First, examine where the event directs participants
Whether an event constitutes marketing cannot be determined solely by whether it is labeled a closed-door meeting, a technical exchange, or an investment promotion briefing. Distributing account-opening links after product presentations, inviting deposits, promising conversion into RMB, and paying channel commissions based on completed transactions will all cause the event to be connected to actual business. Suppose the first half of a seminar discusses compliance while the second half instructs mainland merchants to use overseas accounts to receive crypto and settle payments; the research nature of the first half cannot be used to cover the solicitation conduct in the second half.
Online traffic diversion and offline sales must be reviewed together
Yinfa [2026] No. 42 imposes restrictions on internet companies providing online business premises, commercial displays, marketing promotion, and paid traffic diversion, and requires strengthening relevant advertising supervision. Where domestic agents channel clients to overseas products through official accounts, community groups, QR codes, or direct messages, the fact that the final step occurs overseas does not by itself mean there is no mainland risk. Where participants know or should know that the platform is unlawfully serving the mainland, liability for assisting may also arise.
Lawful fiat currency products cannot become an entry point for crypto business
Where the same brand operates both fiat currency payment and overseas stablecoin business, the promotional page must correspond to the services that are genuinely approved to be provided to that customer. For example, if an advertisement displays ordinary cross-border collection services, and sales staff subsequently direct mainland customers to stablecoin exchange through a "faster solution," the assessment must still be based on the complete sales pathway. Changing the contracting entity between teams or moving referrals into private chats will not automatically change the service recipients and the actual business.
Content and conversion pathways can be reviewed first
General research, risk education, and commercial promotion must be distinguished based on the facts. It cannot be promised that all industry exchanges are prohibited, nor can it be promised that merely not distributing account-opening links will necessarily be lawful. Before publishing content or holding events, complete course materials, lecture scripts, registration conditions, sponsorship arrangements, and post-event contact plans should be retained, and a review should be conducted as to whether they contain inducements to product transactions. For mainland customer acquisition demands that cannot be explained, the promotion pathway should be stopped first, rather than continuing conversion by deleting words, changing groups, or hiding the brand.
Recommended actions
- Review the complete pathway from advertising and registration to sales private chats and account opening.
- Verify channel commissions, customer lists, and the actual tasks of mainland sales personnel.
- Approve research content and product solicitation separately, and retain complete versions and review opinions.
Information note: This article provides general information only and does not replace legal advice based on specific facts.
References
- Notice on Further Preventing and Addressing Risks Associated with Virtual Currency and Related Matters (Yin Fa [2026] No. 42) — People's Bank of China and seven other departments
