This article will take the forum sharing by lawyer Shao Shiwei as the main thread, provide a professional interpretation of this coordination mechanism meeting, sort out the changing trends of criminal risks in the Web3 field, and explore the coping strategies of criminal lawyers in defense practice.
Author: Lawyer Shao Shiwei
On November 28, 2025, the People's Bank of China, together with thirteen other departments including the Ministry of Public Security, the Supreme People's Court, and the Supreme People's Procuratorate, convened a " Coordination Mechanism Meeting on Combating Virtual Currency Trading and Speculation ." The meeting reiterated that virtual currency-related business activities are illegal financial activities and emphasized that a high-pressure crackdown will be maintained on all types of virtual currency trading and speculation.
The very next day, the first "Criminal Law + Web3" professional forum in Zhengzhou, jointly hosted by Shanghai Mankiw Law Firm and Beijing Dongwei (Zhengzhou) Law Firm, successfully concluded. During the forum, Shao Shiwei, head of the Criminal Department of Shanghai Mankiw Law Firm, shared in-depth insights on the practice and regulatory trends of virtual currency crimes, which highly aligned with the policy signals released at the conference.
This article will take the forum sharing by lawyer Shao Shiwei as the main thread, provide a professional interpretation of this coordination mechanism meeting, sort out the changing trends of criminal risks in the Web3 field, and explore the coping strategies of criminal lawyers in defense practice.
Regulatory stance: Maintaining a high-pressure approach, with unwavering determination to crack down.
The meeting clearly stated that it will continue to implement the spirit of the 2021 "Notice on Further Preventing and Handling Risks of Virtual Currency Trading and Speculation," resolutely crack down on virtual currency trading and speculation, and rectify market chaos. It is worth noting that this meeting involved a wider range of departments than in the past, with the deep involvement of judicial departments such as the Ministry of Public Security, the Supreme People's Court, and the Supreme People's Procuratorate, marking a comprehensive shift in the fight against virtual currency crimes from the financial regulatory level to the level of criminal justice collaboration.
From Governor Pan Gongsheng's statement at the Financial Street Forum on October 27, 2025, to the convening of this coordination mechanism meeting, it is not difficult to see that the national determination to combat virtual currency crimes is consistent and constantly strengthened.
As lawyer Shao Shiwei pointed out at the Zhengzhou Forum, since 2017, the regulatory attitude has evolved from "wait and see" to "drawing a clear red line" and then to "comprehensive crackdown and deepening understanding".
Especially after 2021, with the introduction of the "924 Notice" and the in-depth promotion of the "Card Breaking Action", black and gray market funds began to use stablecoins such as USDT on a large scale for money laundering and illegal cross-border settlements, further highlighting the harm of virtual currency crimes.
Meanwhile, the historical risks accumulated by Web3 projects that experienced unchecked growth during the early "compliance loophole" are now coming to a head. Law enforcement accountability has extended to the technical execution and business promotion stages within China. A large number of technical teams, business development, and marketing personnel who previously worked on these projects are now the primary targets of accountability.
New Circumstances and New Challenges: Iteration of Criminal Methods and Upgrading of Law Enforcement Capabilities
The meeting pointed out that "speculation on virtual currencies has resurfaced, and related illegal and criminal activities occur from time to time, posing new challenges and new situations for risk prevention and control."
The so-called "new challenges" manifest in practice as the increasing specialization and concealment of criminal methods. At the forum, lawyer Shao Shiwei focused on analyzing a typical business chain involving the illegal buying and selling of foreign exchange using virtual currencies: using USDT as a medium, employing a "domestic-overseas offsetting" model to achieve cross-border fund transfers without any actual physical flow of funds. This type of activity is highly concealed and involves large sums of money, making it one of the mainstream channels for underground banks and money laundering crimes.
Furthermore, with the emergence of new concepts such as RWA and PayFi in the Web3 field, the forms of crime are becoming more complex. This places higher demands on law enforcement agencies' on-chain traceability capabilities, electronic evidence preservation, and cross-border investigation mechanisms.
Currently, my country's law enforcement agencies have been accumulating experience in practice. Lawyer Shao Shiwei, drawing on his own experience handling cases, points out that in major cases such as cross-border online gambling and cryptocurrency pyramid schemes, public security organs have gradually explored effective pathways for collaborating with overseas exchanges to track on-chain funds and collect evidence.
Enforcement Focus: Information Flow and Capital Flow Become the Core of Penetrating Supervision
The meeting emphasized the need to "focus on key links such as information flow and capital flow, strengthen information sharing, and further enhance monitoring capabilities."
Attorney Shao believes this means that judicial authorities will further intensify their crackdown on the transfer and laundering of illicit funds, especially targeting the on-chain circulation paths of stablecoins such as USDT, and will use technologies such as KYT and address profiling to conduct thorough analysis.
The case of "Concealing Crimes Related to USDT Trading," shared by Zhou Fang, director of the Wuzhi office of Henan Yingyu Law Firm, at the forum, is a microcosm of this trend: virtual currency activities in county-level areas are often closely intertwined with gray industry chains such as "money laundering" and "currency exchange." Through the typical case of a young man from a small town who was ultimately identified as a channel for fraudulent funds after exchanging USDT for others and charging a small handling fee, the case also reveals the widespread lack of legal awareness among grassroots participants and reflects that law enforcement agencies' monitoring of "fund flows" has been reduced to sporadic transactions at the county level.
Future Trends: Comprehensive Regulatory Upgrades Will Lead to More Refined Web3 Criminal Defense
From the "Notice on Preventing Bitcoin Risks" in 2013 to the "94 Announcement" in 2017, and then to the "924 Notice" in 2021 and this joint meeting of thirteen departments, it can be seen that my country's regulatory policies on virtual currencies have been continuously upgraded, the scope of crackdown has been continuously expanded, and the enforcement methods have become increasingly strict.
Against this backdrop, lawyer Shao Shiwei pointed out during the forum's roundtable discussion that Web3 criminal cases will show a trend of "increasing number and diversification of types" in the future.
Attorney Shao stated that cases of virtual currency theft and fraud that previously failed to be filed due to difficulties in securing evidence and disputes over the nature of the crime are now seeing a significant increase in the willingness of public security organs to file cases, thanks to improvements in their understanding and tactics. In the future, in addition to the currently prevalent crimes of aiding and abetting fraud and concealing wrongdoing, cases involving virtual assets such as theft, fraud, and embezzlement will also emerge in large numbers, further extending criminal risks to the entire chain of Web3 project development, operation, and trading.
In conclusion
The recent meeting of the coordination mechanism for combating cryptocurrency trading and speculation convened by the People's Bank of China serves as a clear reminder of the criminal risks associated with cryptocurrencies and the Web3 domain, and sets the tone for the next phase of enforcement actions. However, the increasing specialization, cross-domain nature, and technological sophistication of criminal methods also place higher demands on the professional competence of lawyers.
Attorney Shao believes that only by being familiar with industry operations, understanding technological logic, and deeply cultivating criminal expertise can one achieve effective communication and meticulous defense in increasingly complex virtual currency cases, truly safeguard the legitimate rights and interests of the parties involved, and contribute the professional strength of lawyers to the standardized development of Web3 in the Chinese context.
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