The Shanghai No. 2 Intermediate People's Court of China stated that simply holding or trading cryptocurrency by an individual is generally not considered a crime of illegal business operations.

A seminar on criminal trials, jointly hosted by the China Criminal Law Research Association, the Shanghai High People's Court, the Shanghai No. 2 Intermediate People's Court, and the Law School of Renmin University of China, focused on the theme of "Unified Application of Law in Virtual Currency-Related Crimes." The seminar's content is summarized as follows: The determination of "subjective knowledge" in virtual currency money laundering crimes should be based on a comprehensive assessment to prevent objective attribution of guilt. The determination of the types of conduct and standards for completion in virtual currency money laundering crimes involves: first, accurately grasping the essential nature of the crime—"concealing or disguising the source and nature of criminal proceeds and profits"; second, committing the acts of concealing or disguising criminal proceeds and profits as stipulated in the elements of money laundering crimes constitutes a completed crime; and third, strictly cracking down on money laundering crimes according to law to resolutely safeguard national financial security. Regarding the determination of illegal business operations involving virtual currencies, if the conduct does not possess the characteristics of business operations and is merely personal holding or trading of virtual currency, it is generally not considered illegal business operations. However, if the perpetrator knowingly assists others in illegally buying or selling or indirectly buying and selling foreign exchange through virtual currency exchange, and the circumstances are serious, they should be considered an accomplice to the crime of illegal business operations.