Virtual-asset services
Covers roles involving exchange, trading, custody, brokerage and other virtual-asset services.
Crypto Payments Legal and Compliance Services
Crypto payments are becoming core financial infrastructure for cross-border trade, internet businesses and digital-asset transactions. Long-term viability depends on a compliance architecture aligned with the business model, funds flow and target markets.
Mankun advises digital-asset platforms, crypto-payment providers, blockchain projects and financial institutions on cross-border structures, global licensing, regulatory engagement and risk controls.We start with the business and funds flow, then translate regulatory requirements into licensing, AML, legal documentation and day-to-day operating arrangements.
How crypto payments are regulated
Most jurisdictions do not regulate “crypto payments” as a single activity. The applicable rules depend on the business role, funds flow, control of accounts and customer touchpoints, and may include virtual-asset, payment, e-money and anti-money-laundering regimes. A stablecoin-payment product commonly falls within several regulatory frameworks at once.
Payment services
Covers collections, payouts, money transmission, merchant services, settlement and payment-account arrangements.
Electronic money
Covers e-money issuance, stored-value arrangements and related safeguarding requirements.
AML, CFT and sanctions
Covers customer due diligence, transaction monitoring, suspicious-activity response, the Travel Rule and sanctions screening.
How Mankun can help
From product design through ongoing operations, we provide connected legal support across compliance architecture, licensing, controls, documentation and disputes.
01Compliance architecture
Map the operating and funds flows early, analyse their legal character and design an executable compliance structure.- Business-model legality
- Stablecoin-payment structure
- Wallet and custody model
- Funds and operating flows
- Merchant-payment compliance
02Global licensing strategy
Match the business model, target markets and partnerships to licensing boundaries and a multi-jurisdictional plan.- Multi-jurisdictional licensing plan
- Application support
- Compliant entity formation
03AML and risk controls
Embed AML requirements into onboarding, transaction monitoring, risk grading and exception handling.- AML / CFT framework
- KYC workflow
- Transaction monitoring
- Travel Rule compliance
04Legal documentation
Draft and review the documents governing platform operations, customers, custody and merchant relationships.- User terms
- Privacy policy
- Wallet custody agreement
- Merchant services agreement
- Risk disclosures
05Frozen funds and asset response
Organise evidence and evaluate response and recovery paths for frozen accounts and digital-asset risks.- Bank-account freezes
- Exchange-account restrictions
- On-chain tracing
- Reports and judicial-cooperation materials
- Recovery-path assessment
06Disputes and criminal-risk response
Clarify facts, preserve evidence and organise a response when digital-asset, investment or criminal risks arise.- Digital-asset disputes
- Investment disputes
- Project and user disputes
- Criminal-risk assessment and defence
Global crypto-payments licensing
We assess applicable permissions, entity structures and ongoing compliance paths based on the client's role and target markets.
North America
North AmericaUS MSB
FinCENFederal registration commonly relevant to exchange, transmission and related financial services.
US MTL
State levelState money-transmitter licensing assessed against the states served, funds flow and business role.
Canada MSB
FINTRACApplies to certain virtual-asset exchange and crypto-payment services with continuing AML obligations.
Cayman VASP
CIMAMay apply to virtual-asset trading, custody and related financial services, subject to activity classification.
Europe
EuropeCASP
MiCAThe EU authorisation framework for crypto-asset service providers, classified by the services offered.
EMI
E-MoneyRelevant to e-money issuance and related cross-border payment arrangements.
PI
Payment InstitutionRelevant to money transmission, payment accounts and cross-border payment services.
Asia-Pacific and other markets
APAC & OthersHong Kong VATP
SFCThe Hong Kong licensing route for virtual-asset trading platforms, subject to current law and regulatory policy.
Hong Kong MSO
Customs and ExciseRelevant to money exchange and remittance services where a crypto-payment model includes fiat legs.
Singapore MPI + DPT
MASA combined assessment of major payment institution and digital payment token services.
Australia DCE
AUSTRACRegistration and continuing AML obligations for digital-currency exchange services.
Dubai VARA
VARADubai's virtual-asset licensing system, assessed by activity class and operating zone.
Other jurisdictions
DASP / BVI VASPIncludes routes such as El Salvador DASP and BVI VASP, evaluated against the project's objectives.
Selected clients
We advise digital-asset platforms, crypto-payment providers, payment-technology businesses and related infrastructure projects.
Planning or operating a crypto-payments business?
Tell us about the business model, target markets and current issue. We will help identify the practical next step.