Recently, a company came to us with an increasingly common question: an overseas client is willing to purchase the company's products or services in the ordinary course, and the contract, orders and commercial background are all genuine,except that at the payment stage, the counterparty proposes to useUSDTfor settlement.The company does not intend to engage in a virtual currency business, nor does it plan to provide clients with services for buying, selling or exchanging currencies. It simply faces a very practical commercial question: the client is willing to pay, but the payment instrument has been changed to USDT — can this money be accepted at all? And if it is received, and the company ultimately still needs RMB to pay salaries, make purchases and pay taxes, how should the on-chain USDT be converted into funds that can enter the company's bank account?
On the surface, this appears to be merely a question of "choosing a payment method," but once it enters genuine legal analysis, it becomes clear thata single USDT payment for goods involves at least four dimensions at the same time:whether the contract can be structured this way, whether a domestic enterprise can use virtual currency as an everyday settlement instrument, how the USDT received can be converted into fiat currency the company can use, and whether the entire funds chain can withstand scrutiny by the banking, tax and anti-money-laundering systems.
Contractual arrangements
How the payment instrument and contractual obligations should be structured.
Domestic regulation
Whether virtual currency can serve as an instrument for an enterprise's everyday pricing, receipt of payment and settlement.
Asset disposal
How received USDT can be converted into fiat currency that the enterprise can use.
Booking review
Whether the fund chain can pass verification by the banking, tax and anti-money laundering systems.
Therefore, what the enterprise truly needs to resolve is not "whether it is acceptable to send a wallet address to the client," but whether this commercial income can ultimately travel from the contract and on-chain assets all the way to the company's account, and whether every step in that process can be explained.
I. A client paying in USDT and an enterprise operating a "USDT exchange business" are not the same issue
First, it is necessary to distinguish between two scenarios that are easily confused.
One scenario is that the enterprise itself is engaged in virtual currency-related services, for example, long-term provision to clients of RMB-to-USDT exchange, exchange between virtual currencies, trade matching, pricing or settlement services, and collecting fees or earning exchange spreads therefrom; the other scenario is that the enterprise itself provides software, consulting, trade or other genuine goods or services, and it is merely that an overseas client wishes to pay the contract price in USDT instead.
The business purposes of the two scenarios differ, but thisdoes not mean that the second scenario is naturally free of risk。
In February 2026, the People's Bank of China and seven other departments issuedYin Fa [2026] No. 42The document once again makes clear that virtual currencies such as Bitcoin, Ether and Tether do not have the same legal status as legal tender, are not legal tender, and should not and cannot be circulated and used in the market as currency; at the same time, conducting within the territory businesses such as exchange between legal tender and virtual currency, exchange between virtual currencies, and related information intermediation and pricing continues to be expressly listed within the scope of strictly prohibited illegal financial activities. The document also requires financial institutions and non-bank payment institutions not to provide services such as account opening, fund transfer and clearing and settlement for virtual currency-related business activities.
This means that, for a domestic company, the issue cannot simply be understood as “I am not an exchange, so receiving USDT is fine.” If USDT begins to be used by an enterprise on a long-term and stable basis as a tool for pricing, collecting payment and settling goods and services, it in fact no longer involves merely an isolated receipt of assets, but will further touch upon the basic policy position of the current regulatory regime that virtual currency “may not be circulated or used as currency.”
“The client proactively proposed to pay in USDT” does not automatically eliminate the compliance judgment that an enterprise, as the payee, must undertake.
II. What is truly troublesome is often not “receiving U,” but what to do after receiving it
When many enterprises discuss this issue for the first time, they focus on the technical steps: set up a wallet, send the address to the client, confirm receipt, and the transaction appears to be over.
But for a company genuinely carrying on business,receiving USDT is only the first step.。
The enterprise ultimately needs to pay employee salaries, supplier payments, office expenses and taxes, and these business activities still mainly occur within the fiat currency system. Therefore, a second question quickly arises: how are these USDT converted into RMB or other fiat currency that can enter the enterprise's bank account?
If the company itself seeks out crypto traders within the PRC to sell USDT for RMB and then has the RMB enter the accounts of the company or related personnel, the transaction structure will immediately re-enter the regulatory issues concerning the exchange of virtual currency and legal tender; if collection is made through personal accounts, employee accounts or third-party accounts, this will further create new risks such as commingling of company income with personal funds, inconsistency between the paying entity and the contracting entity, and bank records that cannot be explained.
What is most easily underestimated in a USDT payment for goods is not the “risk of receiving coins,” but the subsequent risk of realization and booking.
What an enterprise must think through in advance is: who performs the payment obligation under the contract, whose controlled wallet the USDT enters, which entity subsequently completes the disposal of the assets, and whether a complete correspondence can be established between the fiat currency that ultimately enters the bank account and the income under the original contract. If these questions are not designed clearly before the business occurs, the enterprise can easily find itself in an awkward position: the on-chain assets have indeed been received, but when they actually enter the company's financial system, it is difficult to explain which business income this RMB, US dollar or Hong Kong dollar actually corresponds to.
III. “Having a Hong Kong company receive it” is also not a problem that can be solved with a single sentence
In practice, enterprises readily think of another approach: if it is not convenient for the domestic company to receive directly, can the USDT simply be received by a Hong Kong, Singapore or other offshore entity?
This approach is not entirely without room for discussion, but one oversimplified understanding warrants particular caution: that “once the wallet is placed offshore, the legal risks automatically disappear.”
What truly needs to be analyzed first is whether the offshore entity is the actual contracting party. If the customer purchases products or services from an offshore company, and the personnel, business, costs and revenue genuinely arise within that entity, and local law permits it to accept and handle digital assets in accordance with the applicable rules, then the matter at least has a genuine commercial basis; however, if the business, personnel, performance and revenue in fact all belong to a domestic company, and an offshore company or an offshore wallet is merely added on a temporary basis at the time of payment as a “USDT collection channel,” then such an arrangement may itself give rise to new issues concerning revenue attribution, related-party transactions, foreign exchange, tax and anti-money laundering characterization.
On the other hand, even if the offshore entity lawfully holds USDT, ultimately converting the assets into fiat currencies such as US dollars or Hong Kong dollars and depositing them into a bank account still requires dealing with the local trading platform's and bank'sKYCKYC, AML and Source of Funds reviewsThe bank will ultimately still ask: who the customer is, what the contract is, why USDT was used for payment, which address the on-chain assets came from, how the exchange completed the conversion, and what relationship the fiat currency received by the bank bears to the original commercial transaction.
A genuinely mature cross-border structure design is not about “placing the collection entity offshore,” but about ensuring that the four dimensions of contracting party, business substance, asset flow and bank crediting correspond with one another.
IV. When an enterprise receives USDT, what most needs to be prevented is “genuine business” and “fund channels” being mixed together
This is also the boundary that most merits enterprises' attention in relation to criminal risk.
Suppose a software company provides genuine technical services to an offshore customer, and the customer pays the price under a genuine contract; even if the payment instrument involves USDT, there is at least still a clear underlying transaction of goods or services. However, if the company gradually begins to accept third-party funds with no genuine business relationship, or if, after the customer pays, the customer asks the company to convert the USDT into other fiat currencies, transfer it to a designated account, or even complete collections and payments on behalf of different entities, then the company's role will change.
What was originally “collecting its own payment for goods” may gradually become “handling funds for others.”
In recent years, in publicly reported cases involving illegal foreign exchange, underground banks and money laundering connected with virtual currencies, what judicial authorities focus on precisely is this kind of role change: whether the actor is merely handling its own assets and normal commercial revenue, or has already begun providing exchange, cross-border payment or fund transfer services to others and steadily collecting fees, service charges or exchange-rate spreads therefrom.
The latest 2026 regulatory documents continue to make clear that the relevant authorities will focus on combating criminal and illegal activities such as fraud, money laundering and illegal business operations carried out using virtual currencies, while strengthening monitoring of the funds, technology and internet service segments.
Therefore, for enterprises, a very important internal red line is:the collection of ordinary payment for goods must be strictly separated from exchanging on behalf of others, collecting and paying on behalf of others, and transferring funds through intermediaries.
Once a company not only accepts USDT paid by its own clients but also begins to help clients address issues such as "how to convert it into RMB," "how to transfer it to a third-party account," and "how to collect money on behalf of others," the enterprise will no longer face only commercial contract compliance issues, but may enter the assessment of payment settlement, foreign exchange, and even criminal risks.
V. What this type of business truly needs to design is an "explainable revenue chain"
For enterprises that genuinely have a need for overseas clients to pay with digital assets, rather than merely asking "can USDT be accepted," it is better to map out the entire revenue chain before the business begins.
From the perspectives of lawyers and compliance, we usually focus more on five consecutive questions:
Who is the contracting party?
Clarify which entity the business revenue is attributed to in the legal relationship.
Why does the client need to use USDT for payment?
Retain the genuine commercial explanation behind the choice of payment instrument.
Which entity's actually controlled wallet does the USDT enter?
Ensure that wallet ownership, control authority, and the contracting party can correspond to one another.
Through what compliance mechanisms is asset disposal completed?
Explain the trading platform, conversion path and participating entities.
How do fiat currencies correspond to business vouchers?
Ensure that bank entries, contracts, invoices, orders and financial records form a closed loop.
These five questions in fact constitute achain of evidence for enterprise digital asset income.
If in the future a bank or regulator requires an explanation of the source of funds, the company cannot provide only a wallet screenshot; it should be able to explain from the contract through to the final bank entry: under what contract the client paid, what the on-chain transaction hash is, which wallet belongs to the company or the overseas business entity, on what platform the digital assets were converted, why the converted fiat currency entered this account, and whether the amount is consistent with the original business income.
From the perspective of finance and bank compliance, what is truly valuable is not "proving that the company once held these USDT," but proving why these USDT belong to the company.
VI. What enterprises need to change is the habit of "collecting money first and supplementing compliance later"
Many Web3 and cross-border startup teams are most likely to adopt a very realistic approach in the early stage of business: collect payment however the client is willing to pay, and resolve banking, tax and compliance issues after the scale grows.
When transaction volumes are very small, this approach may temporarily not expose problems, but as amounts rise, enterprises will increasingly face bank KYC, account reviews, explanations of source of funds and financial accounting requirements, and problems from the early stage such as the lack of contracts, wallet ownership, transaction records and proof of fund paths are often difficult to remedy after the fact.
Especially when an enterprise prepares for financing, audit, mergers and acquisitions or entry into licensed markets, historical digital asset income is very likely to be reviewed again; at that point, what investors, banks and professional institutions focus on is no longer whether a particular USDT payment arrived, but whether the enterprise's entire fund system over the past few years isVerifiable, auditable, and explainable。
Therefore, what is truly worth resolving in advance for enterprises accepting USDT paymentsis not wallet technology, but internal policies。
How contracts should provide for such payments, which customers may pay with digital assets, who has authority to control wallets, how transactions are approved, how on-chain assets are recorded, which entities are responsible for conversion and bank crediting, and how high-risk addresses or abnormal transactions are handled should all be governed by clear rules before the business scale expands.
Final remarks
When a customer asks "can we pay in USDT," it sounds like merely changing one payment instrument, but for a domestic enterprise this question in fact connects multiple regimes: virtual currency regulation, cross-border settlement, bank anti-money laundering, corporate finance, and criminal risk.
The real question is not "can USDT technically be received," but whether, once received, the asset can ultimately enter the enterprise's operating system through a lawful, clear, and verifiable path.
For enterprises in the digital asset era, receiving the money is only the first step in completing a transaction; being able to explain why the money belongs to the company is the true marker of completed compliance.
Mankun lawyers continue to monitor legal issues in Web3, stablecoin payments, digital assets, and cross-border funds, assisting enterprises at the business launch stage in structuring transactions, payment paths, wallet management, and cross-border compliance, and conducting risk assessments and evidence organization for digital asset fund chains that have already formed.
