systems," while developing the virtual asset market, implement strict and transparent licensing regulation, focusing on preventing money laundering and protecting investors.

1. Clarification on "prohibiting USDT trading":

· Hong Kong has not "completely banned USDT trading." The regulatory framework in Hong Kong is aimed at virtual asset trading platforms (VATP) and virtual asset service providers (VASP).

· As of June 1, 2023, all virtual asset trading platforms operating in Hong Kong or providing services to Hong Kong investors must apply for a license from the Hong Kong Securities and Futures Commission (SFC).

· This means that unlicensed platforms providing trading services (including USDT trading) in Hong Kong are illegal. However, licensed platforms can provide virtual asset trading services, including stablecoins (such as USDT), under strict regulatory requirements (such as client asset custodianship, anti-money laundering, market monitoring, etc.).

2. Key regulatory requirements (completely different from mainland China):

· Licensing management: Platforms must meet strict financial, compliance, and corporate governance standards to obtain a license.

· Retail investors can participate: Licensed platforms can provide services to retail investors after ensuring sufficient risk assessments.

· Stablecoin regulation is in progress: The Hong Kong Monetary Authority is actively promoting a licensing system for stablecoin issuers (such as USDT, USDC) and is expected to implement more comprehensive regulation on stablecoins in the future.

Simple summary: Hong Kong follows a route of "regulated openness." It is not a ban, but rather integrating it into a strict financial regulatory system. Unlicensed operations are prohibited, but compliant licensed institutions can conduct business.

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Comparison and key points extraction

Characteristics: Mainland China, Hong Kong Special Administrative Region

Regulatory stance: Completely prohibit commercial transactions and financial services; comprehensive regulation, licensed operation.

Trading platforms are strictly prohibited from establishment and operation and must apply for a license from the Securities and Futures Commission.

Public participation: Prohibit financial institutions from providing services; personal trading is not protected; allow licensed platforms to serve retail investors (subject to risk assessment).

Stablecoins (such as USDT) prohibit all related services and can be traded on licensed platforms; future issuers must also be licensed.

Core objective: Prevent and control risks, maintain financial stability and the authority of legal currency, become an international virtual asset center, and innovate under the assurance of development.

Important Reminder:

1. Information timeliness: Regulatory policies will be dynamically adjusted; please make sure to refer to the latest announcements from official institutions such as the People's Bank of China, the National Financial Regulatory Administration, the Hong Kong Securities and Futures Commission, and the Hong Kong Monetary Authority.

2. Risk borne by investors: Regardless of the jurisdiction, the price of virtual assets is highly volatile, and investment risks are extremely high; please make cautious decisions.

We recommend that you regularly check the websites of the above official institutions for the most accurate and timely policy information.

#监管框架

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