In fact, everyone's daily activities regarding capital entry and exit are consistent with the case below.

In October, a typical financial prosecution case published by the Beijing prosecution authorities caused a stir in the industry: an illegal foreign exchange operation using USDT as a medium involved funds of 1.182 billion yuan, and five defendants were sentenced to 2 to 4 years for illegal business operations.

The key value of this case is far more than just "huge amounts." It clearly defines the criminal boundary of "cross-border currency exchange with virtual currency" for the first time: the core of judicial judgment lies not in whether "virtual currency is considered currency," but rather in whether the actions circumvent foreign exchange regulations to achieve illegal conversion between RMB and foreign currencies.

For a long time, such activities have operated frequently in the OTC circle and among groups needing cross-border funds, disguised under the guise of "technical intermediaries" and "concealed transactions."

The actions of Lin and others are by no means simply "buying and selling USDT." From the flow of funds, its essence is a complete financial attribute of an "alternative cross-border payment system," which can be broken down into four steps:

1. Starting point of funds: RMB funds from the domestic demand side (transferred through personal bank accounts);
2. Conversion stage: directly purchasing USDT with RMB on domestic virtual currency platforms (completing "fiat to virtual currency" conversion);
3. Cross-border stage: transferring USDT to foreign virtual currency platforms using cross-chain technology;
4. Endpoint of funds: exchanging USDT for an equivalent amount of foreign currency on foreign platforms, and transferring it to foreign bank accounts.
This path completely bypasses the statutory foreign exchange regulatory system, not subject to the limit of "individuals purchasing foreign exchange up to $50,000 per year," and has not gone through banks.

From a regulatory perspective, the technical form of virtual currency is irrelevant. As long as it is used to achieve "currency exchange" or "cross-border fund transfers," the nature of the behavior returns to the realm of "traditional financial activities," and must comply with statutory regulatory rules.

Virtual currency itself is not the risk; the transaction structure is the risk. As long as the structure touches the bottom line of "unauthorized cross-border currency exchange," criminal risks will not shift regardless of whether participants subjectively believe they are "engaging in virtual currency transactions."