Recently, regulatory authorities have intensively released policy signals concerning virtual currencies.
Followingthe meeting of the Coordination Mechanism for Combating Virtual Currency Trading and Speculation convened by the People's Bank of China on November 28, 2025The People's Bank of China convened a coordination mechanism meeting on combating speculative trading in virtual currencies.Subsequently,on December 5, 2025, seven industry associations jointly issuedthe "Risk Warning on Preventing Illegal Activities Involving Virtual Currencies and Related Matters", further demonstrating a clear and strong regulatory stance.
Within this risk warning, one statement warrants particular attention from all practitioners, especially job seekers considering transitioning into the Web3 industry:
"Domestic institutions and individuals who, knowing or should have known that they are engaged in virtual currency-related business activities, still provide services to them, shall be held legally accountable in accordance with the law."
Therefore, how should domestic Web3 job seekers interpret the current overall policy orientation of domestic regulatory authorities toward virtual currencies? What practical impact will these policies have on their job-seeking choices and career planning?
I. Author: Attorney Shao Shiwei
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The Current State of the Booming Web3 Job Market
Why have an increasing number of people chosen to transition into Web3 in the past two years?
Based on the extensive consultations handled by Attorney Shao, the reasons generally concentrate on the following aspects.
1. The Influence of Social Media Information
What is the current state of the Web3 job market in China?
If you open Bilibili, you will see numerous content creators sharing their Web3 job-hunting experiences, breaking down job roles, and providing “guides to entering the industry”:
If you open Xiaohongshu (Little Red Book), you will similarly encounter many key opinion leaders (KOLs) explaining various Web3 roles and showcasing salary levels:
The core message conveyed by such content is highly consistent:
High salaries, low entry barriers, remote work, and professional flexibility.
Furthermore, based on the consultation cases handled by Attorney Shao in recent years, this indeed reflects reality. For instance, technical professionals such as data analysts, AI engineers, and development engineers, as well as product managers, have transitioned from traditional industries to join virtual currency exchanges or Web3 project entities.
After communicating with multiple job seekers, Attorney Shao observed that for programmers, since their daily work inherently involves code, transitioning from traditional industries to Web3 does not entail significant learning costs or obvious professional barriers. Regardless of whether a job seeker previously worked in the physical economy, an internet company, or entered Web3 directly, the actual nature of their work does not differ substantially.
2. “Public Recruitment” on Job-Seeking Platforms
When you open recruitment platforms such as Boss Zhipin, you will find that many domestic human resources firms, headhunting agencies, and even individual recruiters openly recruit talent for virtual currency exchanges and Web3 project sponsors, with positions primarily in financial trading, technology, and product development.
Some postings relatively discreetly state that they are recruiting for centralized exchange (CEX) platforms (such as Binance, OKX, etc.);
Others label the positions as related to decentralized exchange (DEX) projects;
Still others plainly state:Cryptocurrency exchange, remote work.
In such scenarios, job seekers, relying on their trust in the platform, may easily perceive these ashigh-paying, lawful job opportunities that are “tacitly permitted”。
3. The Real-World Allure of High Salaries and Remote Work
Although, following the issuance of the “September 24 Notice” in 2021, virtual currency exchanges and Web3 project sponsors publicly announced their overseas expansion, in actual employment practices, due tolabor costsandCommunication efficiencyconsiderations, they remain highly dependent on domestic employees.
In terms of salary comparison, this temptation is extremely compelling.
Consider a not uncommon example:
In traditional industries, the pre-tax annual salary ranges from RMB 500,000 to RMB 700,000;
upon transitioning to Web3, the annual salary can reach RMB 1 million, and one can often chooseto receive compensation in the form of virtual currencies。
One is income from traditional industries that requires tax payments in accordance with the law, resulting in a significantly reduced net amount;
the other is substantial remuneration that is “net received” after conversion into RMB.
If legal risks are temporarily set aside, hardly anyone would remain unmoved.
Many job seekers who have consulted me (predominantly aged between 25 and 35, based on age distribution) have almost all received offers with annual salaries exceeding RMB 1 million:
There are no significant cross-industry barriers, remote work is available without clocking in, and the income is several times higher than before.
It is against this backdrop that job seekers perceive astark contrast between the “heat” of real-world opportunities and the “chill” of policy signals.。
2
a regulatory posture characterized by escalating intensity and sustained high pressure.
In sharp contrast to the job market, domestic regulators have adopted an increasingly clear and steadily intensifying policy stance.
1. Multi-agency coordinated crackdown led by the People’s Bank of China
On November 28, 2025, the People’s Bank of China convened a coordination meeting on combating speculative trading in virtual currencies. The meeting reiterated that, in accordance with the requirements set forth in instruments such as the September 24, 2021 Notice, efforts to crack down on virtual currency trading activities must continue, and it reaffirmed that business activities related to virtual currencies constitute illegal financial activities.
Of particular note, the People’s Bank of China took the lead this time, mobilizing 13 departments,This signifies that financial, cyberspace administration, public security, judicial, and foreign exchange authorities will engage in deep coordination to implement full-chain, penetrative regulation and enforcement.
2. Key signals from the seven associations’ risk warning
On December 5, 2025, seven industry associations jointly issued a risk warning on preventing involvement in illegal activities related to virtual currencies, among others. The following day, the Economic Crime Investigation Bureau of the Ministry of Public Security reposted the document.
The warning explicitly stated:
Overseas virtual currency and real-world assets (RWA) token service providers that directly or indirectly engage in related business activities or provide services to persons within the territory of the People’s Republic of China through various means are likewise engaged in illegal financial activities.
Domestic personnel of relevant overseas virtual currency service providers, as well as domestic institutions and individuals who knowingly or should have known that such parties were engaged in virtual currency-related business yet still provided services to them, shall be held legally accountable in accordance with the law.
The term “domestic institutions and individuals” referred to therein clearly denotes domestic employees recruited by overseas virtual currency exchanges and Web3 project sponsors who perform remote work within China.
The Notice issued on September 24, 2021 also addressed related matters:
With respect to relevant overseas virtual currencyexchange domestic personnel, as well as those who knowingly or should have known that they were engaged in virtual currency-related businessyet still providedmarketing and promotional, payment and settlement,technical supportlegal persons, unincorporated organizations, and natural persons providing such services shall be held legally liable in accordance with the law.
A comparison with the "September 24 Notice" issued in 2021 reveals a notable change:
the 2021 notice specifically enumerated activities such as "marketing and promotion, payment and settlement, and technical support";
whereas the 2025 formulation has been expanded to the broader concept of—“providing services。
This means that even individuals not in technical roles, including those in operations, community management, business development, or support functions,may likewise fall within the scope of potential legal risk.。
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For Web3 professionals working remotely within mainland China, what is the actual level of legal risk?
After reviewing these policies, many clients raise a highly practical question:
Setting aside policy statements, are there actual cases in which employees based in mainland China and working for overseas Web3 platforms have been arrested?
From their perspective, if the legal risk were truly so high, why does social media still feature extensive related content?
Why do recruitment platforms continue to list numerous such positions?
1. Why is there so little coverage in public media reports?
In fact, it is not surprising that clients raise such questions. Apart from lawyers like us who have long handled criminal cases in the new economy and Web3 industries, even practitioners in other legal fields have limited exposure to such cases. On many occasions, fellow lawyers also ask us the same questions.
For ordinary individuals, the information accessible is almost exclusively what has been publicly disclosed by the media. Why, then, do we rarely see criminal cases involving Web3 in public reports (here specifically referring to criminal cases related to Web3 project teams and virtual currency exchanges, rather than isolated instances where individuals are implicated merely because they received illicit funds through buying or selling virtual currencies)?
Based on Attorney Shao’s experience in handling cases in recent years, the primary reasons are concentrated in the following aspects:
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First, criminal cases are inherently highly confidential, and law enforcement agencies cannot disclose all case processes and details to the public.
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Second, in the Web3 sector, due to the absence of clear and systematic legal norms, law enforcement authorities operated for a considerable period in a state of “feeling their way across the river by touching the stones.” Many cases involve significant controversy regarding whether conduct constitutes a crime, and if so, which specific offense applies. Premature disclosure during the investigation stage could easily trigger public questioning of the legality of the investigative actions and the reasonableness of the legal characterization.
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Finally, from a practical standpoint, cases involving cryptocurrencies or Web3 often involve substantial amounts in dispute. Taking cases handled by Attorney Shao as examples, it is not uncommon for the amounts involved to reach hundreds of millions or even billions of yuan. Against this backdrop, issues such as profit-driven law enforcement and “long-arm fishing” objectively exist in some cases.
Due to the aforementioned multiple factors, ordinary job seekers find it difficult to access complete, authentic, and reference-worthy typical cases through public media, thereby hindering their ability to form an intuitive understanding of potential criminal risks.
However, Attorney Shao believes that social media platforms and Web3 job recruiters indeed bear certain responsibilities.
2. Responsibilities of Social Media Platforms
In reality, most job seekers do not actively ignore risks; rather,at the initial stage of information acquisition, they are “guided” by filtered content.。
Many job seekers rely on a rather simplistic line of reasoning:
Since related content can be publicly disseminated on mainstream platforms such as Xiaohongshu, Bilibili, and Douyin, does this not at least indicate that such work is “permitted to exist”?
The problem, however, is that social media platforms are by no means filters for legal risks.
In reality, given the vast volume of content and its rapid mutation, manual review and technical identification by platforms suffer from lag. Some content is packaged as “technical sharing,” “industry observations,” or “personal experiences,” making it difficult for moderation systems to accurately determine its non-compliant nature.
Furthermore, many publishers use English code words, industry jargon, or indirect topics (such as “Web3” and “digital assets”) to evade direct keyword filtering by platforms. For example, much of the content users encounter (such as posts about “airdrop hunting,” “buying USDT,” or sharing screenshots of profits) is, in essence, illegal marketing advertising designed to drive traffic to offshore virtual asset trading platforms.
This does not mean that platforms permit such activities. Taking Xiaohongshu as an example, the platform has explicitly stated its opposition to the promotion of virtual asset transactions and has implemented dynamic monitoring and governance measures, although governance challenges undoubtedly persist.
(According to WuShuo News, OKX’s official account was banned by Xiaohongshu.)
In May 2025, the Cyberspace Administration of China, together with financial regulatory authorities, lawfully dealt with a batch of accounts and websites that disseminated false information about the capital markets, engaged in illegal stock recommendations, or speculated on virtual asset transactions. Among the typical cases announced were those involving inducing internet users to participate in virtual asset transactions by sharing group chat messages and screenshots of profits.
3. Legal Loopholes in the Recruitment Process
In practice, certain recruitment firms and headhunting agencies that cooperate with offshore virtual asset exchanges and Web3 project teams objectively operate in a legal gray area.
From a regulatory perspective, under the Regulations on the Administration of Overseas Labor Cooperation, enterprises that recruit personnel for overseas entities and organize them to work abroad without obtaining the corresponding qualifications may be suspected of administrative violations, or even criminal offenses (such as the crime of organizing others to illegally cross national borders).
However, in actual operation, a large number of positions adoptRemote work arrangements within mainland Chinado not involve personnel leaving the country, and therefore do not fall squarely within the direct scope of application of the aforementioned regulations.
At the same time, such recruiting entities typically operate in the capacity of "intermediary matchmakers," collecting only service fees without directly participating in the actual business operations of the project sponsors. Even if the relevant platforms or projects are subsequently determined to be problematic, existing judicial practice indicates that it remains relatively uncommon for law enforcement authorities to initiate criminal investigations and file cases to hold headhunting firms or human resources agencies themselves criminally liable.
It is precisely due to this gap between institutional frameworks and practical implementation that such recruitment activities possess a certain "appearance of safety" in form, which further diminishes job seekers' vigilance regarding potential legal risks.
4. Cognitive Misconceptions Among Job Seekers
Many job seekers underestimate the risks due to two intuitive assumptions:
First, reliance on social media leads them to believe that the public dissemination of such content implies that "the issues are not significant";
Second, reliance on recruitment platforms leads them to believe that since the positions are posted on legitimate platforms, the work itself must be safe.
Furthermore, there is an even more prevalent misconception—
Many individuals believe that as mere rank-and-file employees, even if the platform is problematic, law enforcement authorities should first pursue the liability of the owners, and ordinary workers would not be targeted.
However, in Web3-related criminal cases, the reality is often quite the opposite.
Unlike traditional industries, the actual controllers of many project sponsors or exchanges have long physically relocated overseas. Consequently, those who remain exposed to domestic judicial jurisdiction over the long term are precisely these employees engaged in remote work within mainland China.
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Concluding Remarks
Even after detailed discussions, some clients still ask me in return:
“So many people around me are doing it and nothing has happened to them. Are you exaggerating the severity?”
Whenever I hear this question, I am reminded of a case involving the sale of counterfeit cigarettes in 2019.
The client asked me while in detention: “Every household in our village sells counterfeit cigarettes. Why did the police travel all the way from Shanghai to Yunnan to arrest only me? When they arrested me, the officers said they had been conducting undercover surveillance in our locality for six months.”
Indeed, why was it him?
#Web3 Job-Seeking Risks#Web3 Remote Work#Remote Work for Overseas Companies#Programmers Transitioning to Web3#Web3 Workers#Career Risks for Programmers#Remote Work for Technical Roles
