Over the past few days, Hainan Huatie has suddenly become a hot topic in both the Web3 and A-share communities.

On one hand, the floor price of its "Wasp Brother NFT" surged from 200 yuan to nearly 15,000 yuan in just three days, dominating discussions in the digital collectibles space. On the other, the company announced the completion of its first 10-million-yuan non-financial RWA (Real World Asset) product issuance, partnering with the well-known licensed Web3 firm Weiyi Digital. To many uninformed observers, this appears to signal a "listed company venturing into Web3," positioning itself as a model for "on-chain assets + equity dividends."

While outsiders may see spectacle, insiders recognize the nuances. Hainan Huatie’s seemingly groundbreaking moves—from NFTs to RWA—are in fact treading the fine line of legal and regulatory boundaries.

From a legal perspective, this is not a compliance pilot worth encouraging but rather a potential case study for future risks.

From NFT to RWA: What Exactly Is Hainan Huatie Doing?
First, let’s examine the NFT—the "Wasp Brother."

This NFT is not just a simple digital collectible but is tied to a three-year "brand promotion revenue" entitlement. According to the company’s official rules released in July, users who activate and lock the NFT via the "Huatie Big Wasp" WeChat mini-program between July 26 and August 1 automatically become "brand ambassadors." They are then entitled to annual cash rewards from 2025 to 2027, equivalent to the dividends from 50,000 Hainan Huatie shares.

The key aspects of this model are:

• The reward amount is linked to the company’s stock dividends.

• Locking the NFT is a prerequisite, requiring annual reactivation.

• The company reserves the unilateral right to interpret or revoke eligibility.

• Users risk losing eligibility if they post "brand-damaging" content online.

In short, this isn’t a collectible purchase but an unequal contract where users trade behavioral compliance for potential rewards.

Next, let’s look at the RWA project. Here, Hainan Huatie attempts to leverage the industry narrative of "asset tokenization" to push boundaries.

The company claims to have partnered with licensed Web3 firm Weiyi Digital to issue its first batch of non-financial RWA products worth 10 million yuan.

Unlike typical RWAs tied to real estate or receivables, this product doesn’t involve ownership transfer. Instead, it digitally maps the "usage rights + operational rights" of the company’s equipment, creating a structure akin to a "digital membership card." These cards can be traded or consigned on-chain, granting holders certain usage benefits or profits.

The highlights of this RWA model are:

• Digitization of usage rights, not asset fragmentation or securitization.

• No ownership transfer, thus avoiding securities regulation.

• On-chain asset registration, but offline processes govern benefit redemption.

• A hybrid model blending "equipment leasing + Web3 entitlement cards" for market experimentation.

In plain terms, these "digital cards" resemble virtual leasing vouchers for industrial equipment, repackaged as "RWA" with on-chain verification and tradability. Combined with the NFT’s brand promotion mechanism, Hainan Huatie has built a complex structure: "asset-heavy operations + on-chain digital rights + user-driven profit-sharing."

At first glance, this setup seems quintessentially Web3—digitizing assets, incentivizing users, and sparking short-term buzz. The problem? Every "innovation" here skirts regulatory red lines, deliberately blurring legal boundaries.

This Isn’t Innovation—It’s Regulatory Arbitrage
While Hainan Huatie’s approach to digital asset operations shows creativity, its non-native Web3 roots make it prone to "old wine in new bottles" pitfalls.

In my view, this model has at least three major flaws.

1. Ambiguous Rights Structure: Payouts Depend on Corporate Whim, Leaving Users Powerless
Whether it’s NFT-based "dividend-equivalent rewards" or RWA-linked "equipment usage rights," redemption relies not on legal contracts or smart contracts but on company policies, a mini-program, and a payment account registration. This is essentially unilateral corporate control: rewards are discretionary, with no recourse for users if payouts stop or rules change.

Such a structure constitutes neither an enforceable civil contract nor a securities or consumer protection mechanism. Users have no avenue for appeal in cases of违约,资格取消, or rule changes.

2. Merging "Speech Policing + Profit Incentives" Violates Community Governance
Hainan Huatie’s rules explicitly state that users spreading "negative remarks" online risk losing entitlements. Framing "speech control" as NFT reward terms masquerades as "brand protection" but systematically suppresses free expression.

Web3 champions freedom and autonomy—not "praise-for-pay" schemes. If emulated, digital collectibles could devolve into corporate PR tools rather than organic cultural or communal expressions.

3. RWA’s Blurred Financial Boundaries Risk "Disguised Fundraising"
By tokenizing usage rights (not ownership) and bundling them with dividends, Hainan Huatie sidesteps regulatory classification—for now. It avoids some hallmarks of securities (public fundraising, promised returns, lack of licensing) but remains functionally close to "quasi-financial products."

Scaling up, introducing multi-tiered benefits, or enabling secondary trading could easily trigger "disguised financial product" allegations, even crossing into illegal deposit-taking territory. Amid tightening financial oversight, such "cross-sector innovation" could invite severe repercussions if controversies or user disputes arise.

Mankun Law’s Warning
The core issue with Hainan Huatie’s campaign isn’t its bold marketing but its fragile legal and compliance foundations.

For Users:

• Your NFT isn’t a property right or equity certificate—just a revocable "company-promised benefit."

• Rule changes, corporate losses, or PR crises could render your "dividend-equivalent" worthless.

• No legal safeguards or enforceability exist; risks hinge entirely on trusting the company.

For Web3 Entrepreneurs:

• Don’t treat this as an industry benchmark. It solves visibility, not legal clarity or user trust.

• RWAs should start with non-financial structures but must address compliance, contracts, and governance.

• NFTs can enhance branding but mustn’t replace contracts, shares, or rights—or risk backlash.

Conclusion: Boundary-Pushing Isn’t Progress
Hainan Huatie’s campaign is undeniably novel and viral. But novelty ≠ correctness, and virality ≠ stability.

As a Web3 compliance lawyer, I welcome listed companies’ innovative experiments—provided they’re legal, transparent, and sustainable. Wrapping old systems, logic, and unequal user relationships in "Web3 packaging" isn’t progress.

Testing regulatory limits isn’t breakthrough—it’s playing with fire.

Over the past few days, Hainan Huatie has suddenly become a hot topic in both the Web3 and A-share communities.

On one hand, the floor price of its "Wasp Brother NFT" surged from 200 yuan to nearly 15,000 yuan in just three days, dominating discussions in the digital collectibles space. On the other, the company announced the completion of its first 10-million-yuan non-financial RWA (Real World Asset) product issuance, partnering with the well-known licensed Web3 firm Weiyi Digital. To many uninformed observers, this appears to signal a "listed company venturing into Web3," positioning itself as a model for "on-chain assets + equity dividends."

While outsiders may see spectacle, insiders recognize the nuances. Hainan Huatie’s seemingly groundbreaking moves—from NFTs to RWA—are in fact treading the fine line of legal and regulatory boundaries.

From a legal perspective, this is not a compliance pilot worth encouraging but rather a potential case study for future risks.

From NFT to RWA: What Exactly Is Hainan Huatie Doing?
First, let’s examine the NFT—the "Wasp Brother."

This NFT is not just a simple digital collectible but is tied to a three-year "brand promotion revenue" entitlement. According to the company’s official rules released in July, users who activate and lock the NFT via the "Huatie Big Wasp" WeChat mini-program between July 26 and August 1 automatically become "brand ambassadors." They are then entitled to annual cash rewards from 2025 to 2027, equivalent to the dividends from 50,000 Hainan Huatie shares.

The key aspects of this model are:

• The reward amount is linked to the company’s stock dividends.

• Locking the NFT is a prerequisite, requiring annual reactivation.

• The company reserves the unilateral right to interpret or revoke eligibility.

• Users risk losing eligibility if they post "brand-damaging" content online.

In short, this isn’t a collectible purchase but an unequal contract where users trade behavioral compliance for potential rewards.

Next, let’s look at the RWA project. Here, Hainan Huatie attempts to leverage the industry narrative of "asset tokenization" to push boundaries.

The company claims to have partnered with licensed Web3 firm Weiyi Digital to issue its first batch of non-financial RWA products worth 10 million yuan.

Unlike typical RWAs tied to real estate or receivables, this product doesn’t involve ownership transfer. Instead, it digitally maps the "usage rights + operational rights" of the company’s equipment, creating a structure akin to a "digital membership card." These cards can be traded or consigned on-chain, granting holders certain usage benefits or profits.

The highlights of this RWA model are:

• Digitization of usage rights, not asset fragmentation or securitization.

• No ownership transfer, thus avoiding securities regulation.

• On-chain asset registration, but offline processes govern benefit redemption.

• A hybrid model blending "equipment leasing + Web3 entitlement cards" for market experimentation.

In plain terms, these "digital cards" resemble virtual leasing vouchers for industrial equipment, repackaged as "RWA" with on-chain verification and tradability. Combined with the NFT’s brand promotion mechanism, Hainan Huatie has built a complex structure: "asset-heavy operations + on-chain digital rights + user-driven profit-sharing."

At first glance, this setup seems quintessentially Web3—digitizing assets, incentivizing users, and sparking short-term buzz. The problem? Every "innovation" here skirts regulatory red lines, deliberately blurring legal boundaries.

This Isn’t Innovation—It’s Regulatory Arbitrage
While Hainan Huatie’s approach to digital asset operations shows creativity, its non-native Web3 roots make it prone to "old wine in new bottles" pitfalls.

In my view, this model has at least three major flaws.

1. Ambiguous Rights Structure: Payouts Depend on Corporate Whim, Leaving Users Powerless
Whether it’s NFT-based "dividend-equivalent rewards" or RWA-linked "equipment usage rights," redemption relies not on legal contracts or smart contracts but on company policies, a mini-program, and a payment account registration. This is essentially unilateral corporate control: rewards are discretionary, with no recourse for users if payouts stop or rules change.

Such a structure constitutes neither an enforceable civil contract nor a securities or consumer protection mechanism. Users have no avenue for appeal in cases of违约,资格取消, or rule changes.

2. Merging "Speech Policing + Profit Incentives" Violates Community Governance
Hainan Huatie’s rules explicitly state that users spreading "negative remarks" online risk losing entitlements. Framing "speech control" as NFT reward terms masquerades as "brand protection" but systematically suppresses free expression.

Web3 champions freedom and autonomy—not "praise-for-pay" schemes. If emulated, digital collectibles could devolve into corporate PR tools rather than organic cultural or communal expressions.

3. RWA’s Blurred Financial Boundaries Risk "Disguised Fundraising"
By tokenizing usage rights (not ownership) and bundling them with dividends, Hainan Huatie sidesteps regulatory classification—for now. It avoids some hallmarks of securities (public fundraising, promised returns, lack of licensing) but remains functionally close to "quasi-financial products."

Scaling up, introducing multi-tiered benefits, or enabling secondary trading could easily trigger "disguised financial product" allegations, even crossing into illegal deposit-taking territory. Amid tightening financial oversight, such "cross-sector innovation" could invite severe repercussions if controversies or user disputes arise.

Mankun Law’s Warning
The core issue with Hainan Huatie’s campaign isn’t its bold marketing but its fragile legal and compliance foundations.

For Users:

• Your NFT isn’t a property right or equity certificate—just a revocable "company-promised benefit."

• Rule changes, corporate losses, or PR crises could render your "dividend-equivalent" worthless.

• No legal safeguards or enforceability exist; risks hinge entirely on trusting the company.

For Web3 Entrepreneurs:

• Don’t treat this as an industry benchmark. It solves visibility, not legal clarity or user trust.

• RWAs should start with non-financial structures but must address compliance, contracts, and governance.

• NFTs can enhance branding but mustn’t replace contracts, shares, or rights—or risk backlash.

Conclusion: Boundary-Pushing Isn’t Progress
Hainan Huatie’s campaign is undeniably novel and viral. But novelty ≠ correctness, and virality ≠ stability.

As a Web3 compliance lawyer, I welcome listed companies’ innovative experiments—provided they’re legal, transparent, and sustainable. Wrapping old systems, logic, and unequal user relationships in "Web3 packaging" isn’t progress.

Testing regulatory limits isn’t breakthrough—it’s playing with fire.