Week 13 On-chain Data: Whale's HODLing vs Market's FUD, Who Will Lead the Next Stage of Crypto?
Original Title: "Whale's Patience vs Market Panic: Who Will Lead Crypto's Next Phase? | WTR 4.07"
Original Source: WTR Research Institute
Weekly Recap
During this week from March 31st to April 7th, Bitcoin reached a high near $88,500 and a low near $74,508, with a fluctuation range of approximately 15.8%.
Observing the on-chain distribution chart, there is a significant volume of chips traded around 78,567, which may provide some support or resistance.

• Analysis:
1. 1.55 million coins around 60,000-68,000;
2. 2.04 million coins around 90,000-100,000;
• The probability of short-term decline not breaking below 70,000 to 75,000 is 70%;
• The probability of short-term rise not breaking above 80,000 to 85,000 is 60%.
Important News Aspects
Economic News Aspect
• U.S. stock index futures have fallen by more than 15% over three consecutive days.
• Last week, the Nasdaq index fell by over 10%, the S&P 500 fell by over 9%, and the Dow Jones index fell by over 7%.
• The Kobeissi Letter data shows that the U.S. stock market lost $11.1 trillion in 44 trading days, approximately 38% of the U.S. GDP.
• The S&P 500 has evaporated about $5.4 trillion in market value in the past two days.
• Due to rumors (later debunked) that Trump was considering suspending tariffs, there was a significant intraday market movement (9.68% swing), especially in the Nasdaq, followed by a retreat after the White House denial (Nasdaq closed up 0.1%, S&P down 0.23%, Dow down 0.91%).
Fed Policy Expectations and Actions:
• Rate Cut Expectations Heighten/Front-Loading: Market expectations for an "emergency rate cut" by the Fed have surged.
• Options trading indicates a 40% probability of a 25 basis point rate cut next week (relative to the reporting time), much earlier than the originally scheduled May 7th meeting. The interest rate futures market fully prices in five rate cuts by 2025, with a 54.6% probability of a 25 basis point cut in May.
Institutional Predictions:
• Goldman Sachs Prediction: If the U.S. avoids a recession, the Fed will start a series of three 25-basis-point rate cuts from June; if there is a recession, the Fed is expected to cut rates by about 200 basis points next year. The total rate cut by 2025 is projected to be 130 basis points (higher than the previous expectation of 105 basis points).
• Morgan Stanley joins Goldman Sachs, UBS, and others in predicting that the Fed will cut rates after June at every meeting until May 2026.
• Goldman Sachs has revised down its forecast for U.S. GDP growth in Q4 2025 to 0.5% and has increased the probability of a recession in the next 12 months from 35% to 45%.
• Trump's Pressure: Trump stated on April 7th that the U.S. has no inflation and reiterated that the Fed should cut rates.
• The Fed held a closed-door meeting on April 7th, and the results are pending. The meeting minutes will be released this Thursday (relative to the reporting time).
Trade and Tariff Issues:
• Trump's Tariff Impact: Trump's insistence on implementing tariff measures is considered one of the key reasons for market turmoil.
• Bloomberg reported that Wall Street executives are pressuring the U.S. Treasury Secretary in an effort to persuade Trump to change his tariff stance.
• Attention is on the possible effective date of tariffs on April 9th; a Trump economic advisor stated that it is impossible to confirm if an agreement will be reached by then.
• EU Retaliation: The European Commission has proposed a 25% retaliatory tariff on U.S. goods, effective from May 16th. Ursula von der Leyen called this a significant turning point for the U.S., but the EU is still prepared to negotiate.
1. Global Market Interconnection:
◦ On Monday, the Nikkei Index (dropped over 8% within the first 10 minutes of trading) and the KOSPI Index (dropped over 5%) triggered a circuit breaker.
◦ Major European stock indices (Euro Stoxx 50, FTSE 100) also plunged significantly (more than 4%).
◦ Gold price fell by 1.67% to $2984 per ounce (Note: Gold usually rises in a risk-off scenario, this information may need verification or have a specific background).
Cryptocurrency Ecosystem Updates
1. The total cryptocurrency market cap reported $2.51 trillion on April 7th, with a 24-hour decrease of 10.7%. Since January 20th (linked to something related to Trump), the market cap has evaporated by $1.111 trillion.
2. The Crypto Fear and Greed Index dropped to 23 on April 7th (extreme fear), below the previous week's average of 34.
3. BTC once dropped to $74,500, and ETH dropped to $1411.
4. The Block reported that Monday's crypto market sell-off was mainly driven by global macro factors rather than inherent issues in the crypto market itself. An oversold condition may trigger a rebound sometime this week (depending on macro data).
5. Analyst Eugene Ng Ah Sio believes that the decline is part of the overall turbulence in U.S. stocks (including the crypto market), survival is key, and there may be an opportunity after the storm.
6. Standard Chartered Bank Analysis: U.S. "Isolationism" and Tariff Risk Could Increase BTC's Safe Haven Value (relative to USD risk), and if traditional markets have no broader safe haven, BTC could rebound to around $84,000.
7. Last week, the U.S. spot BTC ETF saw a cumulative net outflow of $165 million.
8. Grayscale's BUIDL Fund (tokenized fund) reached a size of $19.4983 billion, with a weekly increase of $14 million and a growth of 191.71% in the past 30 days.
9. The "Whale/Institution 7 Siblings" increased their holdings by 25,102 ETH at an average price of $1,700, with the address holding over 660,000 ETH in total.
10. The U.S. SEC will hold its second roundtable discussion on "Customizing Regulation for Cryptocurrency Trading Volume" on April 11 Eastern Time.
11. An executive from the Hong Kong Stock Exchange (HKEX) stated at Web3 Summit that they will issue a circular allowing licensed virtual asset platforms to provide collateral services (including for spot ETFs) and will implement additional safeguards (such as mandatory custody and setting collateral ratio limits) to manage risks.
· Long-Term Insight: Used to observe our long-term situation; Bull Market/Bear Market/Structural Changes/Neutral State
· Medium-Term Exploration: Used to analyze the stage we are currently in, how long it will last, and what situations we will face during this stage
· Short-Term Observation: Used to analyze short-term market conditions; and the possibility of certain events occurring under certain conditions
Long-Term Insight
• Exchange Whale Inflow-Outflow Net Position
• U.S. Bitcoin Spot ETF Fund Flows
• Bitcoin High-Weight Sell Pressure
• Illiquid Whales
(Below Image Exchange Whale Inflow-Outflow Net Position)

While the overall market is selling off due to macro panic and potential ETF outflows, the largest players (whales) appear to be taking advantage of this decline to withdraw tokens from exchanges. This may indicate:
• Accumulation/Distribution: They see the low price as a buying opportunity and are transferring coins to cold wallets for storage.
• Long-Term Holding Intentions: Protecting assets during high volatility periods, indicating confidence in holding even during market downturns.
This strongly suggests that these large entities are not the primary drivers of selling pressure on the current exchange.
Their behavior may even provide potential bottom support or indicate that "smart money" is accumulating chips.
(See chart: U.S. Bitcoin Spot ETF Fund Flows)

While there was indeed a significant net outflow during a recent price decline period (negative bar), a very large single-day net inflow (huge positive bar) has occurred at the most recent data point on the right side of the chart.
This is an extremely important signal. It indicates that recently, a large amount of funds has flowed into the Bitcoin market through the ETF channel.
This completely reverses the short-term assessment based solely on previous outflow data indicating "ETF demand exhaustion." It may imply:
• One or more large institutions/investors believe that the recent price is attractive and have entered the market decisively.
• This large inflow may indicate the beginning of a shift in market sentiment from extremely pessimistic to stabilizing, or at least a sign of selling pressure temporarily exhausting.
• The scale of this inflow may be sufficient to offset or even exceed the previous days' outflows, significantly improving the short-term supply/demand balance from the ETF channel.
Of course, single-day data may be incidental. It is necessary to observe whether the subsequent days' ETF flows can continue to be positive or remain stable to confirm a trend reversal.
(See chart: Bitcoin High Weighted Sell Pressure)

The main selling pressure from long-term holders may indeed be over.
• The high supply of short-term speculators at a peak level still poses a potential risk (they are prone to panic), but the recent significant ETF inflow may boost the market, temporarily stabilizing the price, alleviating some of the short-term speculators' selling pressure, and even giving them hope.
• If the price rebounds due to ETF inflows, the losing position of short-term speculators may improve.
(See chart: Illiquid Whale Cluster)

The recent large inflow is a strong mid-term signal, possibly marking the confirmation by strong buyers of an important support level in the retracement phase. However, this does not immediately change the fact that the long-term accumulation trend has slowed down.
It is more like a strong buy signal that emerged in an adjustment period. The current market situation is more complex and slightly positive than previously assessed.
Although the macro risk still exists, long-term holders have been distributing at high levels, the accumulation momentum has weakened, and a large number of short-term holders are at breakeven or at a loss, two key "smart money" or "institutional volume" signals have appeared simultaneously, and they point in the same direction (bullish on the current price range):
1. Whales continue to withdraw from exchanges, showing long-term holding confidence or off-exchange accumulation.
2. The latest data shows a significant amount of capital flowing into the market through ETFs, indicating strong buying volume intervention at recent lows.
These two signals together have weakened the short-term bearish expectations brought solely by the previous ETF outflows and high short-term speculator chip stack.
The market may be going through a stage of intense long and short force competition, where long-term bulls/large institutions are using pullbacks to accumulate positions, resisting the pressure brought by macro panic and some short-term holders' selling.
Future Outlook
Short Term:
◦ Volatility remains high, but the short-term bottom may have been found or is forming. The latest significant ETF inflow is a strong support signal.
◦ The key is to observe whether the future days' ETF flow can continue to be positive or remain neutral. If the inflow continues, the price is expected to stabilize or even rebound, greatly alleviating the pressure from short-term speculators. If subsequent flows turn significantly outwards again, it indicates that the inflow may have been an isolated event, and there is still downside risk in the market.
Medium Term:
• The possibility of consolidation and forming a bottom increases.
• If ETF inflows can continue for a period (even if not significant inflows every day, but overall no longer significant outflows), combined with whale off-exchange accumulation, it may form a relatively solid bottom near the current price range.
• The market still needs time to digest the chips of high-level short-term speculators and wait for the macro environment to become clearer.
• The fundamental view remains unchanged, long-term value logic is still valid.
• However, this significant ETF inflow (if proven to be a return of institutional behavior) may mean that institutional interest in Bitcoin has not disappeared due to short-term fluctuations; they may still be looking for strategic entry points.
This is positive for Bitcoin's broader acceptance and long-term value discovery.
Mid-Term Exploration
• Short-term, Long-term Participant Supply
• Network Sentiment Positivity
• Liquidity Supply
• Net Headroom of Loss Transfer Amount
• Derivative Clearing Structure
(Chart below Short-term, Long-term Participant Supply)

The current supply of short-term participants is still decreasing, while the supply of long-term participants is increasing.
The current structure may be in a low liquidity environment where short-term supply is weakening, leading to weaker support for secondary pricing.
Conversely, the rise in long-term funds may indicate a return to accumulation on the price chart, compressing the remaining available supply for sale in a cycle of supply-side deflation.
Similarly, in a phase where the market is gradually seeking a bottom, the accumulation of long-term chips favors a stronger breakout in the next market rally.
(Chart below Network Sentiment Positivity)

Network sentiment has been relatively low recently, indicating a poor overall market circulating supply condition.
Combined with the decrease in short-term participant supply, the current speculative capital in the market shows weaker momentum.
(Chart below Liquidity Supply)

Liquidity supply remains in a sluggish state, indicating that the market's structural repair still needs time.
(Chart below Net Headroom of Loss Transfer Amount)

If the selling pressure from loss-making chips gradually weakens, there may be signs of gradually contracting the left-side pricing, although it has not decreased yet but has reached a temporary maximum selling limit.
Assuming there is no continuous stampede of loss-selling, the selling pressure at the current stage may have reached a limit area.
(Chart below Derivative Clearing Structure)

The derivative clearing structure has shifted from a long position clearing to a short position clearing structure, which may exacerbate short selling pressure over time.
Short-Term Observations
• Derivative Risk Factor
• Options Intention-to-Trade Ratio
• Derivative Trading Volume
• Options Implied Volatility
• Profit and Loss Transfer Amount
• New Addresses and Active Addresses
• Sugar Orange Exchange Net Short Position
• Auntie Exchange Net Short Position
• High-Weight Sell Pressure
• Global Buying Power Status
• Stablecoin Exchange Net Short Position
• Off-chain Exchange Data
Derivative Rating: The risk factor is in the green zone, indicating reduced derivative risk.
(See Chart Derivative Risk Factor)

Driven by news, the market has experienced a rapid pullback, with the current risk factor entering the green zone. Solely based on indicators, the rapid liquidation risk to long positions has decreased again. However, this week's market sentiment is expected to be heavily influenced by news.
(See Chart Options Intention-to-Trade Ratio)

The put/call ratio and trading volume have both rapidly increased, with the current put/call ratio at a high level.
(See Chart Derivative Trading Volume)

Derivative trading volume has surged to the median level.
(See Chart Options Implied Volatility)

• Options implied volatility has experienced rapid short-term fluctuations.
• Sentiment Rating: Neutral
(See Chart Profit and Loss Transfer Amount)

The following is only applicable to BTC. With a rapid pullback, the market did not see a true "capitulation" panic sell-off, with only a small number of chips choosing to realize losses.
Observing the Orange Line (panic sell-off), if it touches the phase peak again, it is a relatively good short-term buying opportunity.
(Chart below shows New Addresses and Active Addresses)

- New active addresses are at a mid-low level.
- Spot and selling pressure structure rating: BTC and ETH both saw a small inflow
(Chart below shows Sugar Orange Exchange Net Inflows)

Currently, BTC has seen a small inflow.
(Chart below shows E.T. Exchange Net Inflows)

Currently, ETH has seen a small inflow.
(Chart below shows High-Weighted Selling Pressure)

- The current pullback has seen a small amount of high-weighted selling pressure participation.
- Buying Power Rating: Global buying power is in a state of erosion, with a small outflow in stablecoin buying power.
(Chart below shows Global Buying Power Status)

The current buying power is in a state of erosion.
(Chart below shows USDT Exchange Net Inflows)

- There is a small outflow in stablecoin buying power.
· Off-Chain Transaction Data Rating: Willing to buy at 70000; Willing to sell at 88000.
(See Coinbase Off-Chain Data below)

· Willing to buy around 65000-75000 price range;
· Willing to sell at 88000 price range.
(See Binance Off-Chain Data below)

· Willing to buy around 70000-75000 price range;
· Willing to sell at 88000 price range.
(See Bitfinex Off-Chain Data below)

· Willing to buy at around 65000, 75000 price range;
· Willing to sell at 88000 price range.
Weekly Summary:
News Summary:
The current financial market is undergoing a crisis of confidence driven by drastic changes in macroeconomics (especially the uncertainty of U.S. tariff policies) and expectations of monetary policy (a significant bet on the Fed cutting rates substantially in advance). This has led to a widespread sell-off of risk assets including U.S. stocks and cryptocurrencies, with market sentiment in extreme panic.
The crypto market has shown a high degree of correlation with traditional risk assets in this storm, and short-term outflows of capital (such as BTC ETFs) have exacerbated downward pressure. However, there are also some long-term positive signals within the market, such as continued institutional engagement (BUIDL growth), some whales buying the dip, and the gradual establishment of regulatory frameworks (e.g., new regulations in Hong Kong).
In the short term, the market direction will depend heavily on key economic data to be released, Fed communication, and the final implementation of tariff policies. Volatility is expected to remain high.
Data-Driven Rebound or Plunge: If CPI/PPI data significantly falls below expectations, it may strengthen rate cut expectations, coupled with oversold sentiment, which could trigger a brief rebound in risk assets (including cryptocurrencies).
In the medium term, the Federal Reserve's actual policy path and its game with market expectations, as well as whether the U.S. economy is heading into a recession, will be the key drivers.
Fed's Actual Path vs Market Expectations: The core issue is whether the Fed will deliver on the market's aggressive rate cut expectations and how.
If the economic data does not deteriorate rapidly, the Fed may not cut rates as quickly or significantly as the market expects, which could lead to market repricing.
Whether the U.S. economy is on a substantial path to a recession will be crucial in influencing asset allocation and Fed policy.
In the long term, the evolution of the macroeconomic landscape and the clarification of the positioning of crypto assets' intrinsic value will determine their development trajectory.
Whether BTC and other crypto assets can establish their unique value proposition in different macroeconomic cycles (such as high inflation, recession, geopolitical risks) will be validated through longer-term performance.
The market's short-term direction heavily depends on upcoming events:
· Release of key U.S. economic data (CPI, PPI).
· Publication of the Fed meeting minutes (confirming or revising market expectations).
· Final decision on Trump's tariff policy (April 9th is a key observation point).
On-chain Long-term Insights:
1. Whales have recently continued to withdraw from exchanges, indicating their confidence in accumulating or holding long-term positions during market downturns.
2. Spot ETFs experienced significant net outflows followed by a large single-day net inflow, suggesting strong buying interest at current price levels.
3. High-weight holders have taken profits at highs (VDD), but there are still a significant number of short-term holders (STH) in a fragile state possibly ready to sell.
4. Long-term whale cohorts show diminishing market accumulation momentum, and the momentum peak of this uptrend has passed.
• Market Tone:
After reaching a peak, the market is currently in a phase of pullback under macroscopic pressure.
Despite risks such as fragile short-term holders, positive signals have surfaced: whales accumulating off-exchange, and key spot ETFs experiencing significant single-day inflows.
The convergence of these signals indicates significant buying interest in the current price region, potentially forming a short-term bottom or strong support area, but the short-term outlook heavily relies on the sustainability of this ETF's new demand.
On-chain Mid-term Exploration:
1. Short-term supply reduction coexists with long-term capital accumulation, leading the market into a low liquidity environment, indicating a potential future momentum-building phase.
2. Depressed market sentiment coupled with a contraction in short-term supply reflects a significant decrease in speculative capital activity.
3. Persistent liquidity shortage, requiring more time for structural market repair.
4. Current selling pressure has almost peaked, with signs of either left-side pricing or immediate contraction if it hasn't triggered a cascading sell-off.
5. Derivative liquidation structure transitioning from long to short, with the short-side risk exposure gradually accumulating over time.
• Market Tone:
· The current market is in a low liquidity stock game phase, with structural repair still in progress.
· Long-term capital is being accumulated, derivative short-side risk is accumulating, gradually entering a structural deflation phase with left-side convergence.
On-chain Short-term Observation:
1. Risk metrics are in the green zone, reducing derivative risk.
2. New active addresses are relatively low.
3. Market sentiment rating: Neutral.
4. Net inflows on exchanges show a small amount of BTC and ETH entering.
5. Global purchasing power is in a declining state, with a slight outflow of stablecoin purchasing power.
6. Off-chain transaction data indicates buying interest at 70000; selling interest at 88000.
7. The probability of not breaking below 70000-75000 in the short term is 70%; with a 60% probability of not breaking above 80000-85000 in the short term.
• Market Tone:
For BTC, the market's panic selling has not truly fermented, with only a small number of chips choosing to realize losses. This week, the market is still heavily influenced by news, so short-term investors should exercise patience and wait for news to develop or for true emotional extremes before making trades.
Risk Reminder:
The above is all market discussion and exploration and does not provide directional views for investment; please be cautious and guard against market black swan risks.
This article is a submission and does not represent the views of BlockBeats.
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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk
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) 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.
(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.
(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.
(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.
(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.
(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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China's Central Bank and Eight Other Departments' Latest Regulatory Focus: Key Attention to RWA Tokenized Asset Risk
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) 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.
(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.
(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.
(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.
(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.
(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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