Introduction
Today, a friend forwarded me an article by my fellow lawyer, Zhang Suhang, titled "Airdrop-Fighting Studio Busted! 5 Million Yuan in Illegal Gains Confiscated!", wanting me to analyze whether airdrop-fighting is really that risky. I carefully read Attorney Zhang's article and felt that as a fellow cryptocurrency lawyer, it was necessary to combine my own practical experience, my understanding of circumventing internet censorship (i.e., "scientific internet access"), airdrop-fighting, and my long-term experience dealing with public security organs to write an article analyzing this matter.

I. Case Overview
According to Attorney Zhang's article, he recently handled a case involving a studio that was "forced" to commit fraud. A total of three people embezzled 3 million yuan in a year. In legal terms, "forced" usually means "forced into a position," implying criminal activity. However, Attorney Zhang's article states that his clients were not involved in any criminal offenses related to virtual currency, but they violated relevant laws regarding "scientific internet access." Therefore, they were fined 5 million yuan in illegal gains, had their mobile phones and computers confiscated, and were fined 10,000 yuan.
... Here's a small question: if someone made 3 million in a year, why was 5 million confiscated? Attorney Liu speculates that they might have made the money over a year. However, Attorney Zhang didn't specify, so we shouldn't speculate. Let's assume for now that the person made a total of 5 million in airdrops. II. Is circumventing the Great Firewall illegal? Wrong! According to Attorney Zhang, using a VPN to circumvent the Great Firewall is an administrative violation. The public security authorities can fine the person up to 15,000 yuan and confiscate any illegal gains (if any). The basis is Article 6 of the "Interim Provisions on the Administration of International Connections of Computer Information Networks": "Computer information networks directly connecting to the international internet must use the international access channels provided by the Ministry of Posts and Telecommunications' national public telecommunications network. No unit or individual may establish or use other channels for international connections." My view is completely opposite to Attorney Zhang's. The act of simply using a VPN to bypass the Great Firewall does not violate any current laws, regulations, departmental rules, or other normative documents in my country. Using a VPN does not constitute establishing one's own channel for international connections; even when using a VPN, it still uses the international access channels provided by the national public telecommunications network (such as the channels provided by the three major domestic telecom operators). In essence, a VPN merely circumvents the Great Firewall's blocking of certain overseas IPs (such as Google websites). For detailed technical and legal explanations, please refer to my article from several years ago, "Are there any legal risks in using VPNs and other tools to bypass the Great Firewall?" The key issue here isn't whether a VPN was used; no one has the right to say that using a VPN is illegal. The crucial question is what was done after using the VPN. If you used Google to search academic papers or Instagram to follow celebrities, a law-abiding police officer certainly wouldn't say you're breaking the law. However, if you used a VPN to perform the following actions, that's a different story (excerpt from the Cybersecurity Law). So, the core question is: Is exploiting airdrops illegal? If it's illegal, then the police's confiscation of the money seems reasonable; if it's not illegal, the police can't just confiscate the money earned from airdrops based solely on the so-called "illegality of circumventing the Great Firewall." III. Is airdrop circumventing illegal? Regarding airdrop circumventing, I've actually discussed it in many previous videos. I won't go into lengthy analysis here, but my conclusion is that airdrop circumventing is not illegal. Previously, a programmer in Chengde had over 1 million yuan of his income confiscated for circumventing the Great Firewall to write code for an overseas company. However, the programmer filed an administrative review, and the outcome is unknown (friends who know the details can contact Attorney Liu). At the time, I also wrote an article analyzing "Programmer's Business Income Confiscated for 'Circumventing the Great Firewall': Is Scientific Internet Access Really Safe?". Another case is "Using VPNs to invest in cryptocurrencies resulted in arrest; is cryptocurrency trading illegal?", but it doesn't mention the specific administrative penalties. In both articles, I stated my opinion: writing code for overseas companies is not illegal, nor is cryptocurrency trading. Taking airdrops as an example, such as the recently popular Binance Alpha, one common method is to use multiple accounts to exploit airdrops, or to use cheats to "millisecond-level" exploitation. However, whether it's an overseas cryptocurrency exchange like Binance, or other decentralized exchanges, wallets, public chains, etc., as long as these platforms issue cryptocurrencies, according to China's "9.4 Announcement" in 2017 and "9.24 Notice" in 2021, they all constitute "illegal financial activities." However, this only applies to the platforms; users using these platforms are not subject to any legal consequences. Based on my country's regulatory documents on cryptocurrencies or other laws and regulations, it cannot be concluded that "exploiting airdrops is illegal." If someone believes it's illegal, they can point out which specific laws or regulations were violated; if not, then it's generally considered permissible unless prohibited by law. Of course, if you are a compliant domestic company conducting legitimate business protected by law, then please don't easily try to exploit loopholes. Currently, there are cases where people have been convicted of theft or illegally obtaining computer information system data for using technical means to obtain coupons from platforms like Lalamove and KFC. Therefore, my personal opinion is: since circumventing the Great Firewall itself is not illegal, and exploiting airdrops is not illegal, then why is it said that exploiting airdrops through circumvention is illegal? I'm not writing this article to question Attorney Zhang, but to provide a different perspective for people like my friend who are anxious about this issue. There are wrongful convictions in criminal cases, not to mention wrongful administrative penalties. Therefore, if Attorney Zhang's client is indeed fined 5 million yuan, there are many other remedies that can be attempted to recover their losses. Given the Ministry of Public Security's explicit ban on deep-sea fishing, I believe there are few people who would dare to disregard the consequences and break the law in handling cases.