孙雪洁：我国虚拟货币监管政策的体系解读

Core Viewpoint - The article outlines the evolution of China's regulatory framework for virtual currencies from 2013 to 2025, highlighting key regulations and their implications for the financial system and legal risks associated with virtual currencies [3]. Regulatory Framework Overview - In December 2013, the People's Bank of China and other regulatory bodies issued a notice defining Bitcoin as a specific virtual commodity, prohibiting financial institutions from engaging in Bitcoin-related activities, thus establishing a "non-monetary" position for virtual currencies [4]. - In September 2017, the "94 Notice" was released, which banned Initial Coin Offerings (ICOs) and trading platforms, categorizing ICOs as illegal public financing activities and reinforcing the non-monetary status of virtual currencies [5]. - In September 2021, two significant notices were issued: one targeting virtual currency mining as an obsolete industry and the other emphasizing that virtual currency-related activities are illegal financial activities, thereby tightening regulations from mining to trading [6]. - A special meeting in November 2025 reiterated the illegal status of virtual currencies and emphasized ongoing efforts to combat illegal financial activities related to them, indicating a long-term commitment to stringent regulation [7]. Legal Interpretations and Case Studies - Legal interpretations from 2020 to 2022 have clarified the criminal implications of virtual currencies, including their use in gambling and fraud, and established that virtual currencies can be considered property under criminal law [8][9]. - Specific cases have demonstrated the application of these legal interpretations, highlighting the criminal liability associated with the use of virtual currencies in various illegal activities [9]. Conclusion - The legal risks associated with virtual currencies have evolved into a complex regulatory challenge encompassing criminal, financial, and tax issues. Although there is no dedicated "virtual currency law" in China, a robust regulatory system has been established through strong regulatory policies and existing legal frameworks [10].