As crypto payments go global, why a single license is inevitably insufficient.
If one observes the crypto payments sector over the long term, a rather interesting yet highly realistic phenomenon emerges:Many projects emphasize structural simplicity in their early stages, such as “one company, one license, one fund flow path.” At the startup stage, this structure is not only sufficient to support business launch but also often enables faster product deployment and lower costs, making it a very common model in the industry’s early days. However, as business volume gradually increases, especiallywhen the platform begins serving cross-border users, integrating with the banking system, and providing services to institutional clients, this simple structure often quickly reveals its limitations.
Crypto payment platforms that achieve significant scale almost invariably evolve toward a fundamentally different architecture: multiple operating entities distributed across different jurisdictions, supported by various types of financial or virtual asset licenses. This structure is commonly referred to in the industry as “multi-license synergy.”
Many people interpret “multiple licenses” merely as a compliance upgrade, but from a commercial reality perspective, it is actually a structural inevitability following scaling.
On the surface, this may appear to be merely an increase in the number of licenses held by an enterprise. However, a careful examination from the perspectives of legal structure and commercial logic reveals that this change is not driven by a voluntary pursuit of complexity, but is determined by the regulatory structure of the global payment system itself. When business operations expand to a certain scale, enterprises must simultaneously address regulatory rules in different countries, licensing regimes for different types of financial activities, and compliance requirements imposed by financial institutions, conditions that a single-license structure is often unable to satisfy concurrently.
In short, when crypto payments begin to integrate with the real-world financial system, structural complexity becomes almost unavoidable.
In recent years, several representative crypto payment platforms have emerged in the Asian market, such as RedotPay, Alchemy Pay, and Triple-A. While these three companies differ in product form and business model, an examination from a legal structure perspective reveals that they are all gradually forming operational systems characterized by multiple entities, multiple jurisdictions, and multiple licenses.
These cases illustrate one point: competition in PayFi has begun to shift from product-based competition to structural competition.
Crypto payments are evolving from product features into account-based financial platforms
In the early stages of the industry, most people’s understanding of crypto payments remained confined to relatively simple application scenarios, such as using stablecoins for consumer payments, purchasing crypto assets via bank cards, or directly transferring digital assets from wallets. From a user experience perspective, these functions are indeed merely payment tools; consequently, many startup teams position their products as “payment products” or “payment gateways.”
However, observation of certain platforms that have experienced rapid growth in recent years reveals that their product structures are gradually evolving.An increasing number of crypto payment platforms are, in fact, constructing an “account-based product structure.”
Taking RedotPay as an example, at first glance it may easily be perceived as a stablecoin payment card platform. However, a review of the General Terms published on its official website reveals that the services provided by the platform extend far beyond simple payments. Its service modules include custodial accounts, payment cards, asset conversion, virtual asset lending, yield-generating products, and fiat currency remittances. These functions do not exist in isolation but are integrated around a unified account system, enabling users to perform various operations within the same platform, including asset storage, asset conversion, consumer payments, yield generation, and borrowing.
When a platform simultaneously provides payment, conversion, custody, yield, and lending services, it can no longer be simply understood as a “payment tool.”From the perspective of regulatory authorities, such platforms effectively possess multiple financial service attributes. This explains why many payment platforms, which initially appear to be merely engaging in product innovation, ultimately become subject to more complex regulatory frameworks as they scale.
Practical Challenges Faced by Single-License Structures at Scale
In practice, most crypto payment platforms adopt a relatively lightweight compliance structure during their startup phase, whereby a single operating entity holds a key license that serves as the basis for the legality of their business operations. When business scale is limited, this structure typically satisfies regulatory requirements while reducing compliance costs. However, as platforms expand into global markets, this structure often encounters several practical challenges:
First, regulatory fragmentation across jurisdictions. There is no unified framework for global payment regulation, and regulatory regimes vary significantly across different countries and regions. For example: the United States relies on the Money Services Business (MSB) and Money Transmitter License (MTL) systems to regulate money transmission services; Europe regulates payment and crypto asset services through the Electronic Money Institution (EMI) and Markets in Crypto-Assets (MiCA) frameworks; Singapore adopts the Major Payment Institution regime; and Hong Kong employs the Money Service Operators (MSO) and Virtual Asset Service Provider regimes.No single license can cover global payment operations.This means that if a platform seeks to serve multiple markets simultaneously, a license from a single jurisdiction is often insufficient to support all its business activities.
Second, regulatory overlap arising from product feature expansion. As platforms expand from payments into asset conversion, custody, yield generation, or lending, different business lines trigger distinct types of regulation. For example: payment businesses typically fall under the supervision of payment institutions; digital asset businesses such as custody and conversion may fall under the Virtual Asset Service Provider framework in many jurisdictions; and yield and lending arrangements may further implicate investment management, securities, lending, or other financial regulations.As products continue to expand, regulatory frameworks are layered on in tandem.
The third question comes from financial partners. When a platform is small in scale, banks or payment channels typically do not pay close attention to its regulatory structure. However, as business volume begins to grow—particularly when the platform seeks to issue payment cards, access the bank clearing system, or serve institutional clients—financial institutions usually require the enterprise to clarify its regulatory status.“What type of licensed entity are you?” is often an unavoidable question in all partnership negotiations.Many crypto payment projects realize at this stage that they need to redesign their compliance structure.
Multi-license coordination is, in essence, a form of structural design.
In the industry, “multi-license” is often understood as an enterprise applying for more licenses. However, in practice, multi-license coordination often entails more complex structural arrangements.True multi-license coordination is not simply about “obtaining additional licenses”, but rather involves splitting businesses through legal structures so that different business modules can operate under distinct regulatory frameworks.
From a regulatory perspective, a seemingly simple crypto payment platform often involves multiple financial links in its actual business chain, such as the receipt and clearing of fiat funds, the exchange and transfer of crypto assets, custody of user assets, and merchant settlement. In most jurisdictions, these functions are typically subject to different types of regulatory regimes. If all businesses are undertaken by the same entity, it not only increases compliance risks but also tends to blur regulatory responsibilities. Therefore, as a platform scales, splitting businesses through structural design often becomes a more sustainable approach.
Based on practical experience, such a structure usually comprises three layers.
- The first is functional layering.
Different business modules are undertaken by different entities or licenses. For example, payment and settlement businesses are typically handled by licensed payment institutions, while asset exchange or custody services may be provided by entities acting as virtual asset service providers. If the platform also involves yield or lending services, these businesses are often further split into entities in other jurisdictions to ensure that each type of business operates under the corresponding regulatory framework.
- Second is regional layering.
Different markets are overseen by entities incorporated in different jurisdictions to align with local regulatory frameworks. For example, European operations are typically conducted by entities licensed in the European Union, while Asian operations may be run by entities based in Singapore or Hong Kong. In cross-border payment scenarios, this structure enables the platform to obtain distinct regulatory statuses in different regions while avoiding regulatory conflicts across jurisdictions.
- Third is risk layering.
Through a multi-entity structure, companies can legally isolate fund-related risks, compliance risks, and regulatory liabilities. If regulatory issues or business risks arise in a particular region, they will not directly impact the entire business ecosystem. For payment platforms involving large-scale capital flows, such risk isolation is particularly important in practice.
From the perspective of legal structure,multi-license coordination is in fact a typical design for cross-border financial architecturesWhat it addresses is not “how to obtain more licenses,” but ratherhow to ensure that different functions—such as payments, exchange, custody, and settlement—can operate in compliance simultaneously under a globally fragmented regulatory system.
RedotPay: A Multi-License Portfolio for a Stablecoin Account Platform
The product most widely recognized by RedotPay’s users is its stablecoin payment card. However, a careful review of the service terms disclosed on its official website reveals that the platform’s structure is far more complex than a single payment product. According to its General Terms, the service modules provided by the platform include Custodian Account, RedotPay Card, Swap, Virtual Assets Loan Services, Crypto Earn, Fiat Remittance, and Crypto Transfer.
More importantly, these services are not provided by a single entity. The terms explicitly disclose that the Swap, Fiat Remittance, and Crypto Transfer services are provided byRed Dot Payment Inc, while Crypto Earn and certain asset-related services are provided byRedotX Panamabear such liability.
With respect to its regulatory status, RedotPay’s structure also exhibits distinct multi-jurisdictional characteristics.
First, inHong KongRedotPay acquired a licensed entity in 2024 through an acquisition.Money Service Operator（MSO）This license permits the entity to provide money-changing and remittance services. This means that the platform already has its own licensed entity for fiat currency conversion and remittance services, rather than relying entirely on third-party channels.
Second, inthe United Statesits terms disclose thatRed Dot Payment Inc. has registered with FinCEN as a Money Services Business (MSB)and holds a corresponding MSB registration number. This status indicates that it has been brought within the U.S. federal MSB/AML regulatory framework; however, if specific activities constitute money transmission under state law, separate determination based on each state’s licensing requirements is typically still necessary.
Furthermore, RedotPay’s structure also extends toLatin Americamarket. Its group entitiesRedotX (Tango) Limited Argentine Branchhave been registered in the Virtual Asset Service Provider registry of the Argentine National Securities Commission (CNV), obtaining PSAV/VASP status.
When these pieces of information are viewed together, the structural logic of RedotPay becomes very clear:
- Hong Kong MSOhandles fiat currency exchange and remittances
- U.S. MSBsupports fund transfers and payment channels
- Argentine VASPregistered to provide virtual asset services
- Panamathe entity assumes revenue-generating modules
Different businesses → different entities → different regulatory responsibilities.
This is precisely the typical multi-license synergistic structure of stablecoin payment platforms.
Alchemy Pay: The License Puzzle of a Global Fiat On-Ramp Network
Unlike RedotPay, Alchemy Pay’s business positioning resembles a payment network connecting the traditional financial system with the crypto assets market. Its core products are crypto-fiat on-ramps and off-ramps, enabling users to purchase crypto assets via bank cards or bank transfers, and to convert digital assets into fiat currency when needed.
Given that this model inherently involves cross-border capital flows, its compliance framework has been designed from the outset to address multiple markets.
In theU.S. market, Alchemy Pay accesses the payment system by applying for licenses in multiple states.Money Transmitter License（MTL）The company has currently obtained Money Transmitter Licenses (MTLs) in Arkansas, Iowa, Minnesota, New Hampshire, New Mexico, Oklahoma, Oregon, Wyoming, Arizona, and South Carolina, and continues to expand its state-level licensing footprint. Meanwhile, the company has also completedregistration as a Money Services Business (MSB) with FinCEN.。
In theUK and other markets, Alchemy Pay accesses local payment networks through payment institution licenses, registrations, or partnership channels. Its publicly disclosed regulatory footholds include UK Authorized Payment Institution (API) status, multi-state MTLs in the United States, Digital Currency Exchange (DCE) registration in Australia, Swiss VQF SRO membership, and electronic financial business registration/investment layout in South Korea.
In other words, Alchemy Pay’s payment network is effectively built upon a global patchwork of licenses.
The United States handles money transmission licensing, Europe oversees payment institution regulation, and other jurisdictions provide supplementary coverage through virtual assets or payment registrations.
While the technology platform is unified, its payment regulatory identities are dispersed across multiple jurisdictions.
Triple-A: A Global Regulatory Network for Licensed Crypto Payment Institutions
Triple-A’s business model is more focused on the corporate payments sector, with its primary product helping merchants accept crypto assets payments and settle in fiat currency.
In terms of regulatory structure, Triple-A adopts a typical “hub-and-spoke” model.
First, inSingaporeTriple-A holds aMajor Payment Institution (MPI) licenseissued by the Monetary Authority of Singapore (MAS). This license permits the entity to provide various payment services, including Digital Payment Token Services, Domestic Money Transfer Services, Cross-Border Money Transfer Services, and Merchant Acquisition Services.
Meanwhile, the companyEuropealso has regulatory registrations. For example, its French entity obtainedan ACPR Payment Institution license, and is registered with the French AMF as a Digital Asset Service Provider (DASP). This means that in Europe it holds both traditional payment institution status and digital asset service provider status.
Inthe United States, Triple-A isregistered as an MSB with FinCENand holds licenses in several states.Money Transmitter LicenseIn addition, the company also operates inCanadaasForeign MSBidentity orientation FINTRACregistration.
When these pieces of information are viewed together, the structure of Triple-A becomes very clear:
- Singapore MPI as the Asia-Pacific hub
- French Payment Institution + DASP serving the European market
- U.S. MSB + MTL entering the North American payment system
- Canadian Foreign MSB supplementing regulatory status
First establish licensed payment institutions, then integrate crypto assets into the payment system.This is precisely the most typical development path for merchant payment platforms.
Industry patterns behind the three cases
If RedotPay, Alchemy Pay, and Triple-A are observed together, a very obvious commonality emerges.Regardless of how their business models differ, they have ultimately all moved toward multi-entity, multi-jurisdiction, and multi-license structures.This complexity is not actively pursued by enterprises, but rather results from the global payment regulatory framework. Cross-border payments involve fund custody, asset conversion, payment settlement, and merchant acquisition, each of which is typically subject to distinct regulatory regimes in different jurisdictions.Therefore, when a platform truly reaches a stage of scaled operations, multi-license coordination becomes almost inevitable.
PayFi Competition Is Shifting from Products to Structure
From an industry development perspective, crypto payments are entering a new phase. Early competition primarily focused on product experience, user growth, and transaction volume. However, as the industry matures, the challenges faced by enterprises have evolved. For example: how to help regulators understand business models, how to secure cooperation from banks, and how to explain commercial logic to capital markets.In this environment, true competitive advantage lies no longer solely in products, but in structural capabilities.These include: legal structure design capabilities, regulatory adaptation capabilities, and risk governance capabilities.
Conclusion
Reviewing the development of the crypto payments industry over the past few years reveals a very clear trend. Many projects relied on simple structures for rapid launch in their early stages, but as their businesses expanded globally and at scale, the single-license model often encountered bottlenecks.Multi-license coordination is not a display of compliance prowess, but rather a structural evolution.It addresses a highly practical issue:How to operate a scaled crypto payments network under a fragmented global regulatory framework.For growing PayFi projects, this is likely a critical question that must be addressed in the coming years.
Author
Shao Jiadian, Partner at Mankun Law Firm (Shenzhen). A graduate of the National University of Singapore, he has previously served as a lawyer, head of compliance and risk control, and Vice President of Legal Affairs at prestigious red-circle law firms, a cross-border investment platform of a central state-owned enterprise, and a multi-billion-yuan fund of funds, among other institutions. He specializes in emerging economic sectors such as Web3, demonstrating expertise in creatively providing one-stop legal and compliance solutions for clients, including global structural setup for Web3 projects, license applications, project financing, real-world assets (RWA), and the establishment of crypto funds.
About Mankun
Mankun Law Firm was established in 2015 as a boutique law firm in China dedicated to the Web3 new economy and deeply rooted in the blockchain industry. The Mankun team possesses a unique and diverse industry background, with members hailing from renowned legal service providers, national judicial authorities, internet technology companies, crypto asset institutions, and blockchain industry think tanks.
Leveraging a profound understanding of the new economy, continuous research into policies and regulations, and extensive 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 investment and financing, transaction planning, operational compliance, resolution of complex civil and commercial disputes, prevention and control of criminal risks, and criminal defense for enterprises in emerging sectors such as Web3, blockchain, AI, NFTs, digital collectibles, crypto funds, crypto payments, DeFi, real-world assets (RWA), and GameFi.
Headquartered in Shanghai, Mankun Law Firm maintains branch offices in Hong Kong (China), Silicon Valley (USA), Shenzhen, Hangzhou, Zhengzhou, Chengdu, and other locations. To meet the global compliance development needs of Web3 industry clients, Mankun has established local offices in major global crypto-financial hubs and selected professional local blockchain service partners, thereby providing clients with professional legal and compliance services characterized by global breadth and Chinese depth.
