Mankun Q&A

There is no single "crypto payment license" that is valid worldwide. The product should first be broken down into receiving tokens, custody, exchange, transfer and fiat settlement, and then assessed according to the…

It is not necessarily required to apply from scratch, but the scope of the license must be re-examined. A traditional payment qualification does not automatically cover stablecoin custody, exchange and transfer; some…

Providing software alone does not necessarily require a financial license, but the fact that one does not touch money cannot by itself prove an exemption. It is necessary to examine whether the interface merely…

In offshore markets that permit the relevant business, collecting stablecoins and then settling fiat currency to merchants may be carried out under the corresponding licenses and a lawful cooperation structure; it is…

Possibly, and the fact that "the coins are the company's own" is not a general exemption for operating an exchange business. A distinction should be drawn between the company handling its own investments and a business…

Licensing or registration requirements generally still need to be assessed. Corporate clients are not a general exemption: regulators first look at whether the platform operates exchange, custody, transfer or payment…

The assessment must follow the payment chain rather than looking for a single "cross-border payment license." Collecting funds on behalf of an enterprise, exchanging currencies, transferring tokens and paying fiat…

It is not enough to look only at the place of incorporation, nor should "overseas clients" be treated as a single unregulated category. It is necessary to examine simultaneously the place of incorporation and actual…

Where a business is required by law to obtain prior permission or registration, it may not commence operations merely because it is small in scale, free of charge, or labeled a "closed beta." Technical validation that…

The transition is not merely adding a new currency interface; it requires reworking the alignment of business scope, asset control, risk, and partner channels. Existing customer, order, and reconciliation capabilities…

There is no single best place of incorporation divorced from the business context. The first batch of customers and the product should be determined first, and only then should the scope of market access, substantive…

It is not necessarily required to apply separately in every country, but there should be a clear basis for market access in each market intended to be served. This may be a local licence, a qualifying regional…

MSB, VASP and CASP are not the same global license. MSB is generally a money services business category in specific countries; VASP is a virtual asset service provider concept with differing regimes across…

When the budget is limited, the first step should be to choose the market-entry pathway that can support the first real product and customer market, rather than the cheapest or most easily demonstrated qualification.…

There is no uniform timeline applicable to all crypto payment projects. A distinction should be drawn between document preparation, regulatory processing after a complete application is submitted, and bank and product…

Government fees, professional service fees, capital or safeguard requirements, and ongoing operating costs should be calculated separately; they cannot be summarized by a single "total license acquisition price."…

Whether approval will be granted cannot be determined on the basis of Chinese nationality alone. A distinction should be drawn between shareholder identity, place of residence, actual control, source of funds and…

Many formal licences require genuine management and operational capacity; renting an address alone is not enough. However, offices, resident personnel and positions that may be outsourced should be assessed on a…

An acquisition does not mean buying a license that can be used immediately. You should compare the target entity's actual scope of services, the change-of-control procedures, historical risks, and whether its banking…

The same licensed entity may operate multiple products within the permitted scope, but different subsidiaries cannot share a qualification merely by virtue of their group relationship. It depends on who contracts with…

US MSB registration is primarily used to fulfill FinCEN anti-money laundering regulatory requirements; it is not a nationwide business license. Stablecoin exchange, payment collection and disbursement on behalf of…

Whether an MTL is required generally depends on whether a state characterizes your actual receipt and payment activities as money transmission, not on whether the company is registered in that state. The legal…

Canadian MSB registration may apply to businesses such as commercial virtual currency exchange, transfer and money transmission, but it is only part of anti-money laundering market entry. A distinction must be drawn…

A Hong Kong MSO licence cannot serve as a general authorisation for stablecoin exchange or crypto payments. It primarily addresses money-changing and remittance business; where specified stablecoins are offered to…

Whether an SVF licence is required turns primarily on whether a storable value is created and whether the issuer undertakes to allow customers to pay third parties using that value. Displaying a balance does not…

Hong Kong permits the design of compliant stablecoin collection and payment services, but a clear distinction must be drawn between issuance, offering to clients, custody and transfer, and fiat currency settlement.…

When entering the EU now to provide custody, exchange, transfer on behalf of clients, or other services within the scope of MiCA, the relevant CASP authorisation should generally be obtained; certain already-regulated…

Possibly yes. A MiCA authorisation does not automatically cover fiat-currency payments, e-money issuance, or all payment activities carried out using e-money tokens (EMTs). It is necessary to distinguish between…

A non-EU company cannot actively operate in the EU crypto payment market solely on the basis of an offshore licence. The MiCA exception for transactions where the client is the sole initiator is narrow in scope and…

In Singapore, one should first identify digital payment token services and other payment functions under the Payment Services Act, and then determine the required payment institution licence and permitted business…

Possibly yes, and "incorporated in Singapore, serving only overseas clients" is not a light-touch regulatory shortcut. From 30 June 2025, businesses falling within the scope of the overseas digital token service…

Australia should be assessed at three levels: AUSTRAC VASP or remittance registration, AFSL requirements under existing financial product rules, and the new digital asset platform regime that has been enacted but is…

Joining a Swiss self-regulatory organisation (SRO) recognised by FINMA can be a route to meeting anti-money-laundering requirements for certain crypto exchange, transfer or payment models, but it is not a comprehensive…

Usually yes. Registering a BVI or Cayman Islands company merely establishes a legal person; it does not mean the company is authorized to provide virtual asset services. The two jurisdictions each have VASP…

The actual jurisdiction, assets and services should first be determined before choosing a regulatory pathway. Dubai's VARA does not cover the DIFC, while the ADGM is regulated by the FSRA; stablecoin payments also…

Stablecoin exchange, collection followed by foreign-exchange conversion, and similar businesses cannot be treated as ordinary payment services that may be operated simply by registering a company in mainland China.…

An offshore licence alone is not sufficient to provide stablecoin exchange, trading or other services to clients in mainland China. Yinfa [2026] No. 42 expressly prohibits offshore entities and individuals from…

Chinese shareholders or Chinese nationality alone are not sufficient to determine whether a particular overseas client can be onboarded; conversely, overseas registration or residence status does not mean the client…

Risks exist, but it cannot be concluded that all mainland employees are acting unlawfully merely because the company engages in crypto business, nor can "technical positions" be treated as an exemption. It is necessary…

The fact that a company and its account-opening process are located offshore does not permit it to freely promote stablecoin exchange or related payment services in mainland China. The 2026 regulatory notice restricts…

If the service in substance completes unauthorized RMB-to-foreign-currency exchange for clients, the stablecoin is merely an intermediary medium, and the arrangement may still constitute illegal foreign-exchange…

Genuine trade does not mean that a stablecoin settlement pathway is automatically lawful. Where corporate receipts and payments involve mainland China, virtual currency, payment and foreign exchange restrictions must…

Wages governed by the labor laws of mainland China must be paid in legal tender and cannot be replaced with USDT. An employee's consent to receive crypto, a contract denominated in US dollars, or payment by an offshore…

A group's business structure can be assessed, but "mainland fiat currency payment + offshore crypto payment" is not an inherently compliant combination. Each entity must separately satisfy market-access and regulatory…

Possibly. Neither overseas incorporation nor the failure to remit income back to mainland China can, on its own, exclude PRC tax obligations. The corporate tax residency status, the domestic establishment or source of…

A license exemption is not necessarily available. The fact that an upstream entity is authorized to exchange or make payments only means that the upstream entity may carry out the corresponding work within the scope of…

A white label is not a license that can be shared. Whether you need your own license depends on whom customers contract with, who provides the regulated services, and whether the relevant jurisdiction permits the…

Merely providing contact information and participating in transaction arrangements may lead to different regulatory outcomes; the license exemption cannot be determined based on the commission model alone. Even without…

You cannot directly borrow a bank's license to operate your own crypto payment business. Bank account opening, fiat currency transfer, or settlement services cover only the parts the bank actually undertakes and is…

First choose a bank that clearly understands and accepts the actual business, then compare fees, currencies and account-opening speed. An operating-expense account, an account that collects platform service fees, and…

A license does not mean a bank is obliged to open an account. The bank must also independently understand the actual business, the customers, the source of funds, and whether it can itself manage the relevant risks.…

First distinguish whether the funds received are the company's own payment for goods or service fees, or funds received, held temporarily and transferred on behalf of clients. The latter cannot be used directly as a…

Working with qualified institutions can be evaluated, but virtual accounts or virtual IBANs are not a uniform legal product. Some are merely collection identification numbers under a master account, while other…

Selecting a channel requires examining four matters at the same time: who actually provides the service, whether the qualifications cover the entire funds path, how customer assets are safeguarded, and who bears…

Sharing is technically possible, but it may not be permissible under law and contract. A bank's support for a given currency does not mean it accepts payers, merchants and purposes from all countries; a payment or…

There is no globally applicable "list of serviceable industries." One should simultaneously verify whether the merchant's actual business and place of sale are lawful, the scope of the payment institution's license,…

Yes. A company name, certificate of incorporation and wallet address answer only part of the question; they cannot prove what the merchant actually sells or the commercial rationale for each payment received. Goods,…

Deposits and withdrawals for exchanges and wallets generally connect fiat currency accounts with crypto asset trading or balances; they are not simply another way of collecting payment for ordinary goods sales. The…

Stablecoins may shorten the time for cross-border value transfer and processing by intermediary institutions, but on-chain transaction fees alone cannot be used to determine whether they are cheaper. Enterprises should…

Payment licensing, labor remuneration rules, tax and data responsibilities must each be addressed separately. Overseas employees and independent contractors cannot be lumped into a single category, and the parties'…

A license may still be required. A technical fee, subscription fee or exchange spread is merely a pricing method and cannot change the service actually provided. The assessment should focus on whether the platform…

Purchasing crypto assets by card requires simultaneously satisfying the target market's crypto business access requirements, acquirer approval, card network rules and risk management requirements. A successful charge…

It may lose the value corresponding to the crypto assets already delivered, and may also bear dispute-handling fees, occupied security deposits and additional operational costs. Who ultimately bears the loss depends on…

Value transfer may occur primarily on-chain, but complete cross-border collection and payment need not take place entirely on-chain. Wherever the payee requires bank fiat currency, customer identification, tax…

Multi-currency support may be explored, but it should be reviewed item by item according to "currency and issuer—service function—customer type—target market." Names such as USDT and USDC cannot substitute for legal…

A service that genuinely provides only wallet software, with users independently controlling their assets, may not constitute a custodial or money transmission business in certain jurisdictions. However, "self-hosted"…

Possibly. Swap and cross-chain functions are not automatically exempt as inherent ancillary features of self-custodial wallets; it depends on whether the platform quotes prices, accepts orders, selects routes, arranges…

The parties are generally each responsible for the services they actually provide. The fact that a deposit and withdrawal institution holds a license does not automatically bring the wallet company within the scope of…

A U-card is generally not a standalone statutory license, but rather a product combination that connects crypto assets with bank card spending. A project must separately address card issuance and payment accounts,…

As a general rule, one cannot directly promise that customers worldwide may apply. The fact that a card can be used in multiple locations is distinct from the project being permitted to open accounts for, provide…

The fact that a project issues cards or holds a license overseas does not justify directly promoting U cards that include functions such as buying and exchanging coins to residents of mainland China. Crypto services,…

Possibly, but the license required is not necessarily the same as that of the card issuer. Merely handling branding or introducing customers differs in legal role from providing payment services as an agent,…

Balance yield cannot be treated as an ordinary ancillary feature of a payment account. First, it is necessary to check whether there is a direct prohibition, and then to determine whether a lending, investment or other…

It may, but a distinction should be drawn between protecting ordinary commercial privacy and obstructing lawful verification. Reducing the public display of amounts or transaction relationships is not inherently…

This must be assessed based on the actual business, rather than automatically requiring or exempting a license simply because the product is called an AI agent. Generating payment recommendations, initiating payments,…

The most basic work is not collecting an identity card, but knowing who the customer is, why the transaction occurred, and continuously identifying and handling anomalies. The specific obligations are determined by the…

Serving only enterprises does not mean low risk, nor does it automatically lower anti-money laundering requirements. Clear business and payment materials facilitate review, but multi-tiered equity structures, agency…

Platforms subject to anti-money laundering regulation generally cannot treat anonymous accounts for unidentifiable customers as a standard service. Privacy protection, simplified due diligence and exemption from a…

Accepting only wallets controlled by the client can reduce some of the risk of account misuse and payment by unidentified third parties, but it cannot prove that the funds in the wallet are lawful. Control of the…

A third party can provide verification capabilities, but the platform still needs someone responsible for managing outsourcing, understanding the results and making compliance decisions. Whether a dedicated position is…

Anti-money laundering requirements add necessary steps, but they need not require every customer to repeatedly submit the same materials. The key to improving the experience is to align information collection with…

It may still be possible, but three situations must be distinguished: what is prohibited by law, what is subject to enhanced regulatory requirements, and what banks are simply unwilling to take on. Enhanced review can…

Attention is required, but it cannot be said that all offshore companies are directly subject to the same set of U.S. sanctions. A separate analysis should be made of U.S. persons or U.S. transaction connections, the…

Potentially yes. Where an overseas service provider receives identity documents, remotely accesses a customer database, or a bank obtains payer contact details, all of this should be included in the data-flow analysis.…

Possibly, but the platform should first verify whether it qualifies as a local reporting crypto-asset service provider and identify the specific reporting period. The Crypto-Asset Reporting Framework (CARF) is an…

Liability may still arise. Third-party custody resolves the question of who actually holds the assets; whether the platform bears obligations such as settlement, selection and supervision of counterparties depends on…

Not necessarily, but the platform cannot rely solely on a one-line disclaimer citing "market risk" or "issuer freeze." First determine whether the merchant was entitled to receive a fixed amount of fiat currency, a…

Suspension is not automatic. Whether an upstream service suspension affects the obligation to settle with customers depends on the legal basis for suspension, contractual commitments and actual impediments. A legal…

The assessment should turn on who controls the assets, who issued the transfer instruction, and why the loss occurred. Platform security defects, unauthorized operations, customer entry of an incorrect address, and…

Liability is possible, but "having processed payments for a merchant suspected of fraud" does not automatically constitute joint criminal liability. Administrative, civil and criminal liability each have their own…

Where required by applicable law, by a valid authority request or under valid contractual authorization, transactions may or must be restricted, but "risk" cannot be treated as a reason to arbitrarily withhold funds.…

There is risk, but not all customers will automatically become ordinary creditors. The outcome depends on the local insolvency law, the nature of the customer's rights, and whether fund segregation is genuinely…

Liability may be limited in part to the extent permitted by applicable law, but there is no assurance that a clause stating that "all risks are borne by the customer" will be valid. The service obligations must first…

Recourse may be assessed, but whether funds can actually be recovered depends on evidence of liability, enforceable assets and available procedures. Locating an on-chain address, sending a lawyer's letter or obtaining…

An offshore company generally has a separate legal personality, but that does not provide a comprehensive shield for an individual's own unlawful acts or guarantee obligations. Whether founders, directors and de facto…

It is possible to assess obtaining qualification or changing the business model, but a "retroactive application" is not automatic ratification and does not guarantee approval. First, it is necessary to confirm whether…

The key is not to assemble the company's documents in order, but to demonstrate that revenue derives from a sustainable lawful business, that client assets are genuinely segregated, that key partnerships can continue,…

It is not necessarily necessary to reapply for an entirely new licence, but each expansion should involve checking whether the licence, market access, asset classification and scope of cooperation have changed. A new…

It is possible to first conduct a comparison of business feasibility and regulatory pathways without immediately choosing a country or purchasing a license. An effective preliminary analysis should explain which…

Some models may be permissible, but advance funding or credit payment should be assessed separately against payment, credit extension and lending rules; the existing crypto licence cannot be assumed to cover them…

Against the backdrop of Shangcheng District, Zhejiang Province assisting clothing merchants in expanding overseas using AI tools, this article analyzes the risks of copyright infringement, ownership disputes, and…

With the application of AI agents in cross-border B2B payments, enterprises face new risks related to foreign exchange losses and compliance. Based on the latest industry developments, this article analyzes the legal…

The global expansion of large AI models faces multiple compliance challenges, including the EU GDPR and AI Act, US export controls, and China's security assessment for cross-border data transfer. This article outlines…