Web3 Lawyer Decodes: What kind of RWA do we all understand?

Source: encryption salad

Recently, discussions about RWA projects have been fervent in various Web3 communities. Industry observers often claim online that "RWA will reconstruct the new financial ecosystem of Hong Kong," believing that relying on the existing regulatory framework of the Hong Kong Special Administrative Region, this sector will usher in breakthrough development. In discussions with colleagues, the encryption salad found that everyone has been debating the so-called "compliance" issue recently, and their understanding of the question "what is compliance" varies greatly, often resulting in a situation where each side has its own reasoning. This phenomenon arises from the existing differences in understanding the concept of RWA.

Therefore, it is necessary for the encryption salad to discuss the concept of RWA from the perspective of a professional legal team, and to clarify the compliance red lines of RWA.

1. How should the concept of RWA be defined?

(1) Background and Advantages of RWA Projects

Currently, RWA is becoming the focus of market discussions and is gradually forming a new wave of development. The formation of this phenomenon is mainly based on the following two backgrounds:

The first reason is that the advantages of the token itself can make up for the shortcomings of traditional financing.

Traditional financial market projects have long faced inherent shortcomings such as high entry barriers, long financing cycles, slow financing speeds, and complex exit mechanisms. However, token financing can effectively bypass these defects. Compared to traditional IPOs, RWA has the following significant advantages:

1. Fast Financing Speed: Since the circulation of tokens is based on blockchain technology and typically takes place in decentralized intermediary trading institutions, it bypasses the obstacles that traditional financial projects may encounter, such as foreign investment access restrictions, industry policy constraints, and lock-up period requirements. At the same time, it can compress the review process that would normally take months or even years, greatly enhancing the financing speed.

2. Asset Diversification: Traditional IPOs have a single type of asset, only supporting equity issuance. Therefore, there are strict requirements for the revenue stability, profitability, and asset-liability structure of the issuing entity. However, for RWA, the types of suitable assets are more diverse, encompassing various non-standard assets. This not only expands the range of financeable assets but also shifts the focus of credit assessment to the quality of the underlying assets, significantly lowering the qualification threshold for the issuing entity.

3. Relatively low financing costs: Traditional IPOs require long-term collaboration among multiple intermediaries such as investment banks, auditors, and law firms, with total listing costs potentially reaching millions or even tens of millions. However, RWA issues tokens through decentralized exchanges, eliminating a significant amount of intermediary fees, while also running on smart contracts, thus saving another substantial amount in labor costs.

In summary, RWA has taken center stage in financing projects due to its unique advantages, while the Web3 world and the cryptocurrency space particularly need funds and projects from the traditional real world. This has led to a situation where, whether aiming for substantial business transformation or simply wanting to ride the "trend" and gain exposure, leading projects in the segmented fields of listed companies and a variety of unique grassroots startups are actively exploring the potential applications of RWA.

Secondly, Hong Kong's "compliance" has added fuel to the heat.

In fact, the development of RWA overseas has been underway for some time. The recent surge in interest is due to a series of regulatory innovations that have been passed in Hong Kong, which have led to the launch of several benchmark projects, providing domestic investors with a compliant channel to participate in "RWA" for the first time. The "compliant" RWA that Chinese people can access has been realized. This groundbreaking progress has not only attracted native encryption assets but has also prompted traditional projects and funds to start paying attention to the investment value of RWA, ultimately driving market enthusiasm to new heights.

However, do users who want to experience RWA really understand what RWA is? There are various RWA projects with a wide range of underlying assets and operational structures. Can everyone distinguish their differences? Therefore, we believe it is necessary to clearly define what compliant RWA is through this article.

People generally believe that RWA is a financing project that tokenizes underlying real-world assets through blockchain technology. However, when we delve into the underlying assets of each project and trace back the process of project operation, we find that the underlying logic of these projects is actually different. We conducted a systematic study on this issue and summarized the following understanding of the concept of RWA:

We believe that RWA is actually a broad concept and does not have a so-called "standard answer." The process of asset tokenization through blockchain technology can all be referred to as RWA.

(2) Elements and Characteristics of RWA Projects

A genuine RWA project needs to have the following characteristics:

1. Based on real assets

The authenticity of the underlying assets and whether the project party can establish a transparent and acceptable off-chain asset verification mechanism for third-party audits are key criteria for determining whether the project's tokens will achieve effective value recognition in reality. For example, PAXG, which issues tokens pegged to gold in real-time, each token is backed by 1 ounce of physical gold, and the gold reserves are managed by a third-party platform, with quarterly reserve audits conducted by a third-party auditing firm, and it even supports redeeming a corresponding amount of physical gold with the tokens. This highly transparent and regulated asset verification mechanism allows the project to gain the trust of investors and provides a basis for effective valuation in the real financial system.

2. Asset Tokenization on the Blockchain

Asset tokenization refers to the process of converting real-world assets into digital tokens that can be issued, traded, and managed on-chain through smart contracts and blockchain technology. The value circulation and asset management processes of RWA are automated through smart contracts. Unlike traditional financial systems that rely on intermediaries for transactions and settlements, RWA projects can leverage smart contracts to achieve transparent, efficient, and programmable execution of business logic on the blockchain, significantly enhancing asset management efficiency and reducing operational risks.

Asset tokenization endows RWA with the key characteristics of being divisible, tradable, and highly liquid. After asset tokenization, assets can be split into smaller tokens, lowering the investment threshold and changing the way assets are held and circulated, allowing retail investors to participate in investment markets that were previously high-threshold.

3. Digital assets have ownership value

The tokens issued by RWA projects should be classified as digital assets with property attributes. The project parties should clearly distinguish between data assets and digital assets: data assets are collections of data owned by enterprises that can create value. In contrast, digital assets represent value itself and do not require data for repricing. For example, when you design a painting, upload it to the blockchain, and generate an NFT, this NFT is a digital asset because it can be authenticated and traded. However, the extensive user feedback, browsing data, click-through rates, and other data you collect regarding this painting belong to data assets. You can analyze data assets to determine user preferences, improve your work, and adjust its price.

4. The issuance and circulation of RWA tokens comply with legal regulations and are subject to administrative supervision

The issuance and circulation of RWA tokens must operate within the existing legal framework; otherwise, it may not only lead to project failure but also trigger legal risks. Firstly, real-world assets must be genuine and legal, with clear and undisputed ownership, so that they can serve as the basis for token issuance. Secondly, RWA tokens typically possess rights to income or asset interests and can easily be classified as securities by regulatory authorities in various countries; therefore, compliance with local securities regulations must be ensured before issuance. The issuing entity must also be a qualified institution, such as one holding asset management or trust licenses, and must complete KYC and anti-money laundering procedures. Once in the circulation phase, the trading platforms for RWA tokens must also be regulated, usually requiring compliance as an exchange or possessing financial licenses for secondary markets, and trading on decentralized platforms is not allowed. In addition, continuous information disclosure is necessary to ensure that investors can access the real conditions of the assets linked to the tokens. Only under such a regulatory framework can RWA tokens be issued and circulated legally and safely.

In addition, the compliance management of RWA has typical cross-jurisdictional characteristics. Therefore, it is necessary to build a systematic compliance framework that covers the legal norms of the asset's location, the flow of funds, and various regulatory authorities. Throughout the entire lifecycle of asset on-chain, cross-chain, and token cross-border and cross-platform circulation, RWA must establish a compliance mechanism that encompasses multiple aspects such as asset confirmation, token issuance, fund flow, profit distribution, user identification, and compliance auditing. This involves not only legal consulting and compliance design but may also require the introduction of third-party trust, custody, auditing, and regulatory technology solutions.

(3) Types and Regulation of RWA Projects

We found that there are two parallel types in the compliant RWA projects:

1. Narrow RWA: Physical Assets on Chain

We believe that the narrow definition of RWA specifically refers to projects that tokenize real assets with authenticity and verifiability on the blockchain, which is also the general understanding of RWA among the public. Its application market is the most extensive, such as projects that anchor tokens to offline real assets like real estate and gold.

2. STO (Security Token Offering): Financial Assets on the Blockchain

Apart from the narrowly defined RWA projects, we have found that there are a large number of RWA projects in the market that are STO.

(1) Definition of STO

According to the differences in underlying assets, operational logic, and token functions, the existing tokens in the market can be roughly divided into two major categories: Utility Tokens and Security Tokens. STO refers to the process of financializing real assets and issuing tokenized shares or certificates in the form of Security Tokens on the blockchain.

(2) Definition of Security Tokens

Securities tokens, in contrast to utility tokens, are, simply put, on-chain financial products driven by blockchain technology that are subject to securities regulations, similar to electronic stocks.

(3) Regulation of Security Tokens

Under the regulatory framework of mainstream encryption asset-friendly countries such as the United States and Singapore, once a token is classified as a security token, it will be subject to the constraints of traditional financial regulatory agencies (such as the Securities and Exchange Commission), and the design, trading models, etc., of the token must comply with local securities regulations.

From an economic perspective, the core objective of financial products is to coordinate the supply and demand relationship between financing parties and investors; from a legal regulatory standpoint, some countries focus more on protecting investor interests, while others lean towards facilitating and innovating financing activities. This difference in regulatory stance is reflected in the specific rules, compliance requirements, and enforcement intensity within the legal systems of various countries. Therefore, when designing and issuing RWA products, it is essential to consider not only the authenticity and legality of the underlying assets but also to conduct a comprehensive review and compliance design on key aspects such as product structure, issuance method, circulation paths, trading platforms, investor admission thresholds, and capital costs.

It is especially noteworthy that if the core appeal of a certain RWA project comes from its high leverage and high return expectations, and positions "hundredfold, thousandfold returns" as the main selling point, then regardless of its superficial packaging, it is very likely to be classified as a securities product by regulatory authorities. Once identified as a security, the project will face a much stricter and more complex regulatory framework, and its subsequent development path, operational costs, and even legal risks will be greatly elevated.

Therefore, when discussing the legal compliance of RWA, we need to deeply understand the connotation of "securities regulations" and the regulatory logic behind it. Different countries and regions have different definitions and regulatory focuses regarding securities. The United States, Singapore, and Hong Kong have all defined the criteria for recognizing security tokens. It is not difficult to see that the method of definition is essentially to determine whether the token meets the recognition standards for "securities" under local securities regulations. Once it meets the securities conditions, it is classified as a security token. Therefore, we have compiled the relevant provisions of key countries (regions) as follows:

A. Mainland China

In the regulatory framework of mainland China, the Securities Law of the People's Republic of China defines securities as stocks, corporate bonds, depository receipts, and other negotiable instruments recognized by the State Council, and also includes the listing and trading of government bonds and shares of securities investment funds under the regulation of the Securities Law.

(The above image is taken from the Securities Law of the People's Republic of China)

B. Singapore

Although the "Guidelines on Digital Token Offerings" and the "Securities and Futures Act" in Singapore do not directly mention the concept of "security tokens", they enumerate the different circumstances under which tokens may be recognized as "capital market products":

(The above image is taken from the "Digital Token Issuance Guide" )

C. Hong Kong, China

The Securities and Futures Commission of Hong Kong has specific enumerative provisions regarding the positive list and negative list of securities in the Securities and Futures Ordinance.

(The above image is taken from the Securities and Futures Ordinance) )

The regulation defines "securities" to include "shares, equity shares, notes, bonds" as structured products, without restricting their existence to traditional carriers. The SFC has explicitly stated in the "Circular on Intermediaries Engaging in Activities Related to Tokenized Securities" that the nature of the objects of its regulation is essentially traditional securities packaged as tokens.

D. United States

The U.S. Securities and Exchange Commission (SEC) stipulates that any product passing the Howey Test is classified as a security. Any product identified as a security is subject to SEC regulation. The Howey Test is a legal standard established by the U.S. Supreme Court in the 1946 SEC v. W.J. Howey Co. case, used to determine whether a transaction or scheme constitutes an "investment contract," thereby falling under the regulation of U.S. securities law.

The Howey Test outlines four conditions under which financial products are classified as "securities." The application of the Howey Test in digital assets is specified in the SEC's publication, "Framework for 'Investment Contract' Analysis of Digital Assets." We will proceed with a detailed analysis of this.

• The Investment of Money（金钱投入）

Refers to investors putting money or assets into a project in exchange for certain rights or expected returns. In the field of digital assets, whether using fiat currency or encryption to purchase tokens, as long as there is a value exchange, it is generally considered to meet this standard. Therefore, most token issuances basically meet this condition.

• Common Enterprise

"Joint ventures" refer to the close binding of interests between investors and issuers, usually manifested by the direct correlation between investors' returns and the project's operational effectiveness. In token projects, if the returns of token holders depend on the business development of the project party or the operational results of the platform, it meets the characteristics of a "joint venture," and this condition is relatively easy to establish in reality.

• Reasonable Expectation of Profits Derived from Efforts of Others

This point is key to determining whether a token will be classified as a security token. This condition refers to the situation where, if the purpose of the investor purchasing the product is to expect appreciation of the product in the future or to obtain other economic returns, and such returns do not come from its own use or operational activities, but rather rely on the overall development of a project created by the efforts of others, then such a product may be regarded as a "security."

In the context of RWA projects, if the purpose of an investor purchasing tokens is to obtain future appreciation or economic returns, rather than the benefits derived from personal use or business operations, then the tokens may possess "profit expectations," thereby triggering the determination of securities attributes. Especially when the returns of the tokens are highly dependent on the professional operation of the issuer or project team, such as liquidity design, ecological expansion, community building, or collaborations with other platforms, this characteristic of "relying on the efforts of others" further enhances the possibility of its securitization.

RWA tokens that have sustainable value in the true sense should be directly anchored to the real income generated by the underlying real assets, rather than relying on market speculation, narrative packaging, or platform premiums to drive their value growth. If the value fluctuations of a token primarily stem from the "recreation" by the underlying team or platform operations, rather than the income changes of the assets themselves, then it does not possess the characteristics of "narrow RWA" and is more likely to be seen as a security token.

The US SEC has introduced the Howey Test in its regulation of encryption tokens, meaning it no longer relies on the form of the token to determine its regulatory stance, but instead shifts to a substantive review: focusing on the actual functions of the token, the method of issuance, and investor expectations. This change marks a trend towards stricter and more mature legal positioning of crypto assets by US regulatory agencies.

2. What is the legal logic of the "compliance" stratification in RWA projects?

Having discussed so much about the concepts and definitions of RWA, let's return to the core question raised at the beginning of the article, which is also a focus of widespread concern in the industry:

As of now, what types of RWA can be considered truly "compliant" RWA? How can we meet the compliance of RWA projects in practice?

First, we believe that compliance means being regulated by local regulatory authorities and adhering to the provisions of the regulatory framework. In our understanding, the compliance of RWA is a layered system.

Layer One: Sandbox Compliance

This specifically refers to the Ensemble sandbox project designed by the Hong Kong Monetary Authority (HKMA), which currently represents the narrowest and most regulatory pilot nature of the definition of "compliance". The Ensemble sandbox encourages financial institutions and technology companies to explore technological and model innovations for tokenization applications through projects like RWA in a controlled environment, in support of the digital Hong Kong Dollar project they are leading.

The Hong Kong Monetary Authority (HKMA) has shown a high level of attention to the sovereignty of the future monetary system in promoting the central bank digital Hong Kong dollar (e-HKD) and exploring the regulation of stablecoins. The competition between central bank digital currency and stablecoins is essentially a redefinition and contestation of "monetary sovereignty." The sandbox provides project parties with policy space and flexibility to a certain extent, which is conducive to promoting exploratory practices for bringing real assets on-chain.

At the same time, the Monetary Authority is actively guiding the development of tokenized assets, attempting to expand their applications in real scenarios such as payments, settlements, and financing within a compliant framework. Several technology and financial institutions, including Ant Group, are members of the sandbox community, participating in the construction of the digital asset ecosystem. Projects entering the regulatory sandbox, to a certain extent, indicate a higher level of compliance and policy recognition.

However, from the current situation, such projects are still in a closed operation state and have not yet entered the broad secondary market circulation stage, indicating that there are still real challenges in asset liquidity and market connectivity. Without a stable funding supply mechanism and efficient secondary market support, the entire RWA token system is difficult to form a true economic closed loop.

Second Layer: Hong Kong Administrative Regulatory Compliance

As an international financial center, Hong Kong Special Administrative Region has been continuously advancing institutional exploration in the field of virtual assets in recent years. As the first region in China to explicitly promote the development of virtual assets, especially tokenized securities, Hong Kong has become a target market that many mainland project parties are eager to explore, thanks to its open, compliant, and clear regulatory environment.

By reviewing the relevant circulars and policy practices released by the Hong Kong Securities and Futures Commission, it is not difficult to find that the core of Hong Kong's regulation of RWA is actually to incorporate it into the framework of STO for compliance management. Moreover, the Securities and Futures Commission has established a relatively complete licensing system for virtual asset service providers (VASP) and virtual asset trading platforms (VATP), and is preparing to release the second virtual asset policy declaration to further clarify the regulatory attitude and basic principles regarding the combination of virtual assets and real assets. Under this institutional framework, tokenization projects involving real assets, especially RWA, have been included in a higher level of compliance regulatory scope.

From the perspective of RWA projects that have been implemented in Hong Kong and have certain market influence, most projects possess clear securities attributes. This means that the tokens issued involve ownership, income rights, or other transferable rights of real assets, which can constitute "securities" as defined under the Securities and Futures Ordinance. Therefore, these types of projects must be issued and circulated through the method of Security Token Offering (STO) in order to obtain regulatory approval and achieve compliant market participation.

In summary, Hong Kong's regulatory positioning on RWA has become relatively clear: any real assets with securities attributes that are mapped on the chain should be included in the STO regulatory framework. Therefore, we believe that the RWA development path currently promoted by Hong Kong is essentially a specific application and practice of the securities tokenization (STO) path.

Third Layer: Clear Regulatory Framework for Encryption-Friendly Areas

In regions with an open attitude towards virtual assets and relatively mature regulatory mechanisms, such as the United States, Singapore, and certain European countries, a more systematic compliance path has been established for the issuance, trading, and custody of encryption assets and their mapping to real-world assets. RWA projects in such regions can be considered compliant RWAs operating under a clear regulatory framework if they can legally obtain the necessary licenses and comply with information disclosure and asset compliance requirements.

Layer Four: "Comprehensive Compliance"

This is the most broadly defined compliance in contrast to "non-compliance," specifically referring to RWA projects in certain offshore jurisdictions where the government temporarily adopts a "laissez-faire" attitude towards the virtual asset market, and has not explicitly deemed it as non-compliant or illegal. Its business model has a certain level of compliance space within the local legal framework. Although the scope and concept of this compliance are somewhat vague, and do not yet constitute complete legal confirmation, it falls under the business status of "what is not prohibited by law may be done" before legal regulations become clear.

In reality, we can observe that the vast majority of RWA projects find it difficult to achieve the first two types of compliance. Most projects choose to attempt the first three paths—namely, relying on the lenient policies of certain encryption "friendly" jurisdictions to try to bypass sovereign regulatory boundaries and achieve formal "compliance" at a lower cost.

As a result, RWA projects are seemingly "popping up like dumplings", but the time for generating substantial financial value has not yet arrived. The fundamental turning point will depend on whether Hong Kong can clearly explore the secondary market mechanism for RWA—especially how to open up the cross-border flow of capital. If RWA trading remains confined to a closed market aimed at local retail investors in Hong Kong, asset liquidity and the scale of funds will be extremely limited. To achieve a breakthrough, global investors must be allowed to invest in Chinese-related assets through compliant mechanisms, indirectly "buying the dip in China" in the form of RWA.

Hong Kong's role here can be compared to the significance of Nasdaq for global tech stocks back in the day. Once the regulatory mechanism matures and the market structure becomes clear, when Chinese people want to "go overseas" to seek financing and foreigners want to "buy the dip" in Chinese assets, the first stop will definitely be Hong Kong. This will not only be a regional policy dividend but also a new starting point for the reconstruction of financial infrastructure and capital market logic.

In summary, we believe that the compliance of RWA projects should be done within the current framework. All projects must maintain sensitivity to policies, and any legal adjustments must be urgently addressed. Given the current regulatory environment is not yet fully clarified and the RWA ecosystem is still in the exploratory stage, we strongly recommend that all project parties actively engage in "self-compliance" efforts. Although this means investing more resources and bearing higher time and compliance costs at the early stages of the project, in the long run, this will significantly reduce systemic risks in legal, operational, and even investor relations aspects.

Among all potential risks, the fundraising risk is undoubtedly the most lethal hidden danger for RWA. Once a project design is deemed illegal fundraising, it will face significant legal consequences regardless of whether the assets are real or the technology is advanced, posing a direct threat to the project's survival and delivering a heavy blow to the assets and reputation of the enterprise. During the development of RWA, there will inevitably be differences in the definition of compliance across different regions and regulatory environments. For developers and institutions, it is essential to develop a detailed phased compliance strategy that combines their own business type, asset characteristics, and the regulatory policies of the target market. Only under the premise of ensuring controllable risks can the RWA project be steadily advanced.

3. Lawyer's advice on RWA projects****

In summary, as a legal team, we systematically outline the core aspects that need to be focused on from a compliance perspective during the full-chain advancement of the RWA project.

1. Choose a policy-friendly jurisdiction

Under the current global regulatory landscape, the compliance advancement of RWA projects should prioritize jurisdictions with clear policies, mature regulatory systems, and an open attitude towards virtual assets, which can effectively reduce compliance uncertainty.

2. The underlying assets must have real redeemable capabilities

Regardless of how complex the technical architecture is, the essence of RWA projects is to map the rights of real-world assets onto the blockchain. Therefore, the authenticity of the underlying assets, the reasonableness of valuation, and the executability of the redemption mechanism are all core factors that determine the project's credibility and market acceptance.

3. Obtain investor recognition

The core of RWA lies in asset mapping and rights confirmation. Therefore, whether the final buyer or user of off-chain assets recognizes the rights represented by the on-chain tokens is the key to the project's success or failure. This involves not only the individual willingness of investors but also closely relates to the legal attributes of the tokens and the clarity of rights.

While RWA project parties are promoting compliance processes, they must also confront another core issue: investors must be informed. In reality, many projects package risks with complex structures, failing to clearly disclose the status of underlying assets or the logic of token models, leading investors to participate without a full understanding. Once fluctuations or risk events occur, it not only triggers a crisis of market trust but may also attract regulatory attention, making the situation even harder to manage.

Therefore, establishing a clear investor screening and education mechanism is crucial. RWA projects should not be open to all groups, but should consciously introduce mature investors with a certain risk tolerance and financial understanding. In the early stages of the project, it is particularly important to set certain thresholds, such as a professional investor certification mechanism, participation limit restrictions, and risk disclosure briefings, to ensure that entrants are "informed and voluntary" and truly understand the asset logic, compliance boundaries, and market liquidity risks behind the project.

4. Ensure that the institutional operators in the chain comply with regulations

In the entire process of RWA, it often involves multiple links such as fundraising, custody, valuation, tax processing, and cross-border compliance. Each link corresponds to regulatory agencies and compliance requirements in the real world, and project parties need to complete compliance declarations and regulatory connections within the relevant legal framework to reduce legal risks. For example, in the part involving fundraising, special attention should be paid to whether it triggers compliance obligations related to securities issuance, anti-money laundering, and so on.

5. Preventing Post-Compliance Risks

Compliance is not a one-time action. After the implementation of RWA projects, it is necessary to continuously face changes in the dynamic regulatory environment. Preventing potential administrative investigations or compliance liabilities in a retrospective manner is an important guarantee for the sustainable development of the project. It is recommended that project parties establish a professional compliance team and maintain a communication mechanism with regulatory agencies.

6. Brand Reputation Management

In the highly sensitive virtual asset industry regarding information dissemination, RWA projects also need to pay attention to public opinion management and market communication strategies. Building a transparent, trustworthy, and professional project image helps to enhance public and regulatory trust, creating a favorable external environment for long-term development.

4. Conclusion

In the current process of the integration of virtual assets and the real economy, various RWA projects have different intentions and mechanisms, involving both technological innovation and financial experimentation. The capabilities, expertise, and practical paths of different projects vary greatly, making it worthwhile for us to study and classify them one by one.

Through extensive research and project participation, we have also deeply realized that for market participants, the biggest challenge often does not lie in the technical aspect, but in the uncertainty of the system, especially the unstable factors in administrative and judicial practices. Therefore, what we need more is to explore the "practical standards"—even if we do not have legislative and regulatory authority, promoting the formation of industry standardization and compliance in practice is still valuable. As long as there are more participants, mature pathways, and regulatory agencies establish sufficient management experience, the system will gradually improve. Within the framework of the rule of law, fostering cognitive consensus through practice and promoting institutional evolution through consensus is, for society, a kind of "bottom-up" positive institutional evolution.

However, we must also keep compliance as a constant alert. Respecting the existing judicial and regulatory frameworks is the fundamental premise for all innovative actions. Regardless of how the industry develops or how technology evolves, the law remains the baseline logic for ensuring market order and public interest.

Special statement: This represents the personal opinion of the author of this article and does not constitute legal advice or opinions on specific matters.