Can a U Card Project Issue Cards to Customers Worldwide?

Short answer

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 wallets to, or offer exchange services to local residents. The customer acquisition regions, card issuance qualifications, coverage of crypto features, and scope of use should each be determined separately, and the registration process should correspond strictly to the promotional statements.

Cross-border finance and crypto paymentsWallets, U Cards and new products

A global consumption network does not equate to global account-opening eligibility

A user using an existing card while traveling and a platform actively promoting account opening to residents of a travel destination are different legal facts. Coverage of a consumption network addresses the issue of transaction acceptance; customer eligibility also involves card-issuing product conditions, account services and access to crypto business. Even if merchants in a certain region can accept the card, it cannot be inferred on that basis that all residents of that region can apply.

The same App may have several different regional lists

The customer regions permitted by the card issuer, the markets permitted by the exchange institution and the functions the wallet can provide may not fully overlap. The fact that a fiat currency account can be opened in a certain place does not mean that all stablecoins can be purchased there; the fact that a wallet can be used in a certain place does not necessarily mean that the corresponding bank card can be applied for. The intersection should be taken based on the complete product, or regional versions should be clearly separated, to avoid users being told only after topping up that they cannot open a card or withdraw funds.

The UK FCA's guidance on payments and electronic money indicates that operating relevant services in the UK requires the corresponding qualifications or the application of an exemption; the EU's MiCA sets separate boundaries for third-country institutions providing services to EU customers. A license from a certain overseas place cannot automatically cover these markets merely by its name; local rules and the actual cooperation arrangements should be checked one by one.

Customers visiting on their own initiative is also not a reason for arbitrary global marketing

Article 61 of MiCA sets out specific arrangements for third-country services wholly initiated by customers on their own initiative, but at the same time makes clear that when an institution actively solicits EU customers, it cannot recharacterize the service as customer-initiated through contracts or disclaimers. If a U-card project bundles crypto services, the marketing methods should also be included in the review, rather than merely adding a line in the terms stating "users apply voluntarily".

Assuming a project allows residents of a certain country to apply and allows them to travel to multiple countries for consumption, the website may truthfully distinguish these two scopes; if the advertisement instead states that "residents worldwide may open accounts", while the regions where applicants are actually rejected keep changing, this will create risks of misleading and customer disputes. This comparison does not mean that a customer can obtain eligibility by providing an overseas address; the facts of actual eligibility should still be verified.

Market expansion requires a rollback-capable launch process

It is recommended that, for each new market, written confirmation from the card-issuing and crypto partners be obtained first, and then local access, marketing, customer terms and identity verification configurations be completed. For existing customers changing their place of residence or partners narrowing their scope, review, notification and exit plans should also be pre-established. Regional restrictions should not be written only at the end of lengthy terms; users should be able to see them before applying.

Action recommendations

Separately list the regions where applications are possible, the available functions and the consumption restrictions.
Verify the facts showing that the applicant genuinely meets the product conditions, rather than substituting a single telephone number for such verification.
Ensure that advertising placement, affiliate promotion, registration and top-up entry points all use the same regional strategy.
Before entering a new market, re-verify market access and partnership approvals, and design an exit process for existing customers.

This content is for general information only and does not constitute legal advice. Please consult a qualified lawyer about specific matters.

References

Payment Services Regulations 2017 and Electronic Money Regulations 2011 — UK Financial Conduct Authority (FCA)
Article 61 of MiCA: services initiated entirely by the client — EU regulations / official ESMA rulebook