First confirm whether you are selling crypto assets or merely providing a payment entry point
If a platform quotes prices to users and sells crypto assets in its own name, its eligibility to provide trading services must be reviewed; if users purchase crypto assets directly from an independent third party, the platform must also review whether it is receiving orders, arranging transactions or promoting regulated services. Taking Article 3 of the EU's MiCA as an example, exchanging own funds and executing orders on behalf of clients are distinct service items, and not all of them can be placed within "acquiring technology."
Disclose the true transaction to the acquirer, rather than relabeling it as another product
Visa's public rules contain dedicated coding arrangements for transactions involving the purchase of non-sovereign currencies and require the payment page to disclose relevant information. These are card network rules, not a government license. Actual onboarding should also require the acquirer to confirm the applicable transaction type, customer region, processing path and whether it accepts such business. Purchasing crypto assets must not be packaged as software, membership or other goods in order to obtain a channel that would otherwise not apply.
The payment page should enable users to understand the currency they are purchasing, the total cost, the delivery destination and refund restrictions. The above information is not only used to reduce misunderstandings, but also affects whether it can later be explained what the user actually agreed to. Transaction coding and page disclosures should be tested together to avoid a situation where the front end displays a crypto asset purchase while the back end reports it as an ordinary good.
A card having been authorized is not the same as the risk having ended
Assume that after a user pays by card, the platform immediately sends the assets to a wallet that the platform cannot recall. If card fraud or another dispute subsequently occurs, on-chain delivery cannot automatically prevent the bank card dispute process. The Visa Merchant Dispute Guide distinguishes fraud, processing errors and consumer disputes, and identity verification is not a guarantee that covers all disputes.
Therefore, risk management checks and failure handling should be specified before delivery is permitted. For example, where payment is authorized but the exchange fails, the asset transfer fails or the user submits an order repeatedly, it is necessary to design who reverses the charge, who bears the price difference and how duplicate refunds are avoided. Assets must not be held indefinitely for the purpose of preventing chargebacks, nor should users be promised that no refund is possible under any circumstances.
Divide the launch checklist into three columns: legal, channel and operations
The legal column confirms the service entity and market permissions; the channel column retains the acquirer approval, transaction codes and rule versions; the operations column verifies reconciliation, refunds, fraud review and customer service evidence. Only when all three columns are completed is there a basis to assess launch. There is no uniform answer on security deposits, settlement cycles and fees; these should be calculated based on the actual contract, with particular confirmation of disputes that may still arise after termination of cooperation and arrangements for retention of funds.
Recommended actions
- Confirm the entities that sell the assets, receive card payments and deliver the assets, as well as the scope of each entity's licenses.
- Obtain the acquirer's written approval of the use for purchasing crypto assets and the target cardholder market.
- Verify the payment page information, transaction codes and asset delivery records.
- Test abnormal paths such as a successful charge but failed exchange or delivery, duplicate payments and refunds.
Information note: This article provides general information and does not replace legal advice based on specific facts.
References
- MiCA Article 3: Definitions — EU regulations / ESMA official rulebook
- Visa Core Rules and Visa Product and Service Rules, version dated 2026-10-24, Tables 5-15 and 7-9 — Visa
- Visa Dispute Management Guide for Merchants, October 2026 edition — Visa
