Decide on the new service first, not buy the system first
The team should first answer what commitment it intends to offer to whom: give merchants an additional payment collection method, make payments on behalf of enterprises, or let users hold and transfer out stablecoin balances? For the same payment company to offer these three types of products, the required licenses, wallet permissions and customer terms may differ. The specific financial institution pathway under Article 60 of the EU's MiCA also has service limitations; one cannot presume that all new functions merely require notification simply because traditional payment qualifications are already held.
The ledger needs to explain both bank money and on-chain assets
The original "order success" may have relied mainly on payment channel receipts; after adding on-chain transfers, it is also necessary to define when a transaction is considered finally completed, and how to handle wrong chains, insufficient receipt and incomplete exchanges. It is recommended to distinguish order amount, token holdings, exchange price and final settlement amount, so that customer receivables, platform inventory and on-chain addresses can be reconciled. Do not treat all stablecoins as equivalent US dollar deposits, and do not directly equate on-chain success with receipt into the merchant's bank account. The existing finance and customer service teams also need to understand these statuses in sync, to avoid manual oral explanations of delays after the system marks "completed." A single order can first be used to run through finance, technology and customer service for full-process acceptance testing.
Risk control extends from bank cards to wallets and partner institutions
EU MiCA governance requirements include appropriate personnel, continuous operations and secure information technology arrangements; Singapore's 2024 related measures also strengthened DPT customer asset protection. At the product level, the team should clarify private key and signing permissions, wallet backups, on-chain transaction review, and handling when upstream services are suspended. Using third-party custody or on-chain analytics tools can provide capabilities, but the company still needs to know who judges alerts, who can stop payments and who explains to customers.
Test the business model with one hypothetical corridor
For example, first provide one stablecoin, one network and one fiat settlement method to specific overseas merchants in markets that permit receiving coins, rather than supporting global wallets and multi-currency balances on day one. When assessing, simultaneously calculate exchange spreads, on-chain fees, exception handling, banking channels and personnel costs, and first obtain confirmation from partners on the nature of the business. If the original customers are mainly located in mainland China, the current restrictions should be assessed first, rather than directly migrating domestic merchant resources under an overseas entity's name.
Action recommendations
- Clarify which functions in the first version are limited to payment collection, payment disbursement or balance wallets, and freeze functions that have not been assessed.
- Complete four-way reconciliation testing of the order ledger, on-chain addresses, exchange records and bank receipts.
- Use drills involving freezes, wrong chains and upstream service suspension to confirm the respective authority of customer service, finance, technology and compliance.
Information note: This article provides general information only and does not replace legal advice based on specific facts.
References
- MiCA Article 60 — ESMA
- MiCA Article 68 — Governance arrangements — ESMA
- MAS expands scope of regulated payment services — MAS
- Notice on Further Preventing and Addressing Risks Associated with Virtual Currency and Related Matters — People's Bank of China and seven other departments
