"Chain on Hainan": Blockchain Applications and Legal Challenges in International Trade

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The vision of transforming Hainan Free Trade Port (FTP) into a "Digital Free Trade Port" has been a strategic priority since its inception. As part of China’s broader reform and innovation agenda, this digital transformation leverages cutting-edge technologies like blockchain to build a globally competitive open economy. In 2019, the Ministry of Industry and Information Technology (MIIT) released an action plan supporting Hainan’s development as a blockchain hub, including cross-border supply chain systems and fostering leading enterprises in the sector. The following year, Hainan’s provincial government announced a series of policies to accelerate blockchain industry growth—launching a 1 billion RMB blockchain industry fund and promoting the “Chain on Hainan” ecosystem.

This initiative positions blockchain at the core of Hainan’s international trade modernization. As noted by Brian Behlendorf, Executive Director of Hyperledger and one of the web’s pioneers, two of the most promising real-world applications for blockchain are supply chain management and trade finance. These domains align perfectly with Hainan’s ambitions to become a model for digital trade innovation.

This article explores how blockchain can revolutionize international trade within Hainan’s regulatory sandbox, examining technological foundations, practical implementations, and key legal considerations. We’ll also highlight opportunities for secure, efficient, and transparent global commerce powered by decentralized technology.


Understanding Blockchain: Core Concepts and Evolution

What Is Blockchain?

Blockchain technology first emerged conceptually in 1991 but only gained traction after Satoshi Nakamoto's 2008 Bitcoin whitepaper introduced it as a functional system. While often conflated with cryptocurrencies, blockchain is the underlying infrastructure, while Bitcoin is one of its earliest applications.

At its core, blockchain is a decentralized peer-to-peer network that uses cryptographic hashing and consensus algorithms to securely record transactions across multiple nodes. Each block contains a timestamped batch of data linked cryptographically to the previous block, forming an immutable chain. This structure ensures data integrity and resistance to tampering—critical features for high-stakes international trade operations.

👉 Discover how blockchain is reshaping global trade efficiency and trust.

Types of Blockchain Networks

To address scalability and privacy concerns in enterprise environments, three main types of blockchains have evolved:

For international trade applications, especially in regulated zones like Hainan FTP, consortium blockchains offer the optimal balance between transparency, control, and compliance.

The Three Generations of Blockchain Development

1. Blockchain 1.0: Digital Currencies

This phase centered on decentralized money systems such as Bitcoin and Ripple (XRP). Unlike traditional fiat currencies, these operate independently of central banks. Ripple, for instance, enables near-instant cross-border payments using XRP as a bridge currency—used by over 200 financial institutions globally.

Central Bank Digital Currencies (CBDCs) represent the sovereign counterpart. China’s Digital Currency Electronic Payment (DC/EP) system exemplifies this trend—a state-backed digital yuan deployed through a two-tier model involving commercial banks. Pilots are already underway in major economic zones, including parts of Hainan.

While private cryptocurrencies face regulatory scrutiny due to anonymity risks (e.g., money laundering), CBDCs promise greater monetary policy control and financial inclusion.

2. Blockchain 2.0: Smart Contracts

The launch of Ethereum in 2015 marked the shift to smart contracts—self-executing code stored on the blockchain that triggers actions when predefined conditions are met.

In international trade, smart contracts can automate processes such as:

These capabilities reduce reliance on intermediaries, minimize errors, and accelerate transaction cycles.

3. Blockchain 3.0: Toward a Smart Society

Beyond finance and logistics, blockchain is converging with AI, IoT, and big data to support intelligent cities and governance systems. In Hainan, this could mean integrated digital identities, automated regulatory reporting, and transparent public services—all underpinned by distributed ledger technology.


Why Blockchain Is Essential for Hainan’s Digital Trade Transformation

Hainan’s goal of becoming a fully digital free trade port demands innovative solutions to long-standing inefficiencies in international commerce.

1. Digitizing Trade Documentation with Immutable Proof of Ownership

Traditional international trade relies heavily on paper-based documentation—bills of lading, certificates of origin, letters of credit—each vulnerable to loss, fraud, or forgery. For example, maritime “bill of lading” disputes—such as releasing cargo without presenting original documents—are common and costly.

Blockchain addresses this by:

Using cryptographic signatures and time-stamping, blockchain ensures that ownership records are accurate, traceable, and resistant to manipulation—critical for building trust in cross-border transactions.

2. Building Trust Without Intermediaries

International trade involves numerous parties: exporters, importers, freight forwarders, insurers, banks, and regulators. Each requires assurance about the authenticity and status of goods and payments.

Currently, trust is established through third-party intermediaries—banks issuing letters of credit, notaries certifying documents, auditors verifying compliance. This adds cost, complexity, and delays.

Blockchain enables trustless verification by allowing all authorized participants to view the same data simultaneously. When data is shared across a permissioned network:

For instance, customs authorities can instantly verify product origins and compliance certifications stored on-chain, reducing inspection times and accelerating clearance.

3. Revolutionizing Cross-Border Payments

Global cross-border payments are projected to reach $30 trillion annually by 2025 (Accenture). Yet current systems remain slow and expensive due to layered banking relationships and legacy infrastructure like SWIFT.

Blockchain offers faster alternatives:

Projects like Ant Group’s blockchain remittance service between Hong Kong and the Philippines demonstrate this potential—transferring funds in three seconds with cost savings up to HK$500 per transaction.

Similarly, China Merchants Bank has developed a blockchain-based cross-border payment platform to streamline corporate transfers.

👉 See how next-gen payment networks are redefining speed and security in global finance.


Real-World Applications: Blockchain in Action

Global Initiatives Driving Trade Digitization

Since 2017, governments and institutions worldwide have piloted blockchain for trade modernization:

These efforts underscore growing consensus: blockchain is not just theoretical—it’s operational.

Case Study: ATA Carnet Digitization via Blockchain

The ATA Carnet is an internationally recognized customs document for temporarily imported goods (e.g., exhibition items). Historically paper-based and manually processed, it suffers from delays and administrative overhead.

The European Commission’s DG TAXUD partnered with the International Chamber of Commerce (ICC WCF) to test blockchain integration with their existing Mercury II e-system. By adding Ethereum-based distributed ledger technology:

The proof-of-concept succeeded in demonstrating that blockchain could overcome prior limitations in electronic customs processing—paving the way for full digitization.

Case Study: Jasper-Ubin Project – Cross-Currency Settlement

A landmark collaboration between Singapore’s MAS and Canada’s central bank tested cross-border payments using Hashed Time-Locked Contracts (HTLCs) on Corda (Canada) and Quorum (Singapore) ledgers.

Using HTLCs:

The project successfully transferred SGD 105 (≈CAD 100) in near real-time—showcasing how multi-currency settlements can occur securely without relying on SWIFT or correspondent banking.


Legal Challenges in Blockchain-Based Trade Systems

Despite technological promise, several legal questions remain unresolved.

Regulatory Treatment of Digital Currencies

China distinguishes clearly between:

Under PBOC guidelines:

Nonetheless, Chinese courts recognize digital assets as property rights under Article 127 of the Civil Code—supporting ownership claims in disputes.

In contrast, U.S. regulation spans multiple agencies:

This fragmented approach creates compliance complexity for global firms operating across jurisdictions.

Legal Status of Smart Contracts

Smart contracts raise fundamental questions:

While self-executing code can automate contractual obligations (e.g., releasing payment upon delivery), it lacks essential elements of traditional contracts: negotiation context, dispute resolution clauses, force majeure provisions.

Therefore, most legal experts view smart contracts as execution mechanisms, not standalone legal agreements. The surrounding contractual intent must still be governed by applicable law—typically embedded off-chain in natural language agreements linked to the on-chain logic.


Frequently Asked Questions (FAQ)

Q: Can blockchain replace traditional banking in international trade?
A: Not entirely—but it can reduce dependency on intermediaries for specific functions like payment settlement and document verification. Banks remain vital for credit issuance, risk assessment, and regulatory compliance.

Q: Is blockchain completely secure against fraud?
A: While highly resistant to tampering due to cryptographic hashing and decentralization, vulnerabilities may exist in smart contract code or endpoint systems (e.g., user devices). Robust auditing and cybersecurity practices are essential.

Q: How does blockchain improve customs clearance?
A: By providing instant access to verified data—such as origin certificates, shipment logs, and compliance records—customs agencies can process declarations faster with reduced need for manual checks.

Q: Does Hainan have specific regulations for blockchain use?
A: While no standalone "blockchain law" exists yet, Hainan’s FTP policies encourage innovation within a controlled environment. Regulatory sandboxes allow testing under supervision before wider rollout.

Q: Can small businesses benefit from blockchain in trade?
A: Yes—especially through shared platforms that lower entry barriers. Digitized documentation and faster financing options make it easier for SMEs to compete globally.

Q: What prevents misuse of data on a trade blockchain?
A: Permissioned networks restrict access to authorized participants only. Data encryption, role-based permissions, and audit trails ensure confidentiality while maintaining transparency where needed.


👉 Explore how you can leverage secure blockchain solutions for international business growth.