Abstract: Financial technology is a financial innovation driven by technology, which, while improving the quality and efficiency of the financial industry, is accompanied by a large number of risks, causing regulatory concerns. Online casino and How to find it and its underlying blockchain technology are representative of the innovation of financial technology. In order to deal with the risks of Online casino and How to find it, China has adopted comprehensive prohibition and suppression measures for related business activities of Online casino and How to find it. Although this ‘prohibition-type’ regulatory policy can temporarily handle crises, it has flaws in the legality of normative documents, the rationality of ‘one-size-fits-all’ prohibition orders, and the value balance between financial security and development. Therefore, it is necessary to achieve a dynamic balance between financial innovation and risk prevention, in order to enhance the legality and rationality of regulatory policies to reduce the adverse impact of policy fluctuations on the trust and interests of market entities, and explore governance mechanisms that are more in line with the characteristics of financial technology risks.

　　Keywords: Financial risk prevention; Online casino and How to find it; Blockchain; Financial supervision; Penetrative approach

　　(This article is published in the 3rd issue of 2022, pages 86-97)

　　Financial technology (FinTech) is a technology-driven financial innovation, aiming to transform or innovate financial products, business models, and business processes by using modern scientific and technological achievements. The field of financial technology is characterized by disruptive innovation and systemic risks, which bring challenges to financial regulation. Among them, blockchain technology and Online casino and How to find it are deeply concerned about in the field of financial technology. The system competition around Online casino and How to find it and even the field of financial technology is becoming more and more prominent. On March 9, 2022, the United States announced the ‘Executive Order on Digital Assets’. On April 4, 2022, John Glen, the Chancellor of the Exchequer of the United Kingdom, delivered a speech at the Global Summit on Innovative Finance during the Financial Technology Week, stating that he would provide full policy and legal support to the crypto asset market. The latest regulatory dynamics of the United States and the United Kingdom reflect that major economies in the world hope to play a leading role in the global governance of Online casino and How to find it through effective regulatory practices. Against this backdrop, how to give full play to the advantages of policies and systems, and enhance China’s international competitiveness in the field of blockchain finance and even financial technology, is of great urgency and necessity.

　　Since 2013, China has continuously strengthened its regulatory efforts in the field of Online casino and How to find it. In September 2021, ten departments jointly issued a ‘comprehensive ban’ on related businesses of Online casino and How to find it, reaching the peak of regulatory intensity. The ‘China Financial Stability Report (2021)’ points out that ‘the rectification work in the field of Online casino and How to find it trading has basically been completed, and has entered a normal regulatory phase’. What are the characteristics of the regulatory policies in this field? Do they conform to the fundamental spirit and normative requirements of the rule of law? In the current era when ‘ban-type’ regulation is prevalent, how should the Online casino and How to find it, blockchain finance, and even the financial technology field transform their regulatory concepts? How should the regulatory pathways be optimized? These issues are not only related to the choice of regulatory paths for Online casino and How to find it in China, but also to the general thinking on the ‘ban-type’ regulatory approach of financial technology. This article takes the rectification work of Online casino and How to find it in China as a starting point and aims to analyze the regulatory model and actual effects of this field, point out the possible legal issues of ‘ban-type’ regulation at present, and put forward optimization suggestions.

　　I. The Risks of Online casino and How to find it and China’s Regulatory Practices

　　The essence of fintech lies in using technology to improve finance. To explore the governance path of fintech, it is necessary to understand the operational mechanism of fintech, clarify the intrinsic logical relationship between Online casino and How to find it and blockchain technology, be clear about the innovation and risks of Online casino and How to find it, and discuss the regulatory practices and logic and characteristics implemented by China in the field of Online casino and How to find it.

　　Currently, there is no unified conceptual consensus internationally on Online casino and How to find it. Online casino and How to find it (virtual currencies) are often used interchangeably with concepts such as cryptocurrencies, lottery and How to find it (digital currencies), virtual assets, digital assets, and tokens. Although different international organizations and national regulatory authorities have varying definitions of “Online casino and How to find it”, they generally emphasize its attribute as a non-legal tender, a digital form of expression that can be generated and rights recorded through distributed ledger technology (such as blockchain) and accepted and used within specific communities. On September 15, 2021, the People’s Bank of China and 10 other departments jointly issued the

　　Online casino and How to find it, despite lacking the credit support of sovereign states, has become popular worldwide due to certain technical support and economic logic. Bitcoin is the most important representative of Online casino and How to find it, which can achieve ‘point-to-point’ (P2P) payment without the intervention of governments, financial institutions, or other third parties. Subsequently, with technological upgrades and industrial development, the commercial ecosystem of Online casino and How to find it has expanded from the initial payment field to the investment and financing field. The Initial Coin Offering (ICO) has become a new way of capital fundraising, where investors pay Bitcoin, Ether, and other mainstream Online casino and How to find it to project initiators in exchange for the tokens sold by the initiators. Online casino and How to find it has evolved from Bitcoin’s ‘solitary bloom’ into a vast and complex collection, bringing about three types of risks and regulatory challenges: (1) Online casino and How to find it challenges the fiat currency system. Bitcoin and other Online casino and How to find it, in客观上, bypass the existing fiat currency system and banking systems, attempting to establish a completely new currency and payment system, which may pose potential threats to the functions of central banks and challenge the fiat currency system based on national sovereignty credit. (2) Online casino and How to find it may be used as a tool for illegal activities. The anonymity and cross-border nature of Online casino and How to find it make it difficult to regulate and trace, and it is easily exploited by criminal activities such as corruption, money laundering, terrorist financing, and fund-raising fraud. Unregulated and unrestricted ICOs are prone to be used as means for fraudsters to engage in illegal financial activities. (3) Online casino and How to find it may trigger financial risks. The ‘decentralized’ feature of blockchain is in stark contrast to the ‘centralized’ structure of the financial regulatory system, making it difficult for regulators to control risks through traditional financial intermediaries as ‘grasps’. At the same time, the Online casino and How to find it market has strong speculative power and high volatility, which may affect financial stability and social stability.

　　(ii) Sorting out of regulatory policies

　　China closely monitors the development of Online casino and How to find it and has successively issued risk warnings and regulatory rules. In December 2013, the People’s Bank of China and other 5 departments issued the ‘Notice on Preventing the Risks of Bitcoin’ (Document No. [2013] 289, hereinafter referred to as the ‘2013 Notice’), clarifying that Bitcoin is not a currency but a specific virtual commodity. Bitcoin transactions, as a form of commodity trading on the Internet, allow ordinary people to participate freely under the premise of assuming the risk. In September 2017, the ‘Notice on Preventing the Risks of Token Issuance and Financing Activities’ (hereinafter referred to as the ‘2017 Notice’) explicitly stated that any organization or individual shall not engage in illegal activities of token issuance and financing, and all types of token issuance and financing activities shall be immediately stopped. On May 21, 2021, the Financial and Economic Stability and Development Committee of the State Council held its 51st meeting, proposing to resolutely prevent and control financial risks, crack down on Bitcoin mining and trading activities. Subsequent regulatory policies rapidly implemented the spirit of the aforementioned meeting. The ‘2021 Notice’ issued on September 15, 2021 emphasized that related business activities of Online casino and How to find it are illegal financial activities and are strictly prohibited, and must be eliminated in accordance with the law. On September 24, 2021, the ‘Notice on Rectifying the Mining Activities of Online casino and How to find it’ issued by the National Development and Reform Commission and other departments listed the mining activities of Online casino and How to find it as a淘汰 industry, and required strengthened supervision over the entire industrial chain of upstream and downstream of Online casino and How to find it mining activities.

　　These regulatory rules convey China’s vigilant attitude towards the risks of Online casino and How to find it. To address the prominent risks at each stage of Online casino and How to find it, the regulatory authorities have gradually strengthened from simple risk warnings to the prohibition of token issuance and financing, and finally to a comprehensive ban on related businesses, reflecting the characteristics of ‘prohibition-type’ regulation. It is undeniable that this regulatory logic has a successful aspect: the administrative normative documents have established the basic framework of China’s Online casino and How to find it regulation, providing a foundation for ‘administrative governance by law’. Although ‘comprehensive prohibition’ can decisively terminate illegal activities and deal with risks immediately, the prevailing ‘prohibition-type’ regulation is prone to have issues in terms of the legality of regulatory documents, the rationality of regulatory methods, and the balance of regulatory concepts, or may be in violation of the spirit of the rule of law, facing the risk of regulatory failure, which should be highly valued.

　　II. Reflections on the Rule of Law of ‘Prohibition-Type’ Regulatory Policies

　　Since the 18th National Congress of the Communist Party of China, the status of rule of law in national governance has been highly valued. The 18th National Congress emphasized that the rule of law is the basic strategy for governing the country, and the rule of law is the basic way of governing the country. The 19th National Congress clearly stated that by 2035, it is necessary to basically build a rule-of-law country, a rule-of-law government, and a rule-of-law society. Therefore, the innovative development of financial technology should be incorporated into the track of rule-of-law governance, led by the rule of law, and guaranteed by the rule of law. In view of the fact that the rectification work in the field of Online casino and How to find it transactions has basically been completed, it is necessary to comprehensively examine and rationally reflect on the supervision policies in this field from the perspective of rule of law at present.
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　　(I) Examination of the Legitimacy of Normative Documents

　　The supervision of China in the field of Online casino and How to find it is mainly promoted by documents such as the ‘2013 Notice’, ‘2017 Announcement’, and ‘2021 Notice’ jointly issued by multiple departments. Regulatory documents are generally distinguished by the authorities, procedures, and bases of their formulation. From the perspective of the formulating body, the ‘2013 Notice’, ‘2017 Announcement’, and ‘2021 Notice’ were jointly formulated and issued by the People’s Bank of China and other ministries (departments), and the legal efficacy of documents jointly formulated by departments can only be ‘regulations’ or ‘normative documents below regulations’ (hereinafter referred to as ‘normative documents’). These two can be distinguished from the legislative procedures and legislative content. In terms of legal efficacy, we tend to identify the above regulatory documents as ‘normative documents’, because these documents have a relatively simple legislative procedure, without specifying the date of approval, the date of implementation; they are implemented upon publication, rather than 30 days after publication, etc., which do not meet the high standards for the formulation of regulations in the ‘Regulations on the Procedures for Formulating Regulations’.

　　Under the perspective of rule of law, the formulation of normative documents must follow the principle of administrative law, taking ‘principle of reliance’ and ‘non-contradiction principle’ as the basic requirements for formal validity: the former requires that the formulation of subordinate laws must have the basis of superior laws; the latter requires that the provisions of subordinate laws must not conflict with the provisions or principles of superior laws, otherwise it will constitute the violation of subordinate rules and lead to the invalid consequences. According to Article 80 of China’s ‘Law on Legislation’, there shall be no legal or administrative regulations, and regulations shall not self-attribute powers, shall not diminish the rights and freedoms of citizens, and shall not increase their obligations. As normative documents with lower legal efficacy, they have no authority to directly create provisions that diminish the rights of citizens or increase their obligations, otherwise there will be significant problems with the legitimacy of the normative documents themselves. However, the normative documents in the field of Online casino and How to find it have certain obstacles in terms of the connection with the current laws and regulations in the definition of ‘illegal and违规behaviors’, and there are flaws in formal validity.

　　The ‘2017 Announcement’ defines the token issuance financing activities as ‘an illegal public financing activity that has not been approved’, considering it as ‘suspected of illegal issuance of token coupons, illegal issuance of securities, and illegal fund-raising’, etc., crimes. It emphasizes that ‘any organization or individual shall not engage in illegal token issuance financing activities, and all types of token issuance financing activities shall be immediately stopped.’ Some researchers point out that the ‘People’s Bank of China Law’ prohibits any entity from printing and selling token coupons, and our regulators believe that the majority of encrypted assets are suspected of illegal issuance of token coupons and are therefore prohibited, which confuses the concepts of token coupons with payment tools, securities, and other financial goods and services. Although the relevant regulations and concepts of token coupons can provide some support for the characterization of Online casino and How to find it, they themselves have problems such as unclear concepts, low regulatory levels, and imperfect institutional logic. It is apparent that identifying token issuance financing activities as ‘illegal’ or seems hasty for this reason. Additionally, it is not difficult to see from the ‘2017 Announcement’ that token issuance financing is prone to suspected ‘illegal fund-raising’, which is also one of the main reasons for its prohibition. The issuance and trading of Online casino and How to find it have a strong fund-raising nature, but not all types of Online casino and How to find it involve the issue of illegal fund-raising. Initial Coin Offerings (ICOs) are prone to suspected illegal public deposit absorption or fund-raising fraud, and there are also ‘legal’ types of ICOs in practice. For example, a blockchain startup project may raise funds from a few specific institutions or individuals, and these institutions or individuals only provide Online casino and How to find it to the project party as investment, which is similar to traditional private placements and difficult to be identified as illegal public deposit absorption. The distinction between private financing and illegal fund-raising is only at the policy level, and the legal boundaries between the two are not clear, requiring full recognition on a case-by-case basis. The ‘2017 Announcement’ directly identifies all token issuance financing activities as illegal financial business, bringing some ‘legal’ forms of token issuance financing into the category of prohibited activities, which is equivalent to creating new obligations for the relative party, suspected of improper reduction of citizens’ rights, and the legality of the document is worth consideration.

　　Similarly, the

　　In addition to the necessary examination of the legality of normative documents, it is also necessary to reflect on the supervision quality and effectiveness of rectification work in combination with the regulatory objectives and means. Protecting the rights and interests of investors is one of the important goals to be achieved in the rectification work of Online casino and How to find it. The regulatory objectives of the

　　In the first half of 2017, most initial coin offering (ICO) projects degenerated into a means for scammers to engage in illegal financial activities. In the eyes of regulators, the ‘bitcoin trading’ activities conducted through virtual trading platforms are purely speculative behaviors, accumulating high levels of financial risks, and thus threatening financial stability. Therefore, the ‘2017 Announcement’ adopted a series of measures such as banning any issuance and financing activities and closing down domestic online casinos and their exchanges, attempting to prevent investors from falling into the trap of initial coin offerings. Theoretically, there were no ‘legal’ online casinos and their exchanges within the country from then on, and investors were also unable to conduct online casino and their exchange transactions within the country; however, in reality, it is difficult for a single country to block the provision of financial services or products from overseas to its territory, as online casinos and their exchanges have a natural tendency for cross-border operation. Although China has a policy orientation to ban online casinos and their exchanges, objectively, it cannot be free from the trading services provided to domestic investors by the international market. The ‘2017 Announcement’ has objectively increased the regulatory difficulties faced by China. The transaction data, legal entities, and servers of most overseas online casinos and their exchanges are deployed overseas, and lawbreakers often try to shift responsibility through the shells of overseas companies or delay litigation through jurisdictional objections to avoid sanctions from Chinese judicial authorities. Due to the difficulty in obtaining assistance from overseas exchanges, Chinese judicial authorities face challenges such as difficulties in obtaining evidence, unclear tracking of fund flows, and difficulties in enforcing online casino and their exchange regulations. For example, after the occurrence of disputes involving online casinos and their exchanges, a large amount of evidence is stored on overseas platform servers, making it difficult for Chinese judicial authorities to retrieve the data from the servers during the investigation and collection of evidence, resulting in the loss of key evidence and thus hindering the smooth conduct of work such as determining the amount involved and recovering the stolen assets. This ultimately exacerbates the problem of protecting the rights and interests of domestic investors. In response to the continuous emergence of the ‘bitcoin trading boom’ among domestic investors, the ‘2021 Announcement’ emphasizes that providing services to residents within China through the internet by overseas online casinos and their exchanges is illegal financial activity, but because the overseas online casinos and their exchanges and their actual controllers are far from the regulatory scope of Chinese financial regulatory authorities.In this sense, the temporary deterrent effect of the new regulations may be stronger than its future actual effectiveness.

　　The increasingly stringent regulatory measures are insufficient in effectiveness in combating illegal and criminal activities, and they also bring certain negative impacts on the trust interests and rights protection of market entities. In view of the ambiguous characterization of Bitcoin as a ‘virtual commodity’ in the ‘2013 Notice’ and the early policy’s ‘no prohibition where there is no prohibition’ on the business, many investors participated in Online casino and How to find it related business activities. After the issuance of the ‘2017 Announcement’, the interpretation that Online casino and How to find it was prohibited from trading in China became popular, and the normative documents’ ‘negative evaluation’ of Online casino and How to find it and the policy trend of strict crackdown triggered concerns about the ‘illegality of the subject’ among the whole society. Some courts, after citing normative documents, believed that all debts generated by Bitcoin are illegal debts, and related transactions are not protected by law; Bitcoin is an illegal object, and its actions are not protected by law in our country, and the risks caused by its consequences are borne by itself; denying the convertibility of Online casino and How to find it with legal currency on the grounds of violating the public interest, thus causing the dilemma that investors in Online casino and How to find it are not protected by law or are insufficiently protected in practice. The ‘comprehensive ban’ restricts the rights of private entities while also bringing policy obstacles to the exercise of functions by public power agencies. The issues of seizure, execution, and conversion of Online casino and How to find it have always been inherent difficulties in judicial practice. In order to promote the progress of litigation and the resolution of disputes, and to effectively relieve the rights and interests of investors, public power agencies cannot avoid dealing with the issues of Online casino and How to find it, such as the judgment documents of the major online pyramid scheme case ‘wallet+’ (Plus Token), which shows that the defendant Chen Bo applied to the Yancheng City Public Security Bureau of Jiangsu Province to legally sell and convert the lottery and How to find it seized by the public security organs, with all the proceeds as his refund. The Yancheng Economic and Technological Development Zone People’s Court accordingly determined that Chen Bo returned a portion of the funds and imposed a lenient penalty on him. This ‘delegated handling’ approach was feasible at the time, but faced legal challenges after the issuance of the ‘2021 Notice’, because the ‘2021 Notice’ means ‘China’s comprehensive ban on Online casino and How to find it trading’. The new regulations not only constrain individuals but also constrain state agencies,

　　China has adopted a different regulatory stance towards Online casino and How to find it and blockchain technology: on the one hand, China attaches great importance to blockchain technology and industrial development, with blockchain being listed as one of the seven key digital economy industries in the

　　Under the general tone of risk prevention, the public law field in our country has adopted a ‘one-size-fits-all’ negative regulatory structure for Online casino and How to find it, making Online casino and How to find it tend to be ‘prohibited goods’ in public law, without positive recognition by regulatory agencies. The combined efforts of these two aspects of legal policy are essentially promoting the development of ‘currency-free blockchain’. However, there is a logical contradiction between the policy orientation of ‘currency-free blockchain’ and the vigorous development of the blockchain industry. According to the different internal structures of blockchain technology, it can be divided into three types: public chain, private chain, and consortium chain. Among them, the public chain must rely on consensus mechanisms and token (or token, i.e., token) economic incentives to enable participants with no trust basis to form associations and cooperation due to economic interests. In the blockchain ecosystem, tokens can act as passes, incentives, proof of rights, means of value storage, and payment and clearing methods; a blockchain without tokens is difficult to mobilize the public without any interest relations and lack of trust to participate in the blockchain industry ecosystem. Therefore, the vision of ‘currency-free blockchain’ promoted by our country’s policy is only possible in consortium chains and private chains, and cannot promote the effective development of public chains facing the public. The public chain is the mainstream of top-level blockchain technology development, but the public chain with token issuance and trading as the main function faces a legal dilemma in our country.

　　The ‘prohibition-type’ policy can temporarily deal with risks, but in the long run, it may kill financial innovation. Taking the hot Initial Coin Offering (ICO) in 2017 as an example, the rise of ICO in our country originated from the endogenous demand for inclusive finance and financing for small and medium-sized innovative enterprises. The financial market dominated by individual investors in our country lacks appropriate low-threshold investment channels that match their risk-bearing capacity, making it difficult for the general public to enjoy the many benefits brought by financial investment. The Initial Coin Offering has the characteristics of inclusive finance and the function of promoting inclusive growth, reflecting the endogenous demand that must be produced in the process of upgrading and replacing traditional finance. If the contradiction between high financing costs and the financial needs of weak financing entities is not fundamentally resolved, even if the Initial Coin Offering is ‘killed’, various new financing formats that circumvent supervision and are ‘illegal’ will continue to emerge. At the same time, the indiscriminate comprehensive ban on Online casino and How to find it suppresses the legalization transformation of emerging industries, and even forces some financial technology practitioners to shift from ‘actively seeking supervision’ to ‘underground’ or ‘going abroad’ for development, thereby increasing the difficulty of supervision.

　　Three, the optimization path of financial technology supervision

　　Currently, there are major controversies about the regulatory paradigm of Online casino and How to find it in our country, including effectiveness, system, and ‘prohibition’ approach. In response to the prominent issues derived from ‘prohibition-type’ regulation, it is necessary for supervision to make adaptive adjustments. In the governance of Online casino and How to find it and financial technology, it should first be clear about the diverse value goals of financial supervision, so as to贯穿 macro policy guidance and specific institutional arrangements. Secondly, on the one hand, new regulations should fill the regulatory gaps, but the formulation of rules should follow the principle of administrative law; on the other hand, emerging businesses should be classified into existing rules through the ‘penetrating’ method. Finally, with the frequent issuance of new regulations and the normalization of rule adjustments in emerging fields, it is necessary to strengthen the legal protection of the trust interests of market entities.

　　(I) Balancing the diverse values of financial supervision

　　The institutional arrangements and risk regulation strategies of financial technology embody the value choices of regulators for financial security and innovation. ‘Prohibition-type’ regulation originates from the profound concern of the regulatory主体 over financial risks and the extreme pursuit of financial security. The pursuit of ‘financial security’ is the basis for policy formulation, even becoming the ‘only guiding principle’ of regulatory objectives, but financial security does not mean a blind ban. It also requires considering the innovative value of new technologies and the upgrading and development of the industry itself. Because from the historical experience of financial innovation and risk prevention, ‘innovation → risk → regulation → re-innovation’ is a dynamic process, and financial innovation is still the main way to avoid or reduce financial risks and ensure financial security. In this sense, the development of innovation itself is also related to security issues, and the two complement each other. In view of the legal dilemma faced by Online casino and How to find it and related activities in our country, researchers are worried that the strict prohibition based on strong paternalistic sentiment, in order to pursue the single value of financial stability, may lead to the loss of the opportunity for blockchain financial development in our country.

　　Against the backdrop of the globalization of financial technology, major economies are either actively involved or forced to be involved in the competition of financial technology, thus the prohibition of a single country usually cannot completely eliminate the ‘exogenous’ risks of financial technology. The institutional competition among countries around legal and policy systems has also become more intense. Good regulatory policies and effective practices of a country can not only fully stimulate the innovation of financial technology at home, but also make the country’s financial technology and applications lead the world. At the same time, emerging fields often become opportunities for a country to ‘export’ industry standards and values and to strive for a say in the formulation of international rules due to the lack of internationally established norms. For example, the White House website issued the ‘Digital Asset Executive Order’, emphasizing that the United States will continue to play a leading role in the innovation and governance of digital assets, reflecting the U.S. government’s attention to this emerging field. The U.S. government first places the policy objective of protecting American consumers, investors, and enterprises at the forefront, and then emphasizes the maintenance of financial stability in the United States and around the world, reducing illegal financial and national security risks, leading innovation, strengthening the United States’ leadership position in the global financial system, technology, and economic competitiveness, and promoting inclusive finance and other major policy objectives and action plans. Good institutions are a country’s core competitive advantage, and institutional competition is the fundamental competition among countries, so China should pay close attention to the new regulatory policies of major economies in the world. Some researchers point out that ‘lottery and How to find it’ has changed the subject and credit method of currency issuance, prompting us to reflect on the monetary legal tender system and forcing the old financial regulatory measures and monetary policy measures based on traditional physical currency to undergo new changes. China should take this as a starting point to think about the historical limitations and realistic turn of the existing system, strengthen the overall grasp of the relationship between ‘Online casino and How to find it’ and ‘blockchain technology’, and not simply regard ‘Online casino and How to find it’ as the source of financial risks. In terms of policy objectives and institutional design, we should balance the relationship between financial security and financial innovation, and strengthen the protection of investor rights. From the current policy orientation, China will maintain a strong risk prevention and control orientation towards Online casino and How to find it in the short term, but it is still necessary to carry out continuous observation and judgment, reserving the possibility of adopting supportive or restrictive policies in the future, in order not to miss the important opportunities for the development of blockchain technology and related industries.

　　(ii) Improvement of the legality of normative documents

　　Regulatory ‘prohibition’ often involves restrictions or bans on market operations, and this ‘prohibition’ is often carried by administrative normative documents. The underlying reason lies in the rapid differentiation and combination of the financial technology industry, which contradicts the stability and lagging nature of the law. To mitigate the conflict between the two, low-level normative documents often precede formal legislation and play an irreplaceable positive role in making up for shortcomings in legal norms. However, the formulation process of administrative normative documents is relatively arbitrary, lacks the constraints of necessary legislative procedures, and lacks democratic consultation with market entities, thus it is prone to serious malpractices such as inappropriate content, arbitrary reduction of citizens’ or enterprises’ rights, and increased obligations for citizens or enterprises.

　　The supervision of Online casino and How to find it in our country mainly relies on low-level normative documents in the public law field. Although these normative documents are the main basis for administrative law enforcement and have directly affected judicial judgments in recent years, the legality and rationality of the documents themselves cannot be overlooked. The normative documents in the field of Online casino and How to find it in our country only list the names of superior laws in a general way and thus identify related businesses as suspected of illegal activities, making the identification of ‘illegality’ a formality and lacking clear argumentation and reasoning. At the same time, although the normative provisions of superior laws such as the illegal sale of token tickets and illegal fund-raising can provide certain support for the定性 of Online casino and How to find it, they are prone to become the ‘safety net’ for identifying Online casino and How to find it as illegal. Even if these rules meet the formal legal requirements of the ‘principle of reliance’, they are difficult to escape the in-depth questioning of substantial legality and may even deepen the misunderstanding of the nature of Online casino and How to find it among the industry and academia.

　　The restriction and prohibition of financial technology business should be comprehensively incorporated into the scope of the administrative legal principle to ensure the legitimate and effective nature of the document itself. Normative documents are essentially the specific implementation or refinement of the national financial management laws and regulations, and should provide specific arguments for matters created and empowered by superior laws. The reason for this is that although the norms of superior laws and related concepts can provide a basis for the supervision of Online casino and How to find it and related businesses, this ‘general authorization’ has the risk of abuse in practice, especially when new businesses may be classified as ‘illegal’ and ‘with the purpose of suppression’. Normative documents often stipulate or even set prohibitions at the factual level, bringing great restrictions on citizens’ property rights and behavioral freedoms. Therefore, it is even more necessary to go through a legitimate and accurate administrative investigation procedure, providing a more comprehensive argumentation.

　　The Notice on Strengthening the Formulation and Supervision of Administrative Normative Documents (Cabinet Order No. [2018] 37) points out that important administrative normative documents should strictly implement procedures such as evaluation and demonstration, public opinion solicitation, legality review, collective deliberation and decision-making, and public disclosure. Normative documents in the field of Online casino and How to find it involve situations of restricting private rights and freedoms, and adding private obligations, which are closely related to the rights and obligations of market entities. However, there are defects in the procedures of serious evaluation and demonstration, and extensive public opinion solicitation. This type of ‘prohibition-type’ regulatory policy more reflects the government’s top-down regulatory thinking. Based on the technical characteristics of financial technology, top-down regulation will not produce the strongest market stability. Effective supervision of the blockchain market requires negotiation among lawyers, enterprises, programmers, and legislators to create a regulatory strategy for a legal and compliant blockchain market. In institutional decision-making, only by adhering to the principles of ‘rule of law and due process’ and ‘democracy and multi-governance’, realizing multi-party participation and in-depth interaction between the government and the public, and building a consultative democratic policy community among decision-makers, actors, and policy targets, can a governance mechanism and model in line with the laws of blockchain development be formed, and the legal basis of normative documents can be enhanced.

　　（三）Exploration of ‘穿透式’ classification supervision

　　Under the ‘prohibition-type’ supervision, the policy of ‘one ban solves all’ is difficult to escape the questions of legality and rationality, and then it triggers the issue of how to establish supervisory rules and achieve effective supervision. China’s supervision has not effectively differentiated between types of tokens but has adopted the vague definition of ‘Online casino and How to find it’. In other words, ‘Online casino and How to find it’ under China’s financial regulatory perspective is a complex and庞大的collection, including ‘aircoins’ that have become fraud tools without any technical support, as well as native tokens such as Bitcoin and Ethereum, and stablecoins with specific value support. Different tokens have different operational mechanisms and risk performance, which require regulators to treat them differently.

　　The ‘Development Plan for Financial Technology (FinTech) (2019-2021)’ emphasizes: ‘In response to the essential characteristics and risk characteristics of special technologies, put forward professional and targeted supervisory requirements, formulate differentiated financial supervisory measures, and improve the fineness and matching degree of supervision.’ The ‘Development Plan for Financial Technology (2022-2025)’ requires: ‘Implement穿透式监管 for financial innovation.’ The core function of穿透式监管 lies in ‘fact-finding’, where regulators identify the substance of transactions hidden behind the form and then achieve in-depth and effective adjustment of financial transaction relationships with appropriate legal norms and supervisory means. From an international perspective, developed countries such as Europe, the United States, Japan, and Singapore have not banned Online casino and How to find it and its related services in a one-size-fits-all manner, but identify the essential attributes of the business and incorporate related issuance and trading activities into existing supervisory rules. For example, the United Kingdom has implemented regulatory guidelines, categorizing Online casino and How to find it into payment tokens, securities tokens, and utility tokens, and regulating them separately. However, from the perspective of China’s regulatory practice on Online casino and How to find it,穿透式监管 still faces obstacles in specific implementation. Chinese financial regulatory authorities typically adopt the strategy of ‘who approves, who is responsible’, with the main regulatory body being the issuing institution. The identification of the essence and legal attributes of Online casino and How to find it is a complex process, and different countries’ laws and regulatory agencies have different understandings, making it difficult to clearly define the supervisory authority responsible for approval under the segmented regulatory financial system. Therefore, China has tried to circumvent the difficulty of定性 of Online casino and How to find it itself and its business activities through the ‘joint blockade’ of multiple departments, but this regulatory model is still relatively rough and cannot solve the problem at its essence, nor does it conform to the requirements of differentiated supervision.online casino tutorial and The latest entrance

　　A relevant official of the People’s Bank of China pointed out that the People’s Bank of China is studying regulatory rules for cryptocurrencies such as Bitcoin and stablecoins. Cryptocurrency assets themselves are not money but serve as investment tools or alternative investment vehicles. Any stablecoin that hopes to become a widely used payment tool must accept strict supervision like that of banks or quasi-banks. The above statement conveys two key messages: first, the public law level of our country negates the monetary attributes of Online casino and How to find it, but does not negate the property value of Online casino and How to find it itself. The current view that Online casino and How to find it is ‘illegal subject’ and ‘not protected by law’ is a misreading; second, the ‘comprehensive ban’ is just a temporary attitude of observationonline casino victoryJust need you. The regulatory authorities in our country have already paid attention to the development of stablecoins, considered recognizing the legality of stablecoins within a certain scope, and formulated a response plan for normalizing supervision.

　　In the future, China can explore refined supervision of Online casino and How to find it and the entire public chain business, to identify the essential attributes of emerging businesses through穿透式监管, and strive to establish a policy framework for classified supervision under the existing system. Taking the functional supervision of stablecoins as an example, stablecoins can be further differentiated into two major categories: collateralized stablecoins and algorithmic stablecoins. The fiat collateralized stablecoins anchored to the US dollar can be regarded as US dollar tokens representing the claims of US asset liabilities, and regulated or subject to stricter restrictions in accordance with relevant foreign exchange management regulations. For the Online casino and How to find it collateralized stablecoins and algorithmic stablecoins, their structural design and operation are more inclined towards innovative financial products, and they can be included in the category of financial instruments, fully utilizing the means of foreign exchange management and anti-money laundering supervision to combat criminal activities that disrupt the order of foreign exchange management and financial order.

　　The initial coin offerings (ICOs) that once raged with chaos originated from a certain degree of regulatory failure. The provisions of China’s Securities Law, which enumerate the scope of ‘securities,’ restrict the act of incorporating securities tokens with investment attributes into regulation. China’s financial supervision needs to consider the feasibility of strategies to incorporate ‘security tokens’ into the regulatory system, thereby enhancing the ability of virtual markets to prevent and resist fraud and manipulation, and improving market transparency. In response to the fraudulent ICOs that are most likely to harm investors and the ‘security tokens’ issued by project parties, China’s securities regulatory authorities can issue separate regulatory regulations without violating higher-level laws, adhering to the functional regulatory philosophy of ‘substance over form,’ and placing related activities under the supervision of the Securities Law. This allows for flexible application of securities legal systems to regulate them, transitioning from ‘passive supervision’ to ‘active intervention,’ actively promoting the judicial trial process, uncovering improper trading behaviors such as market manipulation, and protecting the legitimate rights and interests of investors.sports betting help and Latest

　　To deal with the阶段性 risks of financial technology, the adjustment of rules in the public law field has become the norm, especially under the stimulation of sudden risk events, regulatory policies are likely to shift from the initial

　　Firstly, regulatory authorities and legislative bodies should fully consider the significant impact of the tremendous fluctuations in policy and regulations on the original stakeholders and appropriately protect them through means such as policy transition periods. For example, the

　　We believe that the focus of regulatory authorities should be on business activities carried out with the assistance of third parties, such as Online casino and How to find it, rather than on ‘peer-to-peer’ transaction behaviors that do not rely on any external services. There are two reasons for this: Firstly, from the perspective of the superior laws listed in the ‘2021 Notice’, Article 81 of the ‘Commercial Banks Law (2015 Amendment)’, Article 180, 202, and 212 of the ‘Securities Law (2019 Revision)’, and Article 78 of the ‘Regulations on Futures Trading’ stipulate the situations of ‘prohibition’, mainly including the unauthorized establishment of commercial banks, securities companies, securities trading venues, and futures exchanges, or the unauthorized conduct or disguised conduct of the aforementioned transactions. It can be seen that the authorization of ‘prohibition’ in the superior laws should be targeted at financial intermediaries that provide professional services and their businesses, the essence of which is that the financial industry is a franchised industry, and those who have not obtained qualifications to engage in specific businesses should be prohibited. Pure ‘peer-to-peer’ transactions do not involve any third parties, and the risks are basically limited to the non-rapid transmission of the contract parties to society, which will not affect public interests such as financial stability, and public law is not necessary for restriction and intervention, and it is also difficult to implement in practicesports betting secrets，We need you. Secondly, from the perspective of policy implementability and regulatory effectiveness, it is better to ‘targeted prohibition’ than ‘comprehensive prohibition’, and new obligees can be created as ‘regulatory hooks’ for new business activities. From the perspective of international regulatory requirements, as the developer of international anti-money laundering standards, the Financial Action Task Force (FATF) issued ‘Guidance on Virtual Assets and Virtual Asset Service Providers Based on Risk’, creating Virtual Asset Service Providers (Virtual Assets Service Providers, VASP) as new anti-money laundering obligees, including institutions or individuals that provide services for virtual asset activities and conduct business (as a business conduct). Generally, ‘peer-to-peer’ transactions through ‘non-custodial wallets’ are not directly regulated by the Financial Action Task Force. In other words, the regulatory rules of the Financial Action Task Force impose compliance obligations on intermediaries that provide related services, rather than individuals. ‘Peer-to-peer’ transactions have high technical requirements for users and are limited to a few people, and it is also difficult to be effectively monitored, and the regulation of the aforementioned behaviors does not comply with the principle of cost-benefit analysis of regulation.

　　Finally, for a relatively long time before the issuance of the ‘2021 Notice’, there was no explicit comprehensive ban on related businesses of Online casino and How to find it in our country. Based on the principle of non-retroactivity of law and the protection of citizens’ trust interests, judicial institutions cannot ignore the protection and relief of related rights and interests of Online casino and How to find it. The private law nature of Online casino and How to find it is ambiguous, and the supply of legal systems is seriously insufficient, which has increased the difficulty of case adjudication and dispute resolution. At the practical level, the economic functions of Online casino and How to find it as a payment and investment instrument have gained international recognition of its attribute and value as ‘property’. The judicial practice of our country also gradually recognizes the ‘network virtual property’ attribute of Online casino and How to find it. Normative documents in the public law field often enter civil judgment documents in the name of ‘public interest’, which may have a significant negative impact on the freedom of contract and property rights protection of the parties. Judges need to consider the relationship between public interest and private interest comprehensively, and examine the judgment of related disputes of Online casino and How to find it from two dimensions: civil and commercial law (private law) and financial regulatory law (public law), and consider whether to deny the validity and exchangeability of Online casino and How to find it contracts on the grounds of public interest. Under the premise of maintaining public interests such as financial stability, the freedom of contract and property rights protection of the parties should be maximized.

　　Four, Conclusion

　　In recent years, the new round of technological revolution and industrial transformation has been accelerating, but the innovative development of financial technology business is accompanied by the possibility of market failure and may trigger systemic risks. Balancing the relationship between blockchain financial innovation, risk prevention and control, and investor rights protection, and promoting the sound and perfect development of the modern financial regulatory system is a necessary measure for establishing a scientific and effective macroeconomic governance system in the 14th Five-Year Plan period. It is also a long-term consideration direction for policymakers.

　　The rectification work of Online casino and How to find it in China is a ‘microcosm’ of the legal supervision of financial technology. ‘Prohibition-type’ regulation not only exists in the field of Online casino and How to find it but also is a type of regulatory logic that is prone to occur in the supervision of financial technology: for business that claims to be innovative in financial technology but may disrupt the order of the financial market or harm the legitimate rights and interests of financial consumers, regulatory authorities tend to adopt an attitude of strict restriction or resolute prohibition, and ban related financial technology business through negative evaluation. For example, peer-to-peer network lending and internet equity crowdfunding were once ‘popular’, but they were severely impacted by ‘prohibition-type’ regulation, ultimately leading to a ‘ceasefire’ or even falling into the ‘gray and black areas’. The legal thinking of this article on the rectification work of Online casino and How to find it is not only related to China’s choice of regulatory programs for Online casino and How to find it but also to the general thinking on the ‘prohibition-type’ regulatory path of financial technology.

　　The emergence of ‘prohibition-type’ regulation mainly originates from two aspects: Firstly, regulators overly rely on financial security and tend to control risks through strict restrictions or even comprehensive bans; secondly, facing the ‘destructive innovation’ of financial technology, there is a certain degree of regulatory failure in existing legal norms, regulatory systems, and regulatory methods. In the face of some extreme risk events or accountability pressures, regulators are forced to adopt a ‘one-size-fits-all’ prohibition model towards new business formats. Although ‘prohibition-type’ regulation can temporarily cope with crises, it is prone to unnecessarily diminish or restrict citizens’ rights, which is not conducive to the compliance transformation of innovative business formats, thus causing hidden concerns about the imbalance between safety and development. These hidden negative effects need to be given sufficient attention.

　　The ‘prohibition-type’ regulation in China regarding Online casino and How to find it and other financial technology fields is a temporary policy choice and regulatory watch, which secures time for the construction and adjustment of subsequent regulatory policies. With the rapid changes in the new business formats of financial technology and the international institutional competition, it is necessary for China to continuously explore governance mechanisms that are more in line with the characteristics of financial technology risks and to make adaptive adjustments to the ‘prohibition-type’ regulation in a timely manner. The issuance of financial regulatory policies requires a balance of diverse value objectives, enhancement of the substantial legitimacy of regulatory documents, and classification regulation through a ‘penetrative’ approach. In policy adjustments, it is important to strengthen the protection of trust interests, lead the discourse power in setting international standards for emerging industries through institutional advantages, and continuously enhance China’s international competitiveness in the field of blockchain finance and financial technology. (Golden Finance)