银发42号文的红线、锚点与双轨试验

Core Viewpoint - The release of Document No. 42 marks a significant regulatory shift in China's approach to digital assets, particularly focusing on the systematic regulation of Real World Asset (RWA) tokenization, coinciding with the launch of interest-bearing digital RMB 2.0 [1][2][3] Regulatory Framework - Document No. 42 clearly defines RWA tokenization as the conversion of asset ownership and income rights into tokens using cryptographic and distributed ledger technologies, expanding regulatory oversight from virtual currency speculation to the entire asset tokenization chain [2][3] - The document prohibits illegal financial activities related to RWA tokenization unless approved by relevant authorities, emphasizing the need for compliance with specific financial infrastructure [3][4] Comparison of Regulatory Approaches - In contrast to mainland China's "principle of prohibition," Hong Kong is accelerating RWA tokenization, with the government encouraging the tokenization of public assets and establishing a regulatory framework for stablecoins [4][5] - The regulatory strategies in mainland China and Hong Kong represent a "dual-track experiment," where mainland focuses on maintaining financial safety while Hong Kong aims to connect with global capital markets through compliance [4][5][6] Market Dynamics and Opportunities - The market is reassessing the viability of RWA tokenization from three dimensions: asset category selection, geographical strategy, and deeper monetary competition logic [7][8] - Standardized financial assets like money market funds and bonds are becoming the mainstream in global tokenization, while non-standard assets face liquidity challenges [7][8] - The regulatory environment is creating a competitive landscape where licensed institutions dominate, leading to a "survivor game" among players who can navigate both mainland and Hong Kong regulations [13][26] Compliance and Risk Management - The regulatory framework emphasizes the importance of compliance with asset ownership, information disclosure, and cross-border accountability, with specific guidelines for the issuance of RWA [19][26] - Key risks include the potential for illegal service provision to mainland entities from abroad, highlighting the need for strict adherence to regulatory requirements [25][26] Conclusion - Document No. 42 establishes clear regulatory boundaries, indicating that while technology can be utilized, it cannot be leveraged for activities resembling currency, securities, or cross-border channels without proper oversight [9][23]