The regulation of digital financial assets has been a topic of discussion for many countries over the last decade. China is among the world leaders in the digitalization and blockchain technologies. Under the “one country, two systems,” two different approaches to the digital financial assets have been implemented in the PRC. Although the COVID-19 pandemic has stimulated many investors to diversify their investment portfolios to include digital financial assets, the People’s Bank of China has not changed its prohibitive position on tokens and cryptocurrencies and even launched a campaign against miners and crypto exchanges. Macau and Taiwan have also prohibited initial coin offerings and the transfer of cryptocurrencies due to the risks of money laundering connected with the citizens of mainland China. Macau, Taiwan, and the Monetary Authority of Hong Kong have implemented less stringent regulations of digital financial assets. Comparative analysis demonstrates that Hong Kong acts as an intermediary for China to the digital financial assets.

1. Introduction
2. Cryptoasset Regulation in Mainland China
3. Cryptoassets Ban in Macau
4. Cryptoassets Regulation in Taiwan
5. Hong Kong as a Crypto Bridgeto Mainland China
6. Comparative Overview of Cryptoassets Regulations
7. Conclusion
References

• Aleksandr P. Alekseenko(Associate Professor of Saint-Petersburg University (Chair of Commercial Law). Ph.D. in Law (Ural State U.))