First, confirm what the user is actually buying
An e-commerce payment generally corresponds to a single product or service; a deposit to an exchange may merely place funds into a tradable balance, with the coin purchase occurring afterward; a withdrawal from a wallet may involve selling crypto assets and paying funds to a bank account. Even if the interface has only one "pay" button, these arrangements differ in transaction object, delivery outcome and refund logic. They should be identified step by step along the flow of funds and assets, and an ordinary e-commerce acquiring contract cannot simply be applied.
The licence must match the segment you actually perform
For example, the Monetary Authority of Singapore (MAS) expressly brings certain facilitation of token transfer and exchange activities within the regulation of payment services, even where the service provider does not hold funds or tokens. Therefore, if a platform receives exchange instructions, arranges transactions or determines the flow of funds, it cannot conclude that it is merely providing technology solely because its partner exchange holds a licence. This is a specific example of Singapore's rules and does not mean that every country adopts the same definitions.
For card deposits, Visa's public rules separately impose coding and page information requirements for non-sovereign-currency transactions, indicating that coin purchases cannot simply be disguised as ordinary retail transactions. The specific codes, acceptable customers and onboarding conditions should be confirmed by the acquirer on a product-by-product basis; card scheme rules, financial licences and bank contracts are constraints at different levels.
Reviewing only the exchange does not necessarily reveal all risks
Assume a platform receives a consolidated settlement payment from an exchange, but the exchange actually has a large number of individual users behind it. The platform should first clarify whether it is handling the exchange's own funds or collecting and paying on behalf of its users; who reviews end users, who retains payer information, and whether information can be obtained when an investigation or refund request arises. It cannot be asserted arbitrarily that all models must re-identify every user, nor can it be assumed that corporate customers inherently shield underlying risks.
In particular, a distinction must be drawn between deposits by the customer personally, payments made by third parties on the customer's behalf, and centralized corporate payments. The three may require different supporting materials and rejection conditions. Mixing them within the same account and the same business description is neither conducive to due diligence nor easy to explain when a bank raises questions.
Test both normal and failure flows before launch
Deposits not credited, failed coin purchases, failed on-chain transmissions, refunds and account closures should each be run through, to confirm who owes what to the user at each step. It is advisable first to obtain written confirmation from counterparties on the scope of business and markets, and then to verify reconciliation fields and authority to handle exceptions. Successful technical integration only proves that the interface is usable; it does not prove that qualifications, customer relationships or risk allocation have been resolved.
Recommended actions
- Separate the exchange's own funds from end-user funds, and confirm the contracting and identification counterparties.
- Disclose the purpose of crypto deposits and withdrawals to banks and payment channels and obtain the corresponding approvals.
- Agree with counterparties on the processes for obtaining underlying information, declining transactions and investigation cooperation.
- Test reconciliation and failure handling for four categories: deposits, exchanges, withdrawals and refunds.
Information note: This article provides general information and does not replace legal advice based on specific facts.
References
- MAS expands the scope of regulated payment services — Monetary Authority of Singapore (MAS)
- Visa Core Rules and Visa Product and Service Rules, version dated 2026-10-24, Tables 7-9 and 5-15 — Visa
- Indicators of suspicious activity for virtual asset service providers — Australian Transaction Reports and Analysis Centre (AUSTRAC)
