In recent years, stablecoins have gradually evolved from tools within the crypto community into broader scenarios for cross-border payments and trade settlement.
The European Union has incorporated the issuance of crypto assets, trading services, wallets, and anti-money laundering obligations into a unified regulatory framework through MiCA; following the implementation of Hong Kong’s Stablecoin Ordinance on August 1, 2025, the issuance of fiat-backed stablecoins in Hong Kong has become a licensed activity; and the United States passed the GENIUS Act targeting payment stablecoins in 2025. Regulatory advancements do not imply that all stablecoin payments are secure, but they do encourage more overseas clients, payment service providers, and trade intermediaries to treat stablecoins such as USDT and USDC as an optional tool for cross-border payments.
For Chinese foreign trade enterprises, this change is becoming increasingly concrete. Clients may no longer merely ask whether wire transfers, letters of credit, or PayPal are acceptable, but may directly ask: "Can you accept USDT?"
On the surface, accepting USDT appears convenient. Funds arrive quickly, transfers can occur across time zones and during holidays, and stablecoins seem to facilitate faster order completion when clients wish to avoid traditional banking channels. However, the real issue lies herein: what foreign trade enterprises receive is not merely a string of ordinary numbers, but an asset carrying an on-chain path, payer address, counterparty, and compliance record. It may represent legitimate payment for goods, or it may have been tainted at some upstream stage by funds related to fraud, online gambling, money laundering, sanctions, or other cases.
Therefore, the core issue for foreign trade enterprises receiving USDT is not "whether to accept it," but "how to accept it, who is paying, and whether the receipt can be explained." Once a wallet, exchange account, or bank card is frozen, the ability to resolve the situation often depends on whether the enterprise initially managed the receipt as part of a formal transaction process.
Why Foreign Trade Enterprises Are Increasingly Encountering USDT Receipts
In the past, foreign trade receipts primarily revolved around bank wire transfers, letters of credit, third-party payments, and offshore accounts. The increased mention of stablecoins by clients today is driven by multiple factors.
Some clients operate in regions with unstable banking systems, where cross-border remittances are slow, fees are high, and review processes are extensive; some clients are themselves involved in crypto assets or cross-border e-commerce and are accustomed using stablecoins for fund allocation; and some intermediaries proactively propose settling in USDT to bypass traditional bank reviews and reduce currency exchange costs.
For sellers, the most attractive aspect is speed. A USDT transfer may arrive within minutes, unlike bank wire transfers which require waiting for business days, intermediary banks, and compliance reviews. For small, high-frequency orders, clients may even package stablecoins as a "simpler payment method."
However, there is a misconception here: the advancement of stablecoin legislation does not mean that ordinary foreign trade enterprises can accept USDT without risk. On the contrary, as stablecoins increasingly enter mainstream payment and regulatory systems, issuers, exchanges, on-chain analysis firms, and law enforcement agencies will track fund sources more closely. What was previously merely platform risk control may now evolve into address freezes, judicial assistance investigations, account restrictions, or even cross-border law enforcement coordination.
What foreign trade enterprises truly need to concern themselves with is not the client’s claim that "this payment method is convenient," but rather where the USDT originates, why it is being paid from this specific address, the relationship between the paying entity and the contractual buyer, and whether the enterprise can produce a coherent set of materials if questioned in the future.
How the Client Pays USDT Determines the Magnitude of Subsequent Risk
A client stating "I will pay in USDT" is merely the beginning. What truly determines the risk is who pays the USDT, where it comes from, and whether it needs to be further transferred after payment.
The simplest scenario is when the contractual buyer pays directly using their corporate wallet or a fixed payment address, with the payment amount, order, and shipment schedule all corresponding. While this does not guarantee a complete absence of risk, the transaction relationship is relatively clear: who bought the goods, who paid, and why, making the materials easier to explain.
The second scenario involves the buyer arranging for an affiliated company, trade agent, or overseas payer to make the payment on their behalf. This is not uncommon in foreign trade, but written explanations must be retained. If the contractual buyer, the actual payer, and the consignee are not the same entity, the relationships must be clarified in advance. Otherwise, in the event of a freeze, the enterprise may find itself limited to the explanation: "The client asked someone else to pay." This statement is often insufficient for appeals and communications with law enforcement.
The third scenario involves the client paying from an OTC merchant or an unfamiliar third-party address. The risk in such cases rises significantly. The enterprise may not know the identity of the payer, nor the addresses through which the USDT passed upstream. If the upstream address happens to be flagged for fraud, online gambling, hacking, drugs, sanctions, or other case-related funds, the recipient may become entangled in a freeze.
The fourth scenario occurs when, after the client makes payment, they request the enterprise to assist in transferring out, exchanging currency, making payments on their behalf, or splitting funds to other addresses. At this point, the enterprise is no longer merely receiving payment for goods but is assisting the client with fund processing. If the enterprise also charges fees, profits from exchange rate differences, or regularly performs similar operations for multiple clients, external institutions may easily interpret this as acting as a settlement channel rather than as an ordinary seller of goods.
Therefore, the risk of accepting USDT in foreign trade is not directly derived from the act of "accepting USDT" itself, but emerges from the payment method. Who pays, who receives the goods, who instructs the transfer, who bears the fees, whether funds are split, whether payments are made on behalf of others, and whether prices are abnormally high—these facts determine whether the subsequent explanation will be one of normal trade or one involving risks in the fund chain.
Freezes After Receiving USDT: Wallets, Exchanges, or Bank Cards
If USDT has arrived but cannot be transferred out of the wallet, do not rush to contact the wallet app’s customer service. The wallet is merely a tool for displaying balances and initiating transactions; what is actually restricted may be the USDT associated with a specific address. Taking Tether’s public legal terms as an example, it reserves the right to take measures such as freezing, confiscating, blacklisting, or reporting to law enforcement agencies regarding relevant tokens, funds, or addresses in scenarios involving applicable laws, sanctions, anti-money laundering, counter-terrorism financing, and law enforcement requests.
This means that seeing a balance on-chain does not imply that the coins can be freely circulated. What the enterprise needs to do is not repeatedly state "I am engaged in normal trade," but to confirm which transaction triggered the restriction, what the corresponding wallet address is, who the upstream payer address belongs to, and whether the issuer or relevant service portal provides information on the reason for the freeze, case clues, law enforcement agency details, or appeal channels.
If an exchange account is frozen, the initial point of handling is the exchange. Exchange freezes typically occur for several reasons: internal platform risk control, KYT (Know Your Transaction) on-chain risk identification, judicial assistance investigations, regulatory requirements, notifications from law enforcement agencies, or inconsistencies between account behavior and KYC information. In such cases, it is crucial to clarify: whether the freeze is a general account restriction or a freeze on the quota corresponding to a specific deposit; which transaction hash is involved; whether the platform accepts legal opinions, trade materials, or appeal documents; and if judicial assistance is involved, whether materials can be forwarded or communicable channels provided.
Another situation involves the freezing of bank cards due to selling USDT or subsequent withdrawals. This enters the logic of bank risk control, anti-fraud stop-payments, public security freezes, or the return of case-involved funds. The objects of handling are no longer the issuer or exchange, but potentially the opening bank, anti-fraud centers, or the public security organs imposing the freeze. At this stage, the focus of the enterprise’s explanation shifts from "why this USDT was frozen" to "why these RMB funds entered the bank card and which real trade or currency exchange behavior they correspond to."
These three pathways must not be conflated. Wallet freezes require examining the issuer and address restrictions; exchange freezes require reviewing platform risk control and judicial assistance; bank card freezes require identifying the freezing authority and the involved transaction flows. Choosing the wrong entry point, no matter how well-prepared the materials, may result in futile efforts.
What Truly Helps Foreign Trade Enterprises Is a USDT Receipt Risk Control Process
If foreign trade enterprises intend to accept USDT in the future, they should not treat it simply as "another payment option for clients." A more prudent approach is to incorporate USDT receipts into the enterprise’s payment approval and compliance documentation processes.
Before the transaction, at least three questions must be confirmed: Who is the contractual buyer? Who is the actual payer? Who provided the payment address? Whenever the payer and the buyer are not the same entity, the client must provide an explanation in advance, and emails, chat records, supplementary contract agreements, or payment instructions must be retained. Do not wait until a freeze occurs to supplement materials.
During the transaction, avoid turning the receipt account into a mixed fund pool. Enterprises should distinguish between trade receipts, personal funds, currency exchange funds, and funds paid on behalf of others, and should not use the same exchange account or wallet address for receipts, exchanges, and turnover for multiple unrelated clients. The more commingled the accounts, the harder it becomes to explain which receipt corresponds to normal payment for goods and which is related to risky addresses.
After the transaction, do not easily assist clients in further transferring, splitting, exchanging, or making payments on their behalf. The logic of normal foreign trade receipts is: client pays, enterprise ships, finance records the entry. If, after receipt, the enterprise transfers USDT to a third-party address according to the client’s instructions, the enterprise’s role changes. To external institutions, this may no longer appear as merely receiving payment for goods, but as participating in fund circulation.
If a freeze has already occurred, first secure the evidence, then decide on the communication pathway. Do not delete chat records, do not create fake contracts retroactively, do not seek so-called "guaranteed unfreezing" channels, and do not transfer remaining assets to unfamiliar addresses. What is truly useful is organizing the trade facts, on-chain paths, client identities, payment relationships, and freeze notifications into a clear chain of evidence.
The following material checklist can serve as a preparation list for internal self-inspection and for communications with platforms, issuers, and freezing authorities.
This table is not intended for enterprises to make all legal judgments themselves, but rather to clarify the facts first. The greatest fear in cases of frozen USDT receipts in foreign trade is not initially lacking a conclusion, but rather confusing the facts from the outset.
If you or your company have encountered issues such as USDT wallet freezes, exchange account freezes, investigations involving case-related funds, or inability to withdraw foreign trade receipts, the first step is not to seek a "definitive answer," but to organize the freeze location, transaction hashes, client identities, contract orders, customs declaration and logistics records, chat logs, and platform notifications. Only by clearly explaining your position within the fund chain can you subsequently proceed with appeals, communications, and risk control.
If you are also facing legal and compliance issues related to cryptocurrency payments and receipts, you may contact Mankun Law Firm.
About Mankun
Mankun Law Firm, established in 2015, is a boutique law firm dedicated to serving Web3.0 and the next-generation internet, with deep expertise in emerging economic fields such as blockchain, artificial intelligence, and tech finance.
Headquartered in Shanghai, the firm has branch offices in Hong Kong, Shenzhen, Silicon Valley, and other locations. Its core members come from renowned law firms, judicial authorities, technology companies, and digital asset institutions. Leveraging a unique multi-perspective approach encompassing "law, industry, and regulation," the firm provides high-quality legal services to clients with both Chinese depth and global breadth.
Based on a profound understanding of emerging economic sectors, continuous attention to and research on regulatory policies, and rich practical experience, the Mankun team excels in providing comprehensive legal services from the perspectives of business models and legal practice. These services include business structure design, project financing and investment, operational compliance, commercial disputes, construction of anti-money laundering (AML) compliance systems, collaboration with global law enforcement investigations, digital asset tracing and recovery, criminal risk prevention and control, and criminal defense for clients in emerging economic fields such as Web3.0 blockchain, artificial intelligence (AI), encrypted payments (PayFi), decentralized finance (DeFi), tokenization of real-world assets (RWA), NFT digital collectibles, and crypto funds.
