Web3 Lawyers Decode: What kind of RWA do people understand?

Source: encryption salad

Recently, discussions about RWA projects have been fervent in various Web3 communities. Industry observers often claim online that "RWA will reconstruct the new financial ecosystem of Hong Kong," believing that with the existing regulatory framework of the Hong Kong Special Administrative Region, this track will welcome breakthrough development. During discussions with colleagues, Crypto Salad found that everyone has been debating the so-called "compliance" issue recently, with differing understandings of what "compliance" actually means, leading to a situation where each side has its own rationale. This phenomenon is actually based on the divergence in understanding the concept of RWA.

Therefore, the encryption salad needs to discuss the concept of RWA from the standpoint of a professional legal team, and clarify the compliance red lines for RWA.

1. How should the concept of RWA be defined?

(1) Background and Advantages of RWA Projects

Currently, RWA is becoming a hot topic in the market and is gradually forming a new wave of development. This phenomenon is primarily based on the following two major backgrounds:

One reason is that the advantages of the token itself can compensate for the shortcomings of traditional financing.

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

1. Fast Financing Speed: Due to the circulation of tokens being based on blockchain technology, which typically circulates through decentralized intermediary trading institutions, it avoids obstacles that traditional financial projects may encounter such as foreign investment access restrictions, industry policy constraints, and lock-up period requirements. At the same time, it can compress the review process that originally took months or even years, greatly enhancing the financing speed.

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

3. Relatively Low Financing Costs: Traditional IPOs require long-term collaboration among multiple intermediaries such as investment banks, auditors, and law firms, with the total process costs reaching millions or even tens of millions. This incurs substantial expenses. However, RWA issues tokens through decentralized exchanges, saving a significant amount on intermediary fees, and by operating through smart contracts, it eliminates another large portion of labor costs.

In summary, RWA has taken the spotlight in financing projects due to its unique advantages, while the Web3 world and the cryptocurrency circle particularly need funds and projects from the traditional real world. This has led to a situation where, whether aiming for substantial business transformation or simply trying to ride the "trend" to gain attention, leading projects in the segmented fields of listed companies and the myriad of bizarre startups at the grassroots level are all actively exploring the application possibilities of RWA.

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

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

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

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

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

(2) Elements and Characteristics of RWA Projects

Real RWA projects need to have the following characteristics:

1. Based on real assets

The authenticity of underlying assets and whether the project party can establish a transparent and acceptable off-chain asset verification mechanism audited by a third party are key criteria for determining whether the project tokens can achieve effective value recognition in reality. For example, PAXG, a project that issues tokens pegged to gold in real-time, has each token backed by 1 ounce of physical gold, with gold reserves managed by a third-party platform and audited quarterly by a third-party auditing company, and even supports redeeming a corresponding amount of physical gold with the tokens. This high level of transparency and regulated asset verification mechanism allows the project to gain the trust of investors and provides a foundation for effective valuation in the real financial system.

2. Asset Tokenization on Chain

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

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

3. Digital assets have ownership value

The tokens issued by the RWA project should belong to digital assets with property attributes. The project party should clearly distinguish between data assets and digital assets: data assets are a collection of data owned by the enterprise that can create value. In contrast, digital assets are the value itself and do not require repricing through data. For example, when you design a painting, upload it to the blockchain, and generate an NFT, this NFT is a digital asset because it can be certified and traded. However, the large amount of feedback from users regarding this painting, browsing data, click rates, and other data belong to data assets. You can analyze data assets to determine user preferences, improve your work, and adjust its price.

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

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

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

(3) Types and Regulation of RWA Projects

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

1. Narrowly Defined RWA: Real-World Assets on the Blockchain

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

2. STO (Security Token Offering): Financial assets on the blockchain

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

(1) Definition of STO

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

(2) Definition of Security Tokens

Compared to functional tokens, security tokens are, simply put, on-chain financial products driven by blockchain technology that are regulated by securities laws, similar to electronic stocks.

(3) Regulation of Security Tokens

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

From an economic perspective, the core objective of financial products is to coordinate the supply and demand relationship between financing parties and investors; from a legal regulatory standpoint, some countries place a greater emphasis on protecting investor interests, while others tend to encourage smooth financing activities and innovation. This difference in regulatory stance is reflected in the specific rules, compliance requirements, and enforcement intensity within the legal systems of various countries. Therefore, when designing and issuing RWA products, it is essential to not only consider the authenticity and legality of the underlying assets but also to comprehensively examine and design for compliance in key aspects such as product structure, issuance methods, circulation paths, trading platforms, investor access thresholds, and capital costs.

It is particularly noteworthy that once the core appeal of a certain RWA project lies in its high leverage and high return expectations, and positions "hundredfold or thousandfold returns" as a main selling point, then regardless of its superficial packaging, its essence is very likely to be classified as a securities product by regulatory authorities. Once classified as a security, the project will face a more stringent and complex regulatory framework, and its subsequent development path, operational costs, and even legal risks will be significantly heightened.

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

A. Mainland China

Under the regulatory framework in mainland China, the "Securities Law of the People's Republic of China" defines securities as stocks, corporate bonds, depositary receipts, and other negotiable instruments recognized by the State Council that can be issued and traded, and it also includes the listing and trading of government bonds and shares of securities investment funds under the regulation of the "Securities Law."

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

B. Singapore

Although Singapore's "Guidelines on Digital Token Offerings" and the "Securities and Futures Act" do not directly mention the concept of "security tokens", they provide a detailed enumeration of the various scenarios in which tokens can be recognized as "capital market products":

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

C. Hong Kong, China

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

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

The regulation defines "securities" to include "shares, equity interests, notes, bonds" as structured products, and does not limit their existence to traditional carriers. The SFC has explicitly stated in the "Circular on Intermediaries Engaging in Activities Related to Tokenized Securities" that the nature of its regulatory targets is essentially traditional securities packaged as tokenized.

D. United States

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

The Howey Test lists four conditions under which a financial product is recognized as a "security." The application of the Howey Test in digital assets is specified in the U.S. SEC's "Framework for 'Investment Contract' Analysis of Digital Assets." We will proceed to analyze this in detail:

• The Investment of Money（金钱投入）

This refers to investors investing money or assets into a project in exchange for certain rights or expected returns. In the field of digital assets, whether using fiat currency or encryption to purchase tokens, as long as there is a value exchange, it can generally be recognized as meeting this standard. Therefore, most token issuances basically comply with this condition.

• Common Enterprise

"Joint venture" refers to the close binding of interests between investors and the issuer, usually manifested in the direct correlation between the investors' returns and the project's operational performance. In token projects, if the returns of token holders depend on the business development of the project party or the operational results of the platform, it meets the characteristics of a "joint venture". This condition is also relatively easy to fulfill in reality.

• Reasonable Expectation of Profits Derived from Efforts of Others

This point is crucial in determining whether a token will be classified as a security token. The condition refers to the situation where, if the investor purchases the product with the expectation of future appreciation or obtaining other economic returns, and such returns are not derived from their own use or operational actions, but rather rely on the overall development of a project created by others' efforts, then the product may be considered a "security."

In the context of RWA projects, if the purpose of investors purchasing tokens is to obtain future appreciation or economic returns, rather than benefits derived from their own use or operational activities, then the token may have "profit expectations," thereby triggering the determination of securities attributes. Especially when the token's returns are highly dependent on the professional operations of the issuer or project team, such as liquidity design, ecological expansion, community building, or collaborations with other platforms, this characteristic of "relying on the efforts of others" further enhances its potential for securitization.

RWA tokens with truly sustainable value should be directly anchored to the real income generated by underlying real-world assets, rather than relying on market speculation, narrative packaging, or platform premiums to drive their value growth. If the value fluctuations of the tokens are primarily derived from the "recreation" operated by the underlying team or platform, rather than the income changes of the assets themselves, then they do not possess the characteristics of "narrow RWA" and are more likely to be regarded as security tokens.

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

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

After discussing so much about the concept and definition of RWA, let's return to the core question raised at the beginning of the article, which is also a focal point of common concern in the industry:

As RWA has developed to this day, which types of RWA can be considered truly "compliant" RWA? How can we ensure the compliance of RWA projects in practice?

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

Layer One: Sandbox Compliance

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

The Hong Kong Monetary Authority (HKMA) has shown a high level of importance to the sovereignty of future monetary systems in promoting the Central Bank Digital Currency (e-HKD) and exploring the regulation of stablecoins. The competition between Central Bank Digital Currency and stablecoins is essentially a redefinition and struggle for "monetary sovereignty." The sandbox provides a certain degree of policy space and flexibility for project parties, which is conducive to promoting exploratory practices of bringing real assets on-chain.

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

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

Second Layer: Hong Kong Administrative Regulatory Compliance

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

By sorting through the relevant circulars and policy practices issued by the Hong Kong Securities and Futures Commission, we can easily find that the core of Hong Kong's regulation of RWA is to actually incorporate it into the framework of STO for compliance management. Moreover, the Securities and Futures Commission has established a relatively comprehensive licensing system for Virtual Asset Service Providers (VASP) and Virtual Asset Trading Platforms (VATP), and is preparing to release a second virtual asset policy declaration to further clarify the regulatory attitude and basic principles when virtual assets are combined with real assets. Under this institutional framework, tokenization projects involving real assets, especially RWA, have been incorporated into a higher level of compliance regulatory scope.

From the current RWA projects that have been implemented and have a certain market influence in Hong Kong, most projects have clear securities attributes. This means that the tokens they issue involve ownership, income rights, or other transferable rights of real assets, which can constitute "securities" as defined under the Securities and Futures Ordinance. Therefore, such projects must be issued and circulated in the form of security tokens (STO) in order to obtain regulatory approval and achieve compliance in market participation.

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

Layer Three: Clear Regulatory Framework for Encryption-Friendly Areas

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

Fourth Layer: "Pan Compliance"

This is compliance in the broadest sense, which is contrary to "non-compliance". It specifically refers to RWA projects within certain offshore jurisdictions where the government temporarily adopts a "laisser-faire" attitude towards the virtual asset market, and has not been explicitly identified as violating or illegal. Their business model has a certain degree of compliance space under the local legal framework. Although the scope and concept of such compliance are relatively vague, and do not yet constitute complete legal confirmation, it belongs to a business status of "permissible as long as not prohibited" before legal regulation becomes clear.

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

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

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

In summary, we believe that compliance for RWA projects should be conducted within the current framework, and all projects must maintain policy sensitivity. Once there are legal adjustments, urgent changes must be made. Given that the current regulations are not yet fully clarified and the RWA ecosystem is still in an exploratory stage, we strongly recommend that all project parties take the initiative to carry out "self-compliance" work. Although this means investing more resources and bearing higher time and compliance costs at the early stages of the project, in the long run, it will significantly reduce systemic risks in areas such as legal, operational, and investor relations.

Among all potential risks, the fundraising risk is undoubtedly the most lethal hidden danger for RWA. Once a project design is deemed illegal fundraising, significant legal consequences will arise regardless of whether the assets are real or the technology is advanced, which poses a direct threat to the survival of the project itself and is a heavy blow to the assets and reputation of the enterprise. In the process of RWA development, there will inevitably be differences in regulatory definitions in different regions and regulatory environments. For developers and institutions, it is essential to formulate detailed phased compliance strategies in conjunction with their own business types, asset properties, and regulatory policies of the target market. Only under the premise of ensuring controllable risks can the RWA project be steadily advanced.

3. Legal Advice for RWA Projects****

In summary, as a legal team, we systematically outline the core aspects that need attention from a compliance perspective during the full-chain promotion process of RWA projects.

1. Choose a policy-friendly jurisdiction

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

2. The underlying assets must have real redeemable capability

No matter how complex the technical architecture is, the essence of RWA projects is still to map the rights of real assets onto the blockchain. Therefore, the authenticity of the underlying assets, the reasonableness of the valuation, and the executability of the redemption mechanism are all core factors that determine the project's credibility and market acceptance.

3. Obtain Investor Recognition

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

While the RWA project parties are promoting the compliance process, they must also face another core issue: investors must be informed. In reality, many projects wrap risks in complex structures, failing to clearly disclose the underlying asset status or token model logic, leading to investors participating without a full understanding. Once fluctuations or risk events occur, it not only triggers a market trust crisis but may also attract regulatory attention, making the situation often more difficult to handle.

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

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

In the entire process of RWA, it often involves multiple links such as fundraising, custody, valuation, tax processing, and cross-border compliance. Each link corresponds to regulatory agencies and compliance requirements in reality, and the project party needs to complete compliance declaration and regulatory connection under the relevant legal framework to reduce legal risks. For example, in the part related to fundraising, special attention should be paid to whether it triggers compliance obligations related to securities issuance, anti-money laundering, and other aspects.

5. Preventing Post-Compliance Risks

Compliance is not a one-time action; after the implementation of RWA projects, there is still a need to continuously face changes in the dynamic regulatory environment. How to prevent potential administrative investigations or compliance accountability in the post-event dimension is an important guarantee for the sustainable development of the project. It is recommended that project parties establish a professional compliance team and maintain a communication mechanism with regulatory authorities.

6. Brand Reputation Management

In the highly sensitive virtual asset industry where information dissemination is critical, RWA projects must also pay attention to public opinion management and market communication strategies. Building a transparent, credible, and professional project image helps to enhance the trust of the public and regulators, creating a favorable external environment for long-term development.

4. Conclusion

In the current process of continuous integration of virtual assets and the real economy, various RWA projects have different intentions and mechanisms, featuring both technological innovations and financial experiments. The capabilities, professionalism, and practical paths of different projects vary greatly, making it worthwhile for us to study and categorize them one by one.

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

But we must also keep compliance as a constant alert. Respecting the existing judicial and regulatory framework is the basic premise of all innovative actions. Regardless of how the industry develops or how technology evolves, the law remains the baseline logic that protects market order and public interest.

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