Despite China’s continued ban on digital currencies, cryptofever hasn’t stopped the country’s investors and online asset exchanges from seeking loopholes and padding their pockets.

Huobi.Pro, a global digital asset exchange headquartered in Singapore, unveiled the Huobi Autonomous Digital Asset Exchange (HADAX) on Feb. 12. For its first around, HADAX listed 60 proposed cryptocurrencies. Huobi allowed investors to vote using digital coins called Huobi Tokens (HTs) for their favorites from the HADAX list. Each vote cost one-tenth of an HT, and each user was able to cast up to 1 million votes. The 10 cryptocurrency projects that received the most votes by Feb. 28 were given the opportunity to file for an ICO — an initial coin offering.

The fledgling cryptocurrency that received the most votes was proposed as part of a blockchain-backed car database called “Engine.” The project’s 31,951,548 votes are equivalent to $4.8 million at the current exchange rate for HT — which at time of publication was two-thirds of a dollar.

With HADAX, Huobi has taken a different tack from previous listings on its website. It no longer aids investors by “evaluating the investment value of the projects”; instead, it will merely “verify their authenticity and legitimacy” to provide some degree of peace of mind.

The next round of voting from a new crop of cryptocandidates will begin on March 12.

Any votes for projects that don’t make the final top 10 can be fully refunded, Huobi founder Li Lin told The Paper, Sixth Tone’s sister publication. After graduating from Tsinghua University and spending a stint with Silicon Valley tech company Oracle, Li founded Huobi Technology Co. Ltd. in Beijing in 2013.

Huobi would not comment on what it plans to do with the money it earns from investors’ votes.

Li Gangqiang, the founder of blockchain-based trading platform ShareX, told China Business Journal that for a new cryptocurrency to be issued, the company backing it needs to pay for a listing. Apart from that, the company sometimes courts the exchange, in hopes that it will offer promotions to attract investors. In addition, the exchange generally asks to purchase some proportion of the total coins available at a low investment rate.

On Jan. 20, Huobi announced that it would issue exactly 500 million Huobi Tokens. “[We] promise never to increase this number, and only to distribute them through gifting rather than selling,” the company explained.

But the line Huobi draws between “gift” and “sell” is a fine one — and deliberately so. The company advertises a package of points that can be used to pay trading charges on Huobi.Pro for 100 USDT, or “tether U.S. dollars,” with one USDT being pegged to $1. The catch is that each points package comes with a “gift” of 50 HTs.

That extra “T” in “USDT” is crucial: It means obtaining HTs is strictly a coin-to-coin operation, keeping it on the fair-not-foul side of the increasingly strict cryptocurrency regulations being implemented by countries all over the world. China has prohibited currency-to-cryptocurrency trading and ICOs since Sept. 4 of last year. But investors can use domestic mobile payment platforms Alipay and WeChat to buy USDTs, which can then be redeemed for HTs through the company’s points packages.

But not everyone is convinced that this purchasing behavior will remain in the legal clear for long. “With such transactions, there is a risk of breaking the [foreign exchange] law,” Liu Xinyu, a senior partner at Dentons Law Firm in Shanghai, told The Paper. Liu added that platforms like Alipay and WeChat are often used to skirt foreign exchange controls for monitoring or restricting the transfer of large amounts of money overseas.

Indeed, official scrutiny of exchanges has tightened in the wake of the ban, with several being completely shut down. As a result, some cryptocurrency investors have turned to secure-messaging app Telegram to conduct their business, and exchanges will often provide a link for investors to their own official Telegram chat groups. On Friday, there were over 45,000 members in Huobi’s Telegram group.

On Jan. 26, the National Internet Finance Association of China reiterated a warning to investors not to get involved in trading cryptocurrencies.

“There is a universal absence of standards internationally,” the association wrote. “Currently, overseas exchange planforms have hidden risks including system security, market manipulation, and money laundering.”

Clarification: This story has been updated to reflect that obtaining Huobi Tokens — and not the Huobi.Pro website more generally — is a coin-to-coin operation.

Editor: David Paulk.

(Header image: E+/VCG)