Galaxy Research Report: What Is Driving Zcash's Apocalypse Rally?

By: blockbeats|2025/11/05 17:30:01

Original Article Title: Why Has Zcash Suddenly Soared?

Original Article Author: Will Owens, Galaxy

Original Article Translation: AididiaoJP, Foresght News

The term "cryptocurrency" literally means "hidden" or "secret" currency. However, throughout most of its development, the issue of privacy has long been overlooked by the industry. It wasn't until recently that the situation began to change.

Over the past few weeks, the privacy narrative has once again taken center stage. As one of the oldest and most well-known privacy coins, Zcash (ZEC) has seen a price surge of over 700% since September, seemingly overnight turning everyone in the industry into a privacy expert. However, some prominent figures in the Bitcoin space have criticized this rally as "manipulative," warning that buyers will ultimately become "bagholders." Economist Lyn Alden has reminded investors not to fall into the trap of "pump and dump."

However, investor Naval Ravikant quickly countered, presenting a fundamental reason for Zcash: "Transparent cryptocurrencies cannot survive under government crackdown."

Galaxy Research Report: What Is Driving Zcash's Apocalypse Rally?

Let's not forget that Bitcoin's anonymous creator, Satoshi Nakamoto, acknowledged the limitations of the Bitcoin network in terms of privacy in the 2008 whitepaper.

While CoinJoin services like Samourai and Wasabi were once popular on Bitcoin, they are now facing increasing regulatory pressure. Samourai was practically shut down due to its founder's arrest, and Wasabi also discontinued its CoinJoin feature and blocked U.S. users in June 2024 due to regulatory concerns.

Payjoin is a simple tool that can break the inference of "multiple inputs owned by one person" and is gradually gaining attention, but it still requires user interaction. The broader problem highlighted by Satoshi Nakamoto in the previous quote is the transparency brought by Bitcoin. Zcash, as a fork of Bitcoin, allows users to use zero-knowledge proofs to shield transactions, directly addressing the privacy limitations mentioned by Satoshi Nakamoto.

Satoshi Nakamoto also acknowledged Bitcoin's privacy limitations in forum posts.

Key Points

· After years of silence, ZEC has surged around 8x in the past month, far outperforming the market as a whole, forcing people to reconsider the importance of "privacy features."

· This discussion has reignited the early Bitcoin debate on "privacy rights" versus "regulatory realities."

· Zcash's market cap has surpassed Monero's.

· Zcash's user experience has improved (e.g., ZecWallet).

· Cross-chain intent channels have lowered the barrier to entry (NEAR Intents).

· Anonymity sets are expanding.

· For the first time, over 30% of ZEC's supply is held in shielded pools.

· However, compared to Bitcoin, Zcash still has very few full nodes.

Development History and Network Upgrades

Zcash originated from academic research in 2013 when cryptographers at Johns Hopkins University developed the Zerocoin protocol. To improve efficiency, this protocol later evolved into Zerocash and was eventually launched in 2016 by cryptopunk Zooko Wilcox and his Electric Coin Company as a Bitcoin fork. Its goal was simple: to retain Bitcoin's monetary properties while addressing its most commonly cited design flaw (also acknowledged by Satoshi Nakamoto himself): the lack of transaction privacy.

Unlike Bitcoin, where all transactions are publicly visible on the chain, Zcash uses a technology called zk-SNARKs. This allows users to prove the validity of transactions without revealing the sender, receiver, and amount. While Monero introduced privacy features earlier and adopted technologies like ring signatures to protect privacy, Zcash was the first mainstream blockchain to implement zk-SNARKs at the protocol level.

Zcash follows an on-chain funding model, allocating a portion of the block rewards to community-led projects rather than specific organizations. Under ZIP 1016, 8% of the block reward goes into the Zcash Community Fund, while 12% goes to a fund managed by holder voting. The Electric Coin Company and the Zcash Foundation do not automatically receive a share; they also have to apply for funding through these mechanisms.

Zcash has undergone multiple network upgrades:

· Sapling (2018): Significantly improved the efficiency of shielded transactions.

· Heartwood (2020): Introduced shielded mining rewards, allowing miners to receive block rewards privately.

· Canopy (2020): Alongside the first halving, completely revamped the funding model, replacing the original Founders’ Reward with a four-year development fund managed jointly by ECC, Zcash Foundation, and community grants.

· NU5 / Orchard (2022): The most significant milestone since launch, replaced the complex trusted setup ceremony with Halo 2 recursive proofs and introduced unified addresses, simplifying privacy operations. The Orchard shielded pool was launched as a result.

· NU6 (2024): Implemented in-protocol funds lockbox, decentralized treasury management, and increased transparency in development fund usage.

Next, the protocol is preparing for the NU7 upgrade.

Market Performance and Current State

For the most part, ZEC has shown poor market performance, not only underperforming against BTC but also overshadowed by Monero. Monero defaults to providing users with basic privacy, but its reliance on a small ring size for mixing transactions has been successfully de-anonymized in some research, as its ring signature design mixes the real input with 15 decoys, creating a moderately-sized anonymity set.

Regulatory bodies often scrutinize Monero more closely due to its default privacy features. In 2020, the IRS even hired companies like Chainalysis to study methods of tracking Monero transactions. In contrast, Zcash achieves optional privacy through zk-SNARKs, allowing full data encryption and providing a larger anonymity set when using shielded addresses.

This dual-mode design also makes users more prone to operational security mistakes (such as misusing transparent addresses), but with proper operation, Zcash's cryptography can offer substantially stronger and mathematically more reliable privacy. Additionally, Zcash’s privacy layer is quantum-resistant, while Monero's current ring signature scheme is not (developers have acknowledged this issue and plan to address it in future upgrades).

Today, just looking at ZEC's price movement tells a completely different story.

ZEC Price Movement Over the Past Year

(Originally a price chart description: ZEC's price over the past year; ZEC vs. XMR price comparison; ZEC/BTC exchange rate daily chart.)

Technical Details

Zcash follows Bitcoin's monetary model: a fixed supply of 21 million ZEC, a proof-of-work consensus, with halvings approximately every four years. It utilizes the Equihash algorithm designed to be more resistant to ASIC centralization compared to Bitcoin's SHA-256. The block time is approximately 75 seconds, around 8 times faster than Bitcoin. Zcash undergoes halvings roughly every four years, with the next one expected in November 2028, at which point the block reward will decrease to 0.78125 ZEC.

Zcash has two types of addresses:

· Transparent addresses: Functionality similar to Bitcoin, where the balance and transactions are publicly visible.

· Shielded addresses: Use zk-SNARKs to hide transaction participants and amounts while proving no coins were minted out of thin air.

When users transact between shielded addresses, the network verifies a cryptographic proof, not transaction details. The proof states, "I have the right to spend these coins, and the computation is correct," without revealing any extra information. The crux of privacy lies in sharing only the minimal information necessary to establish trust.

The larger the shielded pool, the more challenging it is to trace fund flows. This is why the recent milestone of the shielded pool size surpassing 30% of the total supply is significant. The largest shielded pool is Orchard, launched on May 31, 2022, replacing the old pool, using the Halo 2 proof system that requires no trusted setup, and introducing unified addresses for a simplified user experience.

Currently, the Orchard shielded pool holds over 4 million ZEC (approximately 25% of the circulating supply), the vast majority of the total about 4.9 million shielded ZEC.

(Originally a shielded supply chart description: Shielded supply growth.)

The transparent supply has decreased by nearly 3 million ZEC, from around 14 million at the beginning of the year to approximately 11.4 million currently (about 70% of the total supply).

(Original note: Transparency Set Decrease Chart Note: Transparency Set Decrease.)

Nodes and Future Development

The Zcash network currently has around 100-120 full nodes, up from a low of around 60 earlier this year. However, this number is still relatively low compared to Bitcoin (around 24,000) or Monero (around 4,000), mainly due to the resource-intensive nature of running Zcash nodes (shielded transaction validation is more resource-intensive), as well as the multi-pool architecture and frequent network upgrades that add complexity and maintenance costs.

In the future, developer Sean Bowe is advancing the "Tachyon Project," which is an expansion proposal that significantly increases shielded transaction throughput by restructuring sync and storage methods. Bowe claims that Tachyon can achieve a performance leap without a new protocol, using relatively simple cryptographic solutions to address all bottlenecks. It can be said that Tachyon to Zcash is like Firedancer to Solana.

What Are NEAR Intents?

NEAR Intents is a cross-chain coordination layer built on the NEAR Protocol. It allows users to express intent without the need for manual cross-chain bridge operations, exchanges, or wallets.

The intent executor behind the scenes will automatically allocate liquidity, execute exchanges, and complete cross-chain settlements.

For Zcash, integrating Intents means that users can easily move assets from the transparent chain to the Zcash shielded pool and back without exposing each step. This enables traders or institutions to transition from a transparent chain (like Ethereum) to Zcash to restore privacy, conduct shielded transactions, and then, if necessary, return to the original chain, with no direct address correlation.

After Zashi Wallet integrated NEAR Intents (the ECC official wallet, also the most commonly used wallet for Zcash), it abstracted away the technical friction of cross-chain and shielding for users. Zcash also natively supports viewing keys, which can be used for auditing or compliance purposes, selectively disclosing shielded transaction details. These features make Zcash's privacy both user-friendly and compliant with institutional requirements.

Why the Sudden Surge?

Zcash's sudden surge seems to reflect a shift within crypto culture. As noted in a16z's "2025 Crypto Culture Report," there has been a recent surge in Google searches for privacy-related terms.

Many Bitcoin critics lament its "institutionalization," claiming it is dominated by ETFs and centralized custodians. Bitcoin itself has always been transparent, and ETFs only add intermediaries without changing its transparent nature. In contrast, Zcash supporters position it as the "encrypted version of Bitcoin," a return to the cypherpunk spirit. In the current surveillance-heavy environment from Chainalysis to on-chain forensic analysis, this resonates. Zcash's rise has reopened the old crack between "privacy as a right" and "transparency for regulation."

With its privacy technology stack finally achieving consumer-level usability (the Zashi wallet launched in March 2024 simplifying shielded transactions) and shielded supply continuing to grow, Zcash is gaining more attention. More shielded ZEC implies a wider shielded pool, making Zcash as a whole more private.

Another clear signal that Zcash has "come back" is: a few weeks ago, ZEC perpetual contracts were launched on Hyperliquid, allowing traders to leverage trade privacy coins on this popular decentralized exchange. This indicates strong market demand for this long-forgotten gem. The launch of perpetual contracts has increased ZEC's market liquidity, with open interest reaching about $115 million at one point, also intensifying spot price volatility.

From a technical fundamental standpoint, Zcash has not undergone a sudden transformation. But the market perception of it has changed. This rally is attributed to both continued vocal support from key figures in the industry and a renewed understanding that privacy is crucial for permissionless currency.

Whether the strong price performance of ZEC can be sustained, this market rotation has successfully forced a reassessment of the value of privacy.

After years of silence, this price surge has brought Zcash back into the spotlight. Whether it can translate the speculative momentum into sustainable network growth remains to be seen. However, the renewed focus on privacy reveals a deeper truth: in an increasingly transparent financial system, the ability to transact privately is once again being seen as a valuable feature.

Original Article Link

Foreword: Today, the People's Bank of China's website published the "Notice of the People's Bank of China, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration for Market Regulation, China Banking and Insurance Regulatory Commission, China Securities Regulatory Commission, State Administration of Foreign Exchange on Further Preventing and Dealing with Risks Related to Virtual Currency and Others (Yinfa [2026] No. 42)", the latest regulatory requirements from the eight departments including the central bank, which are basically consistent with the regulatory requirements of recent years. The main focus of the regulation is on speculative activities such as virtual currency trading, exchanges, ICOs, overseas platform services, and this time, regulatory oversight of RWA has been added, explicitly prohibiting RWA tokenization, stablecoins (especially those pegged to the RMB). The following is the full text:

To the people's governments of all provinces, autonomous regions, and municipalities directly under the Central Government, the Xinjiang Production and Construction Corps:

Recently, there have been speculative activities related to virtual currency and Real-World Assets (RWA) tokenization, disrupting the economic and financial order and jeopardizing the property security of the people. In order to further prevent and address the risks related to virtual currency and Real-World Assets tokenization, effectively safeguard national security and social stability, in accordance with the "Law of the People's Republic of China on the People's Bank of China," "Law of the People's Republic of China on Commercial Banks," "Securities Law of the People's Republic of China," "Law of the People's Republic of China on Securities Investment Funds," "Law of the People's Republic of China on Futures and Derivatives," "Cybersecurity Law of the People's Republic of China," "Regulations of the People's Republic of China on the Administration of Renminbi," "Regulations on Prevention and Disposal of Illegal Fundraising," "Regulations of the People's Republic of China on Foreign Exchange Administration," "Telecommunications Regulations of the People's Republic of China," and other provisions, after reaching consensus with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, and with the approval of the State Council, the relevant matters are notified as follows:

I. Clarify the essential attributes of virtual currency, Real-World Assets tokenization, and related business activities

(I) Virtual currency does not possess the legal status equivalent to fiat currency. Virtual currencies such as Bitcoin, Ether, Tether, etc., have the main characteristics of being issued by non-monetary authorities, using encryption technology and distributed ledger or similar technology, existing in digital form, etc. They do not have legal tender status, should not and cannot be circulated and used as currency in the market.

The business activities related to virtual currency are classified as illegal financial activities. The exchange of fiat currency and virtual currency within the territory, exchange of virtual currencies, acting as a central counterparty in buying and selling virtual currencies, providing information intermediary and pricing services for virtual currency transactions, token issuance financing, and trading of virtual currency-related financial products, etc., fall under illegal financial activities, such as suspected illegal issuance of token vouchers, unauthorized public issuance of securities, illegal operation of securities and futures business, illegal fundraising, etc., are strictly prohibited across the board and resolutely banned in accordance with the law. Overseas entities and individuals are not allowed to provide virtual currency-related services to domestic entities in any form.

A stablecoin pegged to a fiat currency indirectly fulfills some functions of the fiat currency in circulation. Without the consent of relevant authorities in accordance with the law and regulations, any domestic or foreign entity or individual is not allowed to issue a RMB-pegged stablecoin overseas.

（II）Tokenization of Real-World Assets refers to the use of encryption technology and distributed ledger or similar technologies to transform ownership rights, income rights, etc., of assets into tokens (tokens) or other interests or bond certificates with token (token) characteristics, and carry out issuance and trading activities.

Engaging in the tokenization of real-world assets domestically, as well as providing related intermediary, information technology services, etc., which are suspected of illegal issuance of token vouchers, unauthorized public offering of securities, illegal operation of securities and futures business, illegal fundraising, and other illegal financial activities, shall be prohibited; except for relevant business activities carried out with the approval of the competent authorities in accordance with the law and regulations and relying on specific financial infrastructures. Overseas entities and individuals are not allowed to illegally provide services related to the tokenization of real-world assets to domestic entities in any form.

II. Sound Work Mechanism

(III) Inter-agency Coordination. The People's Bank of China, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of virtual currency-related illegal financial activities.

The China Securities Regulatory Commission, together with the National Development and Reform Commission, the Ministry of Industry and Information Technology, the Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the State Administration of Foreign Exchange, and other departments, will improve the work mechanism, strengthen coordination with the Cyberspace Administration of China, the Supreme People's Court, and the Supreme People's Procuratorate, coordinate efforts, and overall guide regions to carry out risk prevention and disposal of illegal financial activities related to the tokenization of real-world assets.

(IV) Strengthening Local Implementation. The people's governments at the provincial level are overall responsible for the prevention and disposal of risks related to virtual currencies and the tokenization of real-world assets in their respective administrative regions. The specific leading department is the local financial regulatory department, with participation from branches and dispatched institutions of the State Council's financial regulatory department, telecommunications regulators, public security, market supervision, and other departments, in coordination with cyberspace departments, courts, and procuratorates, to improve the normalization of the work mechanism, effectively connect with the relevant work mechanisms of central departments, form a cooperative and coordinated working pattern between central and local governments, effectively prevent and properly handle risks related to virtual currencies and the tokenization of real-world assets, and maintain economic and financial order and social stability.

III. Strengthened Risk Monitoring, Prevention, and Disposal

(5) Enhanced Risk Monitoring. The People's Bank of China, China Securities Regulatory Commission, National Development and Reform Commission, Ministry of Industry and Information Technology, Ministry of Public Security, State Administration of Foreign Exchange, Cyberspace Administration of China, and other departments continue to improve monitoring techniques and system support, enhance cross-departmental data analysis and sharing, establish sound information sharing and cross-validation mechanisms, promptly grasp the risk situation of activities related to virtual currency and real-world asset tokenization. Local governments at all levels give full play to the role of local monitoring and early warning mechanisms. Local financial regulatory authorities, together with branches and agencies of the State Council's financial regulatory authorities, as well as departments of cyberspace and public security, ensure effective connection between online monitoring, offline investigation, and fund tracking, efficiently and accurately identify activities related to virtual currency and real-world asset tokenization, promptly share risk information, improve early warning information dissemination, verification, and rapid response mechanisms.

(6) Strengthened Oversight of Financial Institutions, Intermediaries, and Technology Service Providers. Financial institutions (including non-bank payment institutions) are prohibited from providing account opening, fund transfer, and clearing services for virtual currency-related business activities, issuing and selling financial products related to virtual currency, including virtual currency and related financial products in the scope of collateral, conducting insurance business related to virtual currency, or including virtual currency in the scope of insurance liability. Financial institutions (including non-bank payment institutions) are prohibited from providing custody, clearing, and settlement services for unauthorized real-world asset tokenization-related business and related financial products. Relevant intermediary institutions and information technology service providers are prohibited from providing intermediary, technical, or other services for unauthorized real-world asset tokenization-related businesses and related financial products.

(7) Enhanced Management of Internet Information Content and Access. Internet enterprises are prohibited from providing online business venues, commercial displays, marketing, advertising, or paid traffic diversion services for virtual currency and real-world asset tokenization-related business activities. Upon discovering clues of illegal activities, they should promptly report to relevant departments and provide technical support and assistance for related investigations and inquiries. Based on the clues transferred by the financial regulatory authorities, the cyberspace administration, telecommunications authorities, and public security departments should promptly close and deal with websites, mobile applications (including mini-programs), and public accounts engaged in virtual currency and real-world asset tokenization-related business activities in accordance with the law.

(8) Strengthened Entity Registration and Advertisement Management. Market supervision departments strengthen entity registration and management, and enterprise and individual business registrations must not contain terms such as "virtual currency," "virtual asset," "cryptocurrency," "crypto asset," "stablecoin," "real-world asset tokenization," or "RWA" in their names or business scopes. Market supervision departments, together with financial regulatory authorities, legally enhance the supervision of advertisements related to virtual currency and real-world asset tokenization, promptly investigating and handling relevant illegal advertisements.

（IX） Continued Rectification of Virtual Currency Mining Activities. The National Development and Reform Commission, together with relevant departments, strictly controls virtual currency mining activities, continuously promotes the rectification of virtual currency mining activities. The people's governments of various provinces take overall responsibility for the rectification of "mining" within their respective administrative regions. In accordance with the requirements of the National Development and Reform Commission and other departments in the "Notice on the Rectification of Virtual Currency Mining Activities" (NDRC Energy-saving Building [2021] No. 1283) and the provisions of the "Guidance Catalog for Industrial Structure Adjustment (2024 Edition)," a comprehensive review, investigation, and closure of existing virtual currency mining projects are conducted, new mining projects are strictly prohibited, and mining machine production enterprises are strictly prohibited from providing mining machine sales and other services within the country.

（X） Severe Crackdown on Related Illegal Financial Activities. Upon discovering clues to illegal financial activities related to virtual currency and the tokenization of real-world assets, local financial regulatory authorities, branches of the State Council's financial regulatory authorities, and other relevant departments promptly investigate, determine, and properly handle the issues in accordance with the law, and seriously hold the relevant entities and individuals legally responsible. Those suspected of crimes are transferred to the judicial authorities for processing according to the law.

（XI） Severe Crackdown on Related Illegal and Criminal Activities. The Ministry of Public Security, the People's Bank of China, the State Administration for Market Regulation, the China Banking and Insurance Regulatory Commission, the China Securities Regulatory Commission, as well as judicial and procuratorial organs, in accordance with their respective responsibilities, rigorously crack down on illegal and criminal activities related to virtual currency, the tokenization of real-world assets, such as fraud, money laundering, illegal business operations, pyramid schemes, illegal fundraising, and other illegal and criminal activities carried out under the guise of virtual currency, the tokenization of real-world assets, etc.

（XII） Strengthen Industry Self-discipline. Relevant industry associations should enhance membership management and policy advocacy, based on their own responsibilities, advocate and urge member units to resist illegal financial activities related to virtual currency and the tokenization of real-world assets. Member units that violate regulatory policies and industry self-discipline rules are to be disciplined in accordance with relevant self-regulatory management regulations. By leveraging various industry infrastructure, conduct risk monitoring related to virtual currency, the tokenization of real-world assets, and promptly transfer issue clues to relevant departments.

IV. Strict Supervision of Domestic Entities Engaging in Overseas Business Activities

（XIII） Without the approval of relevant departments in accordance with the law and regulations, domestic entities and foreign entities controlled by them may not issue virtual currency overseas.

（XIV） Domestic entities engaging directly or indirectly in overseas external debt-based tokenization of real-world assets, or conducting asset securitization activities abroad based on domestic ownership rights, income rights, etc. (hereinafter referred to as domestic equity), should be strictly regulated in accordance with the principles of "same business, same risk, same rules." The National Development and Reform Commission, the China Securities Regulatory Commission, the State Administration of Foreign Exchange, and other relevant departments regulate it according to their respective responsibilities. For other forms of overseas real-world asset tokenization activities based on domestic equity by domestic entities, the China Securities Regulatory Commission, together with relevant departments, supervise according to their division of responsibilities. Without the consent and filing of relevant departments, no unit or individual may engage in the above-mentioned business.

(15) Overseas subsidiaries and branches of domestic financial institutions providing Real World Asset Tokenization-related services overseas shall do so legally and prudently. They shall have professional personnel and systems in place to effectively mitigate business risks, strictly implement customer onboarding, suitability management, anti-money laundering requirements, and incorporate them into the domestic financial institutions' compliance and risk management system. Intermediaries and information technology service providers offering Real World Asset Tokenization services abroad based on domestic equity or conducting Real World Asset Tokenization business in the form of overseas debt for domestic entities directly or indirectly venturing abroad must strictly comply with relevant laws and regulations. They should establish and improve relevant compliance and internal control systems in accordance with relevant normative requirements, strengthen business and risk control, and report the business developments to the relevant regulatory authorities for approval or filing.

V. Strengthen Organizational Implementation

(16) Strengthen organizational leadership and overall coordination. All departments and regions should attach great importance to the prevention of risks related to virtual currencies and Real World Asset Tokenization, strengthen organizational leadership, clarify work responsibilities, form a long-term effective working mechanism with centralized coordination, local implementation, and shared responsibilities, maintain high pressure, dynamically monitor risks, effectively prevent and mitigate risks in an orderly and efficient manner, legally protect the property security of the people, and make every effort to maintain economic and financial order and social stability.

(17) Widely carry out publicity and education. All departments, regions, and industry associations should make full use of various media and other communication channels to disseminate information through legal and policy interpretation, analysis of typical cases, and education on investment risks, etc. They should promote the illegality and harm of virtual currencies and Real World Asset Tokenization-related businesses and their manifestations, fully alert to potential risks and hidden dangers, and enhance public awareness and identification capabilities for risk prevention.

VI. Legal Responsibility

(18) Engaging in illegal financial activities related to virtual currencies and Real World Asset Tokenization in violation of this notice, as well as providing services for virtual currencies and Real World Asset Tokenization-related businesses, shall be punished in accordance with relevant regulations. If it constitutes a crime, criminal liability shall be pursued according to the law. For domestic entities and individuals who knowingly or should have known that overseas entities illegally provided virtual currency or Real World Asset Tokenization-related services to domestic entities and still assisted them, relevant responsibilities shall be pursued according to the law. If it constitutes a crime, criminal liability shall be pursued according to the law.

(19) If any unit or individual invests in virtual currencies, Real World Asset Tokens, and related financial products against public order and good customs, the relevant civil legal actions shall be invalid, and any resulting losses shall be borne by them. If there are suspicions of disrupting financial order and jeopardizing financial security, the relevant departments shall deal with them according to the law.

This notice shall enter into force upon the date of its issuance. The People's Bank of China and ten other departments' "Notice on Further Preventing and Dealing with the Risks of Virtual Currency Trading Speculation" (Yinfa [2021] No. 237) is hereby repealed.

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