“I serve as a multisig manager for a real-world assets (RWA) project, a 3-of-5 wallet. I hold only one private key. How the fundraising plan is set, how it is promoted, and where the money goes are all decided by the project team, and I am not involved. Each time they send over a transaction proposal, I check the address and amount, then click to sign and transfer the tokens out.
Now the project has blown up, and the police have summoned me, saying I constitute an accomplice. I am quite puzzled: I only helped sign, I had no decision-making authority, and I never took a single benefit from the project. Does this still constitute being an accomplice?”
Whether you have decision-making authority is in fact not the key to this question. What determines the finding of liability is your subjective state of knowledge at the time you signed.
I. The role of the multisig manager in the case
The principle of a multisig wallet is not complicated. A so-called 3-of-5 multisig means that five private keys are configured in the wallet, and for any transfer of funds to go out, at least three private keys must separately sign before the transaction will be executed on-chain.
The original design intent is to guard against single-point risk: the loss or theft of one private key will not directly cause the loss of all assets.
And the problem lies precisely here.
Multisig changes “one person has the final say” into “funds can be moved only with the joint authorization of multiple persons,” but it does not change the core legal fact:Signing is authorization; only upon completion of the signature can the funds complete the on-chain transfer.
The division of roles in projects in the industry is roughly as follows:
the project team initiates the proposal, stating to whom the money is transferred and the purpose of the funds; the finance staff check the accounts; the external manager only performs signature confirmation.
Many projects invite external persons to serve as multisig managers for the purpose of creating, externally, the impression of joint fund management and project regularity.
The disagreement between the prosecution and the defense also lies here:
I did not participate in operations, did not formulate plans, and did not engage in promotion; I merely performed procedures—to put it bluntly, I was essentially a signing tool.
However, the investigating authorities' review perspective is entirely different: your signature is an indispensable link in the fund-transfer chain; without your signature, the funds could not have been transferred out.
In criminal law, the assessment of aiding conduct does not require the actor to have participated in project decision-making or held a management position; the focus is on the actual role the conduct played in bringing about the criminal result, and more critically, on whether the actor subjectively knew the nature of the conduct he was assisting.
II. Whether accomplice liability is found turns primarily on subjective knowledge, not on whether one held decision-making authority
In cases of illegal fundraising, the determination of liability for external assisting personnel may refer to two Opinions:
The Opinion of the Supreme People's Court, the Supreme People's Procuratorate, and the Ministry of Public Security onSeveral Issues Concerning the Handling of Criminal Cases of Illegal Fundraising》： To determine whether an actor possessed the criminal intent of illegal fundraising, a comprehensive judgment must be made in light of all evidence in the case, including employment circumstances, professional background, business processes, promotional materials, documentary evidence, and statements, and no single act will be viewed in isolation.
In plain terms: the investigating authorities will not merely count the number of times you signed; the key review is whether you were able to know the nature of the business underlying your signature.
Opinion on Several Issues Concerning the Application of Law in the Handling of Criminal Cases of Illegal Fundraising:
Providing assistance to others in illegally absorbing public funds and collecting agency fees, kickbacks, commissions, percentage-based fees, or other such fees may constitute joint crime;
Where the above-mentioned fees can be returned or paid in a timely manner, a lesser penalty may be imposed in accordance with law; where the circumstances are minor, the penalty may be waived; where the circumstances are obviously minor and the harm is not significant, the matter shall not be treated as a crime.
When applied to the specific role of a multisignature administrator, there are two entirely different paths of assessment:
1. Prior knowledge that the project was engaged in illegal fundraising
You knew that the project was raising funds from unspecified members of the public within the territory, publicly promised fixed returns, and clearly knew that the underlying assets were exaggerated or fictitious, yet you still accepted the role of multisignature administrator and continued to sign for the transfer of the raised funds.
Even if you do not participate at all in project decision-making or in the distribution of returns, there remains a risk of being found to be an accomplice to illegal fundraising.
If the project has already collapsed and the fundraising conduct has already been completed, and you still assist in transferring the tokens at issue in the wallet, the conduct is no longer assisting fundraising, and there is a risk of being found guilty of the crime of concealing or disguising criminal proceeds.
In judicial practice, the vast majority of ordinary multisignature administrators are assessed as upstream accomplices or as committing the crime of concealment and disguise.
2. No actual prior knowledge of the illegal facts
You did not participate in fundraising planning, publicity or promotion, and did not join the project's user-acquisition communities; remuneration was a fixed service fee and was not linked to fundraising scale or user-acquisition numbers; performance of duties was limited to formal verification, checking the proposed address and amount, and requesting underlying asset, white paper and other materials from the project party; and communication records and verification records were fully retained.
In such circumstances, because the constitutive element of subjective knowledge is absent, there is a high probability that no accomplice liability will arise, and there is considerable room for defense.。
III. The form of remuneration and timely withdrawal also affect the determination of the charge
The form of remuneration affects the inference of subjective knowledge.
A model involving token revenue sharing or commissions based on fundraising scale is readily found by judicial authorities to involve a binding of interests, making it easier to infer subjective knowledge.
A fixed-amount service fee is more favorable for the defense, but it does not mean automatic exemption from liability.
Even if the remuneration is very low, if there is evidence proving that you knew the project was unlawful, accomplice liability may still be established.
A multisig manager enjoys the right to refuse to sign, and timely withdrawal has practical legal significance.
When it is discovered that the purpose of a transaction is clearly abnormal, one should refuse to sign, withdraw from the multisig authority, and fully retain records of the withdrawal notice.
In joint crime, causation may be severed by ceasing participation;
continuing to sign after risk has already been perceived will itself become evidence highly unfavorable to one's own side.
IV. Five Practical Recommendations for Relevant Practitioners
Case-handling authorities generally infer subjective knowledge comprehensively from the following aspects:
Whether the chat records involve fundraising plans, return promises, or recruitment and promotion; the role in the project community; whether the remuneration is a fixed service fee or token commissions tied to fundraising scale; whether there are abnormal on-chain fund flows; and whether signing continued after risk signals had already appeared.
A mere oral defense that "I did not know the project was unlawful," if lacking support from objective evidence, is difficult for judicial authorities to accept on its own; therefore, here are several recommendations for relevant practitioners:
1. Before accepting appointment as a multisig manager, fully retain due diligence materials.
At a minimum, retain records of the fundraising logic, ownership documentation for the underlying assets, explanations of the use of funds, and records of communications with counterparties.
What appears useless in ordinary times becomes key evidence for proving subjective state of mind once a case arises.
2. Define the scope of your review through written documents, expressly providing that you have the right to withdraw unilaterally if anomalies arise.
Do not rely solely on oral agreements; a written agreement can help establish how you defined your own responsibilities.
3. Keep a record of every transaction proposal, every verification process, and every objection raised.
Retaining only records showing that you "have signed" leaves you in a very passive position in criminal proceedings.
4. Once you become aware of legal risk in a project, stop signing immediately and preserve records of the notice of withdrawal.
Each additional signature adds another layer of contribution to the conduct.
5. As far as possible, avoid taking token profit-sharing or fundraising commissions as remuneration, and participate prudently in large-value, high-frequency transfers of funds.
The remuneration model and the frequency of fund flows are both important references for judicial determination of subjective knowledge.
Lawyer Observations
A multisignature wallet is merely an on-chain fund management tool. It can address the risk of a single point of private key theft, but it cannot insulate against criminal legal risk.
Holding the private key carries with it a corresponding duty of prudent review.
From the perspective of the case-handling authority, signing is not a neutral technical operation but a necessary condition for the transfer of funds; each signature is, in substance, an authorization of that fund transfer.
Once a project becomes involved in a case, a person who was unaware but cannot produce objective evidence will find themselves in a very passive position; the earlier the risk is identified and the more promptly one exits, the greater the room for defense one retains.
