Scaling crypto payment platforms requires multi-license structures.

If you observe the crypto payments space over the long term, you’ll notice a fascinating yet very real phenomenon: many projects initially emphasize simplicity in structure—such as “one company, one license, one funding pathway.” In the startup phase, this structure is not only sufficient to launch operations but often enables faster product deployment and lower costs, making it a common model in the industry’s early stages. However, as business volume grows—particularly when platforms begin serving cross-border users, integrating with banking systems, or providing services to institutional clients—this simplified structure quickly reveals its limitations.

Truly large cryptocurrency payment platforms almost invariably evolve into an entirely different architecture: multiple operating entities distributed across different jurisdictions, supported collectively by various types of financial or virtual asset licenses. This structure is commonly referred to in the industry as "multi-license collaboration."

Many people interpret "multiple licenses" as a compliance upgrade, but from a business reality perspective, it is actually an inevitable structural outcome after scaling up.

At first glance, this may appear to be simply an increase in the number of licenses held by the company. However, upon closer examination from the perspective of legal structure and business logic, this change is not driven by the company’s deliberate pursuit of complexity, but rather is dictated by the regulatory framework of the global payments system. As business scales reach a certain level, companies must simultaneously comply with varying national regulations, different licensing regimes for various financial services, and institutional compliance requirements—conditions that a single license structure often cannot satisfy.

Simply put, when crypto payments begin integrating with the real financial system, increased complexity is almost inevitable.

In recent years, several representative crypto payment platforms have emerged in the Asian market, such as RedotPay, Alchemy Pay, and Triple-A. While these three companies differ in product offerings and business models, a legal structure analysis reveals that they are all gradually developing multi-entity, multi-jurisdiction, and multi-license operational frameworks.

These cases actually illustrate one thing: PayFi competition has begun to shift from product competition to structural competition.

In the early stages of the industry, most people’s understanding of crypto payments remained limited to relatively simple use cases, such as using stablecoins for everyday spending, purchasing crypto assets via bank cards, or directly transferring digital assets through wallets. From a user experience perspective, these features were essentially just payment tools, so many startup teams positioned their products as “payment solutions” or “payment gateways.”

However, observing some of the platforms that have grown rapidly in recent years reveals that their product structures are gradually evolving. An increasing number of crypto payment platforms are, in fact, building what amounts to an "account-based product structure."

Taking RedotPay as an example, from a user’s first impression, it may appear to be a stablecoin payment card platform. However, upon reviewing the General Terms published on its official website, it becomes clear that the platform offers far more than simple payments. Its service modules include custodial accounts, payment cards, asset exchange, virtual asset lending, yield products, and fiat money transfers. These features are not isolated but are integrated around a unified account system, enabling users to perform multiple operations—such as asset storage, asset conversion, spending, earning yields, and borrowing—all within the same platform.

When a platform simultaneously offers payment, exchange, custody, yield, and lending services, it becomes difficult to view it simply as a “payment tool.” From a regulatory perspective, such platforms effectively possess multiple financial service characteristics. This is why many payment platforms, although initially appearing as product innovations, eventually enter more complex regulatory frameworks as they scale.

In practice, most crypto payment platforms adopt a relatively lightweight compliance structure during their startup phase, whereby a single operating entity holds a key license to serve as the foundation for legal operations. When business scale is modest, this structure typically satisfies regulatory requirements while also reducing compliance costs. However, as the platform begins to expand into global markets, this structure often encounters several practical challenges:

First is the geographic fragmentation of regulation. There is no unified global framework for payment regulation; regulatory systems vary significantly across different countries or regions. For example: the United States relies on the MSB and MTL systems to regulate money transmission services; Europe regulates payment and crypto-asset services through the EMI and MiCA frameworks; Singapore employs the Major Payment Institution regime; and Hong Kong has the MSO and Virtual Asset Service Provider regimes. No single license covers global payment operations. This means that if a platform wishes to serve multiple markets simultaneously, a license from a single jurisdiction is often insufficient to support its full range of activities.

Secondly, product feature expansion leads to layered regulatory requirements. As the platform expands from payments to asset exchange, custody, yield, or lending, different business lines may trigger distinct regulatory frameworks. For example: payment services typically fall under payment institution regulations; custody and exchange services for digital assets may be subject to virtual asset service provider frameworks in many jurisdictions; and yield or lending arrangements may further trigger investment management, securities, lending, or other financial regulations. As products continue to expand, the regulatory structure similarly accumulates.

The third question comes from a financial partner. When a platform is small, banks or payment channels typically pay little attention to its regulatory structure. However, as the business scales—especially when the platform seeks to issue payment cards, integrate with banking clearing systems, or serve institutional clients—financial institutions usually require the company to clearly define its regulatory status. “What type of licensed entity are you?” is often an unavoidable question in all partnership negotiations. Many crypto payment projects only realize at this stage that they need to redesign their compliance structure.

In the industry, many people interpret "multi-license" as a company applying for more licenses, but in practice, multi-license coordination often means a more complex structural arrangement. True multi-license coordination is not simply about obtaining more permits; rather, it involves using legal structures to segment business operations so that different business modules can operate under distinct regulatory frameworks.

From a regulatory perspective, a seemingly simple crypto payment platform often involves multiple financial processes in its actual business chain, such as fiat currency receipt and disbursement with clearing, cryptocurrency exchange and transfer, user asset custody, and merchant settlement. In most jurisdictions, these functions are typically subject to different regulatory frameworks. If all operations are handled by a single entity, it not only increases compliance risk but also blurs regulatory responsibilities. Therefore, as the platform scales, structurally separating the business functions often becomes a more sustainable approach.

From practical experience, this structure typically consists of three levels.

• First is functional layering.

Different business modules are operated by separate entities or licensed entities. For example, payment and settlement services are typically handled by licensed payment institutions, while asset exchange or custody services may be provided by virtual asset service providers. If the platform also offers yield or lending services, these activities are often further separated into entities in other jurisdictions to ensure each type of business operates under its corresponding regulatory framework.

• Second is regional stratification.

Different markets are managed by entities licensed in their respective jurisdictions to align with local regulatory frameworks. For example, European operations are typically handled by EU-licensed entities, while Asian operations may be operated by entities in Singapore or Hong Kong. In cross-border payment scenarios, this structure enables the platform to obtain separate regulatory status in each region while avoiding regulatory conflicts between jurisdictions.

• Third is risk stratification.

Through a multi-entity structure, businesses can legally isolate financial risks, compliance risks, and regulatory responsibilities. If regulatory issues or operational risks arise in one region, they will not directly impact the entire business system. For payment platforms handling large volumes of fund flows, this risk isolation is particularly important in practice.

From a legal structure perspective, multi-license coordination is a typical cross-border financial architecture design. It addresses not how to obtain more licenses, but how to enable different functions—such as payments, exchanges, custody, and settlement—to operate compliantly simultaneously within a fragmented global regulatory landscape.

RedotPay is best known to users for its stablecoin payment card, but a careful review of its service terms disclosed on the official website reveals that its platform structure is far more complex than a single payment product. According to its General Terms, the platform offers service modules including Custodian Account, RedotPay Card, Swap, Virtual Assets Loan Services, Crypto Earn, Fiat Remittance, and Crypto Transfer.

More importantly, these services are not provided by a single entity. The terms explicitly disclose that Swap, Fiat Remittance, and Crypto Transfer services are provided by Red Dot Payment Inc., while Crypto Earn and certain asset services are provided by RedotX Panama.

In terms of regulatory identity, RedotPay’s structure also exhibits a distinct multi-jurisdictional character.

First, in Hong Kong. In 2024, RedotPay acquired a licensed Money Service Operator (MSO), granting the institution the authority to provide currency exchange and remittance services. This means the platform now has its own licensed entity for fiat currency exchange and remittances, eliminating the need to rely entirely on third-party channels.

Second, in the United States, the terms disclose that Red Dot Payment Inc. has registered with FinCEN as a Money Services Business (MSB) and holds the corresponding MSB registration number. This status indicates that it is subject to the federal MSB/AML regulatory framework; however, if its specific activities constitute money transmission under state law, compliance typically requires separate evaluation against individual state licensing requirements.

In addition, RedotPay’s structure extends to the Latin American market. Its group entity, RedotX (Tango) Limited Argentine Branch, has registered with Argentina’s National Securities Commission (CNV) under the Virtual Asset Service Provider registry and has obtained its PSAV/VASP status.

When viewed together, the structural logic of RedotPay becomes very clear:

• Hong Kong MSO handles fiat currency exchange and remittances.
• U.S. MSB supports money transfer and payment infrastructure
• Argentina VASP registration for virtual asset services
• The Panama entity is responsible for the income-generating modules.

Different businesses → Different entities → Different regulatory responsibilities.

This is a typical multi-license collaborative structure for a stablecoin payment platform.

Alchemy Pay’s business positioning differs from RedotPay, as it functions more like a payment network connecting traditional financial systems with the cryptocurrency asset market. Its core products are crypto-fiat on-ramps and off-ramps, enabling users to purchase cryptocurrency using debit/credit cards or bank transfers, and to convert digital assets back into fiat currency when needed.

Because this model inherently involves cross-border fund flows, its compliance framework must be designed for multiple markets from the outset.

In the U.S. market, Alchemy Pay enters the payment system by applying for Multi-State Money Transmitter Licenses (MTLs). The company has already obtained MTLs in multiple states, including Arkansas, Iowa, Minnesota, New Hampshire, New Mexico, Oklahoma, Oregon, Wyoming, Arizona, and South Carolina, and continues to expand its licensing to additional states. Additionally, the company has completed its registration as a Money Services Business (MSB) with FinCEN.

In the UK and other markets, Alchemy Pay integrates with local payment networks through payment institution licenses, registrations, or partnership channels; its publicly disclosed key regulatory touchpoints include the UK API, multiple U.S. state MTLs, Australia’s DCE registration, Switzerland’s VQF SRO qualification, and South Korea’s electronic financial services registration/investment presence.

In other words, Alchemy Pay’s payment network is essentially built on a global patchwork of licenses.

In the United States, fund transfer licensing is handled; in Europe, payment institution regulation is enforced; in other regions, supplementation is achieved through virtual asset or payment registration.

The technology platform is unified, but payment regulatory identities are distributed across multiple jurisdictions.

Triple-A's business model is more focused on enterprise payments, with its core product enabling merchants to accept cryptocurrency payments and settle in fiat currency.

In terms of regulatory structure, Triple-A adopts a typical "hub + extension" model.

First, in Singapore. Triple-A holds a Major Payment Institution (MPI) license issued by the Monetary Authority of Singapore (MAS). This license permits the institution to offer a variety of payment services, including Digital Payment Token Services, Domestic Money Transfer Services, Cross-Border Money Transfer Services, and Merchant Acquisition Services.

Meanwhile, the company has also established regulatory status in Europe. For example, its French entity holds an ACPR Payment Institution license and is registered with the French AMF as a Digital Asset Service Provider (DASP). This means it possesses both traditional payment institution status and digital asset service status in Europe.

In the United States, Triple-A is registered with FinCEN as a Money Services Business (MSB) and holds multiple state Money Transmitter Licenses. Additionally, the company is registered with FINTRAC in Canada as a Foreign MSB.

When viewed together, the structure of Triple-A becomes very clear:

• Singapore MPI as the Asia-Pacific hub
• French Payment Institution + DASP Serving the European Market
• U.S. MSB + MTL enters the North American payment system
• Canada Foreign MSB Additional Regulatory Status

First establish a licensed payment institution, then integrate cryptocurrency assets into the payment system. This is the most typical development path for merchant payment platforms.

When observing RedotPay, Alchemy Pay, and Triple-A together, a clear commonality emerges. Regardless of their differing business models, they all ultimately converge toward a multi-party, multi-jurisdiction, and multi-license structure. This is not a deliberate pursuit of complexity by these companies, but rather a consequence dictated by the global payment regulatory landscape. Cross-border payments involve fund custody, asset conversion, payment settlement, and merchant acquisition—each of these functions is typically governed by distinct regulatory frameworks across different countries. As a result, when a platform truly scales, a coordinated multi-license approach becomes nearly inevitable.

From an industry development perspective, crypto payments are entering a new phase. Early competition primarily focused on product experience, user growth, and transaction volume; however, as the industry matures, the challenges companies face have shifted. For example: how to help regulators understand the business model, how to encourage banks to collaborate, and how to enable capital markets to comprehend the commercial logic. In this environment, true competitive advantage is no longer just about the product, but about structural capabilities—such as legal structure design, regulatory adaptability, and risk governance.

Looking back at the development of the crypto payments industry over the past few years, a clear trend emerges. Many projects initially launched quickly with simple structures, but as they scaled globally, the single-license model often hit a bottleneck. Multi-license coordination is not merely a compliance showpiece—it’s a structural evolution. It addresses a very practical challenge: how to operate a scalable crypto payment network within a fragmented global regulatory landscape. For growing PayFi projects, this is likely an essential question they must answer in the coming years.

Original author: Attorney Shao Jiaodian