Recently, regulators have been releasing a series of policy signals regarding virtual currencies.
Author: Lawyer Shao Shiwei
Following the People's Bank of China's meeting on November 28, 2025, to coordinate efforts to combat speculation in virtual currencies , seven industry associations jointly issued a "Risk Warning on Preventing Illegal Activities Involving Virtual Currencies" on December 5, 2025 , further demonstrating a clear and strong regulatory stance.
One sentence in this risk warning deserves the utmost attention from all practitioners, especially job seekers considering a transition to the Web3 industry:
"Domestic institutions and individuals who knowingly or should have known that a company is engaged in virtual currency-related business and still provide services to it will be held accountable in accordance with the law."
So, how should domestic Web3 job seekers understand the overall policy orientation of Chinese regulators towards virtual currencies? What real-world impact will these policies have on their job choices and career planning?
The current state of the booming Web3 job market
Why have more and more people chosen to transition to Web3 in the past two years?
In the numerous consultations that Attorney Shao has encountered, the reasons have generally focused on the following aspects.
1. The impact of social media information
What is the current situation of Web3 in the Chinese job market?
If you open Bilibili, you'll see a large number of content creators sharing their Web3 job-seeking experiences, job breakdowns, and "entry guides":
If you open Xiaohongshu (Little Red Book), you can also find many KOLs explaining various Web3 positions and showcasing salary levels:
The core message conveyed by these contents is highly consistent:
High salary, low entry barrier, remote work, and work freedom.
Furthermore, based on the consultation cases received by Attorney Shao in recent years, this is indeed the case. For example, job seekers for technical positions such as data analysts, AI engineers, development engineers, and product managers are often transitioning from traditional industries to work for cryptocurrency exchanges and Web3 projects.
After communicating with several job seekers, Attorney Shao found that for programmers, since their daily work involves code, transitioning from traditional industries to Web3 does not present a significant learning curve or obvious professional barriers. Regardless of whether the job seeker previously worked in a physical industry, an internet company, or went directly to Web3, the actual job content was not significantly different.
2. "Public Recruitment" on Job Search Apps
If you open recruitment platforms like Boss Zhipin, you'll find that many domestic human resources companies, headhunting firms, and even individual recruiters are openly recruiting talent for cryptocurrency exchanges and Web3 projects, with positions mainly in financial trading, technology, and product management.
Some will more subtly state that they are recruiting for CEX platforms (such as Binance, Easy, etc.);
Some are labeled as DEX projects;
Some even explicitly state: Cryptocurrency exchange, remote work.
In this scenario, job seekers are likely to trust the platform and assume it's a high-paying, legal, and "tacitly approved" job opportunity .
3. The allure of high salaries and remote work
Despite the fact that cryptocurrency exchanges and Web3 projects announced their overseas expansion after the "924 Notice" was issued in 2021, they still rely heavily on domestic employees in terms of actual employment due to considerations of labor costs and communication efficiency .
In terms of salary comparison, this kind of temptation is extremely powerful.
To give a fairly common example:
In traditional industries, the pre-tax annual salary is 500,000 to 700,000 yuan.
Switching to Web3 can lead to an annual salary of up to a million dollars, and often the salary can be paid in the form of virtual currency .
One is the income from traditional industries that requires legal taxation but whose actual take-home pay is significantly reduced;
One is a high reward that you "receive" in RMB.
If we set aside the legal risks for the moment, almost no one would be unmoved.
Many job seekers who consult me (mostly aged 25-35) have received offers with annual salaries exceeding one million yuan.
There are no obvious barriers to entry across industries; people work remotely and don't clock in, yet their income is several times higher than before.
It is against this backdrop that job seekers experience a stark contrast between the "hot" opportunities available and the "cold" policy signals .
The regulatory stance of continuous tightening and sustained high pressure
In stark contrast to the job market is the increasingly clear and increasingly stringent policy stance of domestic regulators.
1. A coordinated crackdown led by the central bank and involving multiple departments.
On November 28, 2025, the People's Bank of China convened a meeting of the coordination mechanism for combating virtual currency trading and speculation. The meeting reiterated that, in accordance with the requirements of the September 24, 2021 Notice, the crackdown on virtual currency trading activities should continue, and reiterated that virtual currency-related business activities are illegal financial activities.
More notably, the fact that the central bank is leading 13 departments this time signifies that financial, cybersecurity, public security, judicial, and foreign exchange departments will engage in deep collaboration to implement full-chain, penetrating supervision and crackdown.
2. Key Signals from Risk Warnings by the Seven Associations
On December 5, 2025, seven associations jointly issued a risk warning on preventing illegal activities involving virtual currencies, and the Economic Crime Investigation Bureau of the Ministry of Public Security forwarded the document the following day.
It clearly states:
Overseas virtual currency and real-world asset token service providers that directly or indirectly provide services to China through various means to conduct related business activities are also considered to be engaging in illegal financial activities.
Domestic staff of relevant overseas virtual currency service providers , as well as domestic institutions and individuals who knowingly or should have known that they are engaged in virtual currency-related businesses and still provide services to them , will be held accountable in accordance with the law.
The " domestic institutions and individuals " mentioned clearly refer to domestic employees recruited by overseas cryptocurrency exchanges and Web3 projects who work remotely in China.
The relevant content was actually mentioned in the Notice issued on September 24, 2021:
Those who work for relevant overseas virtual currency exchanges within China , as well as legal persons, non-legal persons, and natural persons who knowingly or should have known that these exchanges are engaged in virtual currency- related businesses and still provide them with services such as marketing , payment settlement, and technical support , will be held accountable in accordance with the law.
If we compare this to the "924 Notice" of 2021, we can find a significant change:
The specific actions listed at the time included "marketing and promotion, payment settlement, and technical support";
The wording for 2025 has been expanded to a broader scope— " providing services" .
This means that even if you are not in a technical role, even if you are only in operations, community, business development, or support roles, you may still be included in the risk scope .
What are the risks for Web3 workers working remotely in China?
After learning about these policies, many people seeking advice raise a very practical question:
Policies are policies, but in reality, are there really any domestic employees working for overseas Web3 platforms being arrested?
In their view, if the risk is really that high, why is there still so much related content on social media?
Why are there still so many job postings on recruitment platforms?
1. Why are there so few public media reports about this?
It's not surprising that clients have such questions. Aside from lawyers like us who specialize in criminal cases related to the new economy and Web3 industries, even lawyers in other fields don't have much experience with these cases. Often, even fellow lawyers ask us the same questions.
For ordinary people, the information they have access to is almost exclusively what is publicly disclosed by the media. So why do we rarely see Web3-related criminal cases (specifically referring to criminal cases involving Web3 projects and cryptocurrency exchanges, rather than individual cases of people being implicated simply because they received illicit gains from buying and selling cryptocurrencies) in public reports?
Based on Attorney Shao's experience in handling cases in recent years, the main reasons can be summarized in the following aspects:
- First, criminal cases are inherently highly confidential, and law enforcement agencies cannot disclose all case processes and details to the public.
- Secondly, in the Web3 field, due to the lack of clear and systematic legal regulations, law enforcement agencies have been in a state of "crossing the river by feeling the stones" for a considerable period of time. Many cases are inherently controversial regarding guilt or innocence, and between different types of crimes. Disclosing information to the public during the investigation stage could easily trigger public scrutiny of the legality of the investigation and the reasonableness of the characterization of the crime.
- Finally, in reality, cases involving cryptocurrency and Web3 often involve enormous sums of money. For example, cases handled by Attorney Shao frequently involve hundreds of millions or even billions of yuan. Against this backdrop, some cases also objectively exhibit issues such as profit-driven enforcement and "deep-sea fishing" (i.e., exploiting loopholes for profit).
Due to the aforementioned multiple reasons, it is difficult for ordinary job seekers to see complete, authentic, and referable typical cases through public media, thus making it difficult for them to gain an intuitive understanding of potential criminal risks.
However, Attorney Shao believes that social media platforms and Web3 job recruiters also bear some responsibility.
2. The responsibilities of social media platforms
In reality, most job seekers do not actively ignore risks, but are "guided" by the filtered content in the initial stage of information acquisition .
Many job seekers base their judgment on a very basic logic:
Since such content can be openly disseminated on mainstream platforms such as Xiaohongshu, Bilibili, and Douyin, it at least indicates that this type of work is "allowed to exist"?
The problem is that social media platforms have never been a filter for legal risks.
However, in reality, faced with massive and rapidly evolving content, the platform's manual review and technical identification processes lag behind. Some content is packaged as "technical sharing," "industry observation," or "personal experience," making it difficult for the review system to accurately determine its nature as illegal.
Furthermore, many publishers use English codes, industry jargon, and indirect topics (such as "Web3.0" and "digital assets") to circumvent the platform's direct keyword filtering. For example, much of the content users see (such as "airdrop grabbing," "buying USDT," and posting screenshots of profits) is essentially illegal marketing advertising that directs traffic to overseas cryptocurrency trading platforms.
However, this does not mean that the platform allows it. Taking Xiaohongshu as an example, the platform has explicitly stated that it opposes the promotion of virtual currency transactions and has carried out dynamic monitoring and governance, but the difficulty of governance does exist.
In May 2025, the Cyberspace Administration of China, together with financial regulatory authorities, dealt with a number of accounts and websites that spread false information about the capital market, engaged in illegal stock recommendations, and speculated on virtual currency transactions. Among the typical cases reported were those that induced netizens to participate in virtual currency transactions by sharing group chat information and screenshots of profits.
3. Legal loopholes in the recruitment process
In practice, some recruitment companies and headhunting agencies that cooperate with overseas virtual currency exchanges and Web3 projects do indeed exist in a legal gray area.
From a regulatory perspective, according to the "Regulations on the Administration of Foreign Labor Cooperation", enterprises that have not obtained the corresponding qualifications and recruit personnel for overseas entities and organize them to work overseas may be suspected of administrative violations or even criminal offenses (such as organizing others to illegally cross the border).
However, in practice, many positions adopt a domestic remote work model, which does not involve personnel leaving the country, and therefore do not fully fall within the direct scope of the above regulations.
Meanwhile, these recruitment entities typically operate as intermediaries, charging only service fees without directly participating in the actual business operations of the project. Even if the relevant platforms or projects are subsequently found to have problems, in current judicial practice, it remains relatively rare for law enforcement agencies to initiate criminal investigations and hold the headhunting companies or human resource agencies accountable.
It is precisely this gap between the system and practice that gives the relevant recruitment behavior a certain "safe appearance" in form, and further weakens job seekers' vigilance against potential legal risks.
4. Common misconceptions among job seekers
Many job seekers underestimate the risks because of two intuitive judgments:
One reason is the trust in social media, with the belief that if relevant content can be publicly disseminated, it means "there's not much of a problem";
Secondly, it stems from trust in recruitment platforms, with the belief that since job postings can be published on legitimate platforms, the work itself must be safe.
In addition, there is an even more common misconception—
Many people believe that since they are just entry-level employees, even if the platform has problems, law enforcement agencies should hold the boss accountable first, rather than ordinary workers.
However, in Web3-related criminal cases, the reality is often quite the opposite.
Unlike traditional industries, many project owners or exchange controllers have already physically gone overseas. It is actually these employees who work remotely within the country who are truly exposed to domestic judicial jurisdiction in the long term.
In conclusion
Even after detailed communication, some clients still ask me:
"So many people around me are doing it, and nothing has happened. Aren't you exaggerating?"
Whenever I hear this sentence, I am reminded of a case involving the sale of counterfeit cigarettes in 2019.
The person in question asked me in the detention center: "Every household in our village sells counterfeit cigarettes, so why did the police travel all the way from Shanghai to Yunnan just to arrest me? When the police arrested me, they said they had been staking out our area for six months."
Yes, why him?
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