Red-line orientation for teams with China nexus—not investment advice and not a how-to for unlawful token offerings. Overseas structures do not erase China risk when persons, promotion or infrastructure remain onshore.
Framing: Educational map only. Engage licensed counsel before any token, NFT marketplace or payment product.
China red lines (high level)
Since 2017–2021 policy packages, Chinese authorities have treated cryptocurrency exchange services aimed at China residents and token fundraising (ICO-style) as prohibited or severely restricted under notices issued by the PBOC and other agencies (including the September 2021 notice on further preventing and disposing of virtual-currency speculation risks—confirm full titles and current posture with counsel). Banks and payment institutions are restricted from serving virtual-currency business. Criminal exposure can arise under illegal business operations, illegal fundraising, fraud and related offences when facts support them.
Offshore entity myths
- A Cayman or Singapore company does not legalise marketing tokens to mainland users
- Overseas domains with China-based promoters remain a China nexus fact
- Education or technology covers are tested against substance
- Underground RMB on/off ramps create separate criminal risk
Host licences and AML
Truly non-China projects still face securities tests, VASP/MiCA-style frameworks, money-transmission licences and sanctions screening. AML/CFT programs and transparent UBOs are table stakes—align with CRS / tax residence honesty on controlling persons.
Next steps
Industry rules change quickly. Confirm licences, ratings, and host-country rules for your product before launch.
