Analysis: How do countries that do not ban Bitcoin and its derivatives regulate them? (AI Translation)
Listen to the full version


文|姚前
By Yao Qian
2024年1月,美国证券交易委员会(SEC)批准首批11只比特币现货交易所基金(ETF)上市,短短两个月内,资金净流入约100亿美元;对比之下,第一只上市的黄金ETF用了三年才达到这一水平。这段时间ETF基金持有的比特币大约为18万枚,同期矿工生产5.5万枚比特币。据彭博社报道,目前全球所有比特币现货ETF共持有约110万枚比特币,占比特币总供应量5.8%。从交易量看,目前这些ETF基金的日均比特币现货交易量约为40亿—50亿美元,占全球加密货币交易所总交易量的15%—20%。
In January 2024, the U.S. Securities and Exchange Commission (SEC) approved the listing of the first 11 Bitcoin spot exchange-traded funds (ETFs), attracting approximately $10 billion in net inflows within just two months. In contrast, it took three years for the first gold ETF listed to reach this level. During this period, the ETFs held about 180,000 Bitcoins, while miners produced 55,000 Bitcoins. According to Bloomberg, currently, all Bitcoin spot ETFs globally hold about 1.1 million Bitcoins, accounting for 5.8% of the total Bitcoin supply. In terms of trading volume, these ETFs have an average daily Bitcoin spot trading volume of approximately $4 billion to $5 billion, representing 15% to 20% of the total global cryptocurrency exchange trading volume.
市场预期,比特币现货ETF的资金流入有望以渐进、持续的方式吸收现货,对比特币的现货价格产生推动效应。与此同时,比特币矿工奖励将于2024年4月发生第四次减半,从6.25个比特币降为3.125个比特币,意味着比特币发行量从每天约900个,降至每天约450个。减半之后,比特币的月产量约为1.35万个,年产量约为16.43万个;按照近期比特币平均价格每个6.5万美元计算,年产值约为100亿美元。有测算认为,假定基于美国比特币现货ETF的新流入速度从2月的60亿美元逐步放缓,加之比特币发行减半的影响,比特币价格仍会冲高。
Market expectations suggest that the inflow of funds into Bitcoin spot ETFs is likely to absorb spot holdings in a gradual and sustained manner, thereby exerting a positive effect on the spot price of Bitcoin. At the same time, Bitcoin miners' rewards are set to undergo their fourth halving in April 2024, decreasing from 6.25 Bitcoins to 3.125 Bitcoins. This means that the daily issuance of Bitcoin will drop from approximately 900 to about 450. Following the halving, the monthly production of Bitcoin will be around 13,500 units, with an annual output of approximately 164,300 units; based on the recent average price of $65,000 per Bitcoin, this equates to an annual production value of about $10 billion. Some estimates suggest that assuming the new inflow rate for U.S.-based Bitcoin spot ETFs gradually slows down from February's $6 billion and considering the impact of the halving on Bitcoin issuance, prices for Bitcoin are still expected to surge.
比特币现货ETF产品的热卖以及币价的大幅波动,引发了市场高度关注,赞同和反对的声音都不绝于耳。
The brisk sales of Bitcoin spot ETF products and the significant price volatility have attracted heightened market attention, with both voices of support and opposition being incessantly heard.

- DIGEST HUB
- In January 2024, the U.S. SEC approved the first 11 Bitcoin spot ETFs, attracting approximately $10 billion in net inflows within two months, a milestone that took the first gold ETF three years to achieve. These ETFs held about 180,000 Bitcoins during this period while miners produced 55,000 Bitcoins.
- Global Bitcoin spot ETFs hold around 1.1 million Bitcoins, accounting for 5.8% of the total supply, with daily trading volumes between $4 billion and $5 billion, representing 15%-20% of global cryptocurrency exchange volumes. The upcoming Bitcoin halving in April 2024 is expected to reduce daily production from about 900 to approximately 450 Bitcoins.
- The approval and success of Bitcoin spot ETFs have sparked significant attention and debate among supporters and critics alike. Supporters view Bitcoin as a hedge against inflation and a complement to traditional financial systems, while critics raise concerns over price manipulation, money laundering risks, asset custody challenges, and potential disruptions to cross-border financial regulation.
In January 2024, the U.S. Securities and Exchange Commission (SEC) made a significant move by approving the listing of the first 11 Bitcoin spot exchange-traded funds (ETFs), which quickly attracted around $10 billion in net inflows, a milestone that took the first gold ETF three years to achieve. This rapid influx highlights the growing acceptance and demand for cryptocurrency-based financial products among traditional investors. These Bitcoin ETFs held approximately 180,000 Bitcoins, contributing to a global total of about 1.1 million Bitcoins held by all Bitcoin spot ETFs, representing 5.8% of the total Bitcoin supply [para. 1].
The market anticipates that these inflows will continue to absorb spot holdings gradually, positively impacting Bitcoin's spot price. This expectation comes at a time when Bitcoin miners are preparing for their fourth halving event in April 2024, which will reduce their rewards and consequently decrease daily Bitcoin issuance from about 900 to roughly 450 units. Despite potential slowdowns in new inflow rates and the halving event reducing issuance, projections still foresee a surge in Bitcoin prices [para. 2].
The introduction of Bitcoin spot ETFs has sparked diverse opinions within the financial community. Supporters view it as an evolution of financial products catering to demand-side dynamics and see Bitcoin as an innovative hedge against inflation due to its scarcity and fixed supply mechanism. They argue that cryptocurrencies offer alternatives for value storage akin to digital gold and can enhance financial system reliability by providing services to underdeveloped regions without relying on large financial institutions [para. 3][para. 4]. On the payment front, digital stablecoins are gaining traction in the United States, with significant market services now comparable to traditional banking methods. Notably, Tether's USDT has emerged as a dominant player with a substantial holding of U.S. Treasury bonds [para. 5].
However, critics raise several concerns regarding Bitcoin and its related products, including risks associated with price manipulation due to high concentration among top investors and miners; money laundering facilitated by the anonymity and decentralization of transactions; asset safekeeping challenges highlighted by incidents like FTX's collapse; and potential disturbances in cross-border capital regulation due to massive fund movements through unregulated channels [para. 6].
In response to these challenges, regulatory bodies worldwide have adopted various strategies ranging from strict regulation without outright bans to complete prohibition of Bitcoin-related activities. The U.S., for instance, has allowed participation in cryptocurrency investments through both on-exchange products like futures ETFs approved by SEC and off-exchange products such as Grayscale's compliant trust product despite concerns over market manipulation risks [para. 7][para. 8]. To address these issues further, regulatory measures have been enhanced focusing on market manipulation regulation within cryptocurrency sectors; strengthening anti-money laundering regulations particularly for decentralized finance models; and tightening oversight on cryptocurrency exchanges requiring registration or exemption compliance [para. 9].
This evolving regulatory landscape underscores efforts to balance maximizing benefits while minimizing risks associated with cryptocurrencies like Bitcoin. As this sector continues to grow and integrate into mainstream finance, ongoing dialogue between innovators, investors, regulators will be crucial in shaping its future direction.
Yao Qian emphasizes that this analysis represents personal academic views rather than official positions from any institution he is affiliated with [para. 10].
- BlackRock
贝莱德 - Summary: According to the article, BlackRock is mentioned as having submitted an application for a Bitcoin spot ETF to the U.S. Securities and Exchange Commission (SEC) in June 2023. As the world's largest asset management firm, with assets under management exceeding $10 trillion, BlackRock's involvement in the Bitcoin spot ETF application significantly raised expectations within the industry for the potential approval of such ETFs. The submission of a supervision sharing agreement by BlackRock to the SEC was seen as a key factor that could alleviate the SEC’s concerns about manipulation risks associated with Bitcoin. This agreement supports the SEC in obtaining information on Bitcoin spot market trading activities, clearing activities, and customer identities, which could help detect and prevent fraud, manipulation, and other improper behaviors.
- Grayscale Investments
灰度投资公司 - Summary: Grayscale Investments is mentioned in the article as having launched the world's first compliant Bitcoin trust product, known as the Grayscale Bitcoin Trust (GBTC), in September 2013. Unlike Bitcoin ETFs, Bitcoin trust funds like GBTC cannot be exchanged for Bitcoin and trade on over-the-counter (OTC) trading systems in the United States. This means they often lack a balancing mechanism with spot prices, leading to potential significant premiums or discounts to the actual price of Bitcoin. Grayscale Investments is highlighted as an example of a financial institution offering an alternative way for investors to gain exposure to Bitcoin without directly holding the cryptocurrency, although it comes with its own set of liquidity constraints compared to spot ETFs.
- Binance
币安 - Summary: According to the article, Binance, a cryptocurrency exchange, has been under investigation by the U.S. Department of Justice (DOJ) for potential charges related to money laundering conspiracies and violations of criminal sanctions. In December 2023, Binance faced multiple charges including money laundering and conspiracy to conduct an unlicensed money transmitting business. Eventually, Binance reached a settlement with the DOJ and was fined $4.3 billion.
- FTX Exchange
FTX虚拟资产交易所 - Summary: According to the article, FTX Exchange experienced a significant downfall in November 2022. The exchange was found to have misappropriated company funds, engaging in aggressive investment strategies that resulted in substantial losses. Additionally, it was revealed that FTX had used company funds to purchase personal real estate for its executives. This misuse of funds led to a liquidity crisis when users began withdrawing their assets en masse, ultimately resulting in the exchange's inability to cover these withdrawals and leading to bankruptcy. This event caused significant losses for renowned investment institutions such as Sequoia Capital, SoftBank, and Temasek Holdings.
- Meta Platforms, Inc.
Meta公司 - Summary: According to the article, Meta Platforms, Inc. is involved in the digital currency space through its Diem stablecoin project. The company's engagement in this area highlights its interest and investment in the evolving landscape of digital currencies and financial technologies. This involvement represents a significant move by a major tech company into the realm of digital finance, indicating a broader trend of technology companies exploring and integrating financial services, including cryptocurrencies and stablecoins, into their ecosystems.
- PayPal
PayPal - Summary: According to the article, in August 2023, the American payment giant PayPal announced the launch of its stablecoin, PayPal USD (PYUSD), becoming the first major technology company to issue a stablecoin.
- Tether
Tether - Summary: According to the article, Tether (USDT) is a digital stablecoin that plays a significant role in the global cryptocurrency market. As of March 2024, Tether's USDT has a market value of approximately $994.4 billion, making it a dominant force among digital stablecoins, particularly those pegged to the US dollar. The article also highlights that by September 2023, Tether held $72.5 billion in U.S. Treasury securities, positioning it as the world's 22nd largest holder of U.S. Treasuries. This surpasses several countries such as the UAE, Mexico, Australia, and Spain in terms of U.S. Treasury holdings.
- Circle
Circle - Summary: According to the article, Circle is a company that issues a digital stablecoin named USDC (USD Coin). As of March 2024, USDC has a market value of approximately 276.1 billion USD, making it one of the dominant dollar stablecoins in the global digital currency market.
- Chicago Mercantile Exchange (CME)
美国芝加哥商品交易所 - Summary: The Chicago Mercantile Exchange (CME) is mentioned in the article as having launched cash-settled Bitcoin futures in December 2017. This move allowed traditional investors to gain exposure to Bitcoin's price movements without the need to directly hold the cryptocurrency. The introduction of Bitcoin futures by CME was a significant step towards integrating cryptocurrencies into the mainstream financial system, providing a regulated and standardized way for investors to speculate on or hedge against the price changes of Bitcoin.
- Coinbase
Coinbase - Summary: According to the article, Coinbase was fined $6.5 million by the U.S. Commodity Futures Trading Commission (CFTC) for reporting false, misleading, or inaccurate information about transactions and for wash trading. This action is part of the broader regulatory efforts to oversee and enforce compliance within the cryptocurrency market, highlighting the challenges and scrutiny that crypto exchanges face under U.S. regulations.
- EtherDelta
EtherDelta - Summary: EtherDelta is mentioned in the article as a decentralized cryptocurrency exchange that was penalized by the U.S. Securities and Exchange Commission (SEC) for operating without proper registration. Specifically, EtherDelta's founder, Zachary Coburn, faced penalties for running an exchange that allowed trading of ERC-20 tokens, which are a type of Ethereum-based token, without registering the platform as a national securities exchange or applying for an exemption from registration. This action by the SEC against EtherDelta and its founder highlights the regulatory body's efforts to enforce compliance with federal securities laws among platforms trading digital assets that may be considered securities.
- January 2024:
- U.S. SEC approves first 11 Bitcoin spot ETFs, attracting $10 billion in net inflows within two months
- April 2024:
- Bitcoin miners' rewards undergo fourth halving, decreasing from 6.25 to 3.125 Bitcoins
- October 2023:
- Paul Brody of EY states Bitcoin's issuance won't increase with rising prices but will gradually cease over time
- March 2024:
- Bitcoin's market value surpasses $13.47 trillion, ranking 8th globally in asset market value
- August 2023:
- PayPal announces launch of its stablecoin PayPal USD (PYUSD)
- December 2023:
- Binance faces charges including money laundering, reaches settlement with U.S. DOJ and fined $4.3 billion
- November 2022:
- FTX cryptocurrency exchange collapses due to misappropriation of funds
- June 2023:
- BlackRock submits application for Bitcoin spot ETF to SEC
- April 2019:
- FATF releases guidance for risk-based approach to virtual assets and VASPs
- March 2018:
- SEC specifies cryptocurrency platforms must register as national securities exchanges or apply for exemption
- 2023:
- SEC investigates Binance for unregistered securities transactions, future of Ethereum spot ETF uncertain due to SEC investigation
- PODCAST
- MOST POPULAR