Long-term observation of the crypto payment sector reveals a fascinating yet very real phenomenon: many projects emphasize structural simplicity in their early stages, such as "one company, one license, one funding path." In the startup phase, this structure is not only sufficient to support business launch but also often allows for faster and lower-cost product deployment, making it a very common model in the early stages of the industry. However, as business scales up, especially when platforms begin serving cross-border users, integrating with the banking system, and providing services to institutional clients, this simple structure quickly exposes its limitations. Truly large crypto payment platforms almost always gradually develop a completely different architecture: multiple operating entities distributed across different jurisdictions, supported by various types of financial or virtual asset licenses. This structure is commonly referred to in the industry as "multi-license synergy." Many people interpret "multiple licenses" as a compliance upgrade, but from a business perspective, it is actually an inevitable consequence of scaling up. On the surface, it seems to be simply an increase in the number of licenses held by a company, but a closer look at the legal structure and business logic reveals that this change is not a deliberate pursuit of complexity by companies, but rather determined by the regulatory structure of the global payment system itself. As businesses expand to a certain scale, they must simultaneously confront the regulatory rules of different countries, the licensing systems for different types of financial businesses, and the compliance requirements of financial institutions. A single license structure often cannot meet all these conditions at the same time. Simply put, when crypto payments begin to integrate into the real financial system, structural complexity is almost inevitable. In recent years, some representative crypto payment platforms have emerged in the Asian market, such as RedotPay, Alchemy Pay, and Triple-A. These three companies are not entirely the same in terms of product form and business model, but from a legal structure perspective, it can be seen that they are all gradually forming a multi-entity, multi-jurisdictional, and multi-license operating system. These cases actually illustrate one thing: the competition in PayFi has begun to shift from product competition to structural competition. Crypto payments are evolving from product functions into account-based financial platforms. In the early stages of the industry, most people's understanding of crypto payments was still limited to relatively simple application scenarios, such as using stablecoins for consumer payments, purchasing crypto assets through bank cards, or directly using digital assets for transfers in wallets. From a user experience perspective, these functions are indeed just payment tools, so many startup teams also positioned their products as "payment products" or "payment gateways."However, observing some of the fastest-growing platforms in recent years reveals a gradual shift in their product structures. A growing number of crypto payment platforms are actually building an "account-based product structure." Take RedotPay as an example. At first glance, it's easily perceived as a stablecoin payment card platform. However, its General Terms reveal that the platform offers far more than just simple payments. Its service modules include escrow accounts, payment cards, asset exchange, virtual asset lending, yield products, and fiat currency remittances. These functions are not isolated but rather combined around a unified account system, allowing users to perform multiple operations such as asset storage, asset conversion, consumption payments, yield generation, and lending within a single platform. When a platform simultaneously provides payment, exchange, custody, yield, and lending services, it becomes difficult to simply categorize it as a "payment tool." From a regulatory perspective, such platforms effectively possess multiple financial service attributes. This is why many payment platforms that initially appear as product innovations eventually enter more complex regulatory frameworks as they scale up. The Real-World Problems of a Single-License Structure in the Scaling-Up Phase: In practice, most crypto payment platforms adopt a relatively lightweight compliance structure during their startup phase, where a single operating entity holds a key license, which serves as the basis for the legitimacy of their business. When the business is small, this structure can usually meet regulatory requirements and reduce compliance costs. However, once the platform begins to expand into the global market, this structure often encounters several real-world problems: First, there is the fragmentation of regulation by region. There is no unified framework for global payment regulatory systems; regulatory systems vary significantly across different countries and regions. For example, the US relies on the MSB and MTL systems to regulate money transfer services; Europe regulates payments and crypto asset services through the EMI and MiCA frameworks; Singapore uses the Major Payment Institution system; and Hong Kong has the MSO and Virtual Asset Service Provider system. No single license can cover global payment operations. This means that if a platform wants to serve multiple markets simultaneously, a license from a single region is often insufficient to support all its business. Second, there is the regulatory overlap resulting from product feature expansion. As the platform expands from payments to asset exchange, custody, returns, or lending, different businesses will be subject to different types of regulations.For example, payment services typically fall under the regulation of payment institutions; digital asset services such as custody and exchange may fall under the framework of virtual asset service providers in many regions; and income and lending arrangements may further involve investment management, securities, lending, or other financial regulations. As products expand, regulatory structures also overlap. The third issue comes from financial partners. When a platform is small, banks or payment channels usually don't pay much attention to its regulatory structure. However, as business grows, especially when the platform wants to issue payment cards, connect to the bank clearing system, or serve institutional clients, financial institutions usually require the company to clarify its regulatory status. "What type of licensed institution are you?" is often an unavoidable question in all cooperation negotiations. Many crypto payment projects realize at this stage that they need to redesign their compliance structure. Multi-license synergy is essentially a structural design: people in the industry often understand "multiple licenses" as a company applying for more licenses, but in practice, multi-license synergy often means a more complex structural arrangement. True multi-license synergy is not simply "obtaining more licenses," but rather breaking down the business through legal structure so that different business modules can operate under different regulatory frameworks. From a regulatory perspective, a seemingly simple crypto payment platform often involves multiple financial processes in its actual business chain, such as the receipt and settlement of fiat currency funds, the exchange and transfer of crypto assets, user asset custody, and merchant settlement. In most jurisdictions, these functions are typically subject to different types of regulatory systems. If all business is handled by the same entity, it not only increases compliance risks but also blurs regulatory responsibilities. Therefore, as the platform scales, structurally splitting the business is often a more sustainable approach. In practice, this structure typically includes three levels. First, functional layering: different business modules are handled by different entities or licenses. For example, payment settlement is usually handled by a licensed payment institution, while asset exchange or custody services may be provided by a virtual asset service provider. If the platform also involves revenue or lending services, these businesses are often further split into entities in other jurisdictions to ensure each type of business operates under its corresponding regulatory framework. Second, regional layering: different markets are handled by different entities in different jurisdictions to adapt to local regulatory frameworks. For example, European operations are typically handled by EU-licensed entities, while Asian operations may be run by entities in Singapore or Hong Kong.In cross-border payment scenarios, this arrangement allows platforms to obtain regulatory status in different regions while avoiding regulatory conflicts between different jurisdictions. Thirdly, it enables risk stratification. Through a multi-entity structure, companies can legally isolate financial risks, compliance risks, and regulatory responsibilities. If regulatory issues or business risks arise in one region, they will not directly affect the entire business system. This risk isolation is particularly important in practice for payment platforms involving large-scale fund flows. From a legal structural perspective, multi-license synergy is actually a typical cross-border financial architecture design. It doesn't address "how to obtain more licenses," but rather how to ensure the simultaneous compliant operation of different functions such as payment, exchange, custody, and settlement within a fragmented global regulatory system. RedotPay: A multi-license combination for stablecoin account platforms. RedotPay's most well-known product among users is its stablecoin payment card, but a careful reading of its terms of service on its official website reveals that its platform structure is far more complex than a single payment product. According to its General Terms, the platform offers services including Custodian Account, RedotPay Card, Swap, Virtual Assets Loan Services, Crypto Earn, Fiat Remittance, and Crypto Transfer. Crucially, these services are not provided by a single entity. The terms explicitly state that Swap, Fiat Remittance, and Crypto Transfer services are provided by Red Dot Payment Inc., while Crypto Earn and some asset services are handled by RedotX Panama. In terms of regulatory status, RedotPay's structure also exhibits a clear multi-jurisdictional characteristic. First, in Hong Kong, RedotPay acquired a licensed Money Service Operator (MSO) in 2024, a license that allows institutions to provide currency exchange and remittance services. This means the platform already has its own licensed entity for fiat currency exchange and remittance, without relying entirely on third-party channels. Second, in the United States, its terms disclose that Red Dot Payment Inc. is registered with FinCEN as a Money Services Business (MSB) and possesses the corresponding MSB registration number. This status indicates that it has been incorporated into the US federal MSB/AML regulatory framework; however, if specific business operations involve money transmission under state law, they usually still need to be assessed individually in conjunction with the licensing requirements of each state. Furthermore, RedotPay's structure extends to the Latin American market. Its group entity, RedotX (Tango) Limited Argentine Branch, has registered with the Argentine Securities Commission (CNV) in its Virtual Asset Service Provider Registry, obtaining PSAV/VASP status.If you put all this information together, RedotPay's structural logic becomes very clear: the Hong Kong MSO handles fiat currency exchange and remittances, the US MSB supports fund transfers and payment links, the Argentine VASP registers to handle virtual asset services, and the Panama entity handles revenue-generating modules. Different businesses → different entities → different regulatory responsibilities. This is a typical multi-license collaborative structure for stablecoin payment platforms. Alchemy Pay: The licensed piece of a global fiat currency gateway network. Alchemy Pay's business positioning differs from RedotPay's; it's more like a payment network connecting the traditional financial system and the crypto asset market. Its core products are crypto-fiat on-ramp and off-ramp, allowing users to purchase crypto assets via bank cards or bank transfers and convert digital assets into fiat currency when needed. Because this model inherently involves cross-border fund flows, its compliance system must be geared towards multiple markets from the outset. In the US market, Alchemy Pay entered the payment system by applying for multi-state Money Transmitter Licenses (MTLs). Currently, the company has obtained MTLs in multiple states including Arkansas, Iowa, Minnesota, New Hampshire, New Mexico, Oklahoma, Oregon, Wyoming, Arizona, and South Carolina, and continues to expand to more states. Simultaneously, the company has completed FinCEN Money Services Business (MSB) registration. In the UK and other markets, Alchemy Pay accesses local payment networks through payment institution licenses, registrations, or partnerships. Its publicly disclosed regulatory tools include the UK API, multiple US state MTLs, Australian DCE registration, Swiss VQF SRO qualification, and registration/investment in South Korean electronic financial services. In other words, Alchemy Pay's payment network is essentially built on a global licensing puzzle. The US handles fund transfer licensing, Europe regulates payment institutions, and other regions supplement this through virtual asset or payment registrations. The technology platform is unified, but payment regulatory identities are scattered across multiple jurisdictions. Triple-A: A global regulatory network for licensed crypto payment institutions. Triple-A's business model is more focused on corporate payments, with its main product helping merchants accept crypto asset payments and settle in fiat currency. In terms of regulatory structure, Triple-A adopts a typical "central + peripheral" model. Firstly, in Singapore, Triple-A holds a Major Payment Institution (MPI) license issued by the Monetary Authority of Singapore (MAS). This license allows the institution to provide various payment services, including Digital Payment Token Services, Domestic Money Transfer Services, Cross-Border Money Transfer Services, and Merchant Acquisition Services. Simultaneously, the company also holds regulatory status in Europe.For example, its French entity obtained an ACPR Payment Institution license and registered with the French AMF as a Digital Asset Service Provider (DASP). This means it possesses both traditional payment institution qualifications and digital asset service qualifications in Europe. In the United States, Triple-A is registered as a FinCEN MSB and holds several state Money Transmitter Licenses. Furthermore, the company is also registered with FINTRAC in Canada as a Foreign MSB. Looking at this information together, Triple-A's structure becomes very clear: Singapore's MPI serves as the Asia-Pacific hub, the French Payment Institution + DASP serves the European market, the US MSB + MTL enters the North American payment system, and the Canadian Foreign MSB supplements its regulatory status. First, establish a licensed payment institution, then incorporate crypto assets into the payment system. This is precisely the most typical development path for merchant payment platforms. Industry trends behind these three cases: If we observe RedotPay, Alchemy Pay, and Triple-A together, we find a very obvious commonality. Regardless of their different business models, they all ultimately move towards a multi-entity, multi-jurisdictional, and multi-license structure. This isn't a deliberate pursuit of complexity by companies, but rather a consequence of the global payment regulatory system. Cross-border payments involve fund custody, asset exchange, payment settlement, and merchant collection, and these processes are typically subject to different regulatory systems in different countries. Therefore, when a platform truly reaches a scale, multi-license collaboration is almost inevitable. PayFi competition is shifting from product to structure: from an industry development perspective, crypto payments are entering a new phase. Early competition focused primarily on product experience, user growth, and transaction volume, but as the industry matures, the challenges companies face have changed. For example, how to convince regulators to understand the business model, how to get banks to cooperate, and how to convince the capital market to interpret the business logic. In this environment, the real competitive advantage is no longer just the product, but structural capabilities. This includes: legal structure design capabilities, regulatory adaptation capabilities, and risk governance capabilities. Conclusion: Looking back at the development of the crypto payment industry over the past few years, a very clear trend emerges. Many projects launched quickly in their early stages relying on simple structures, but as businesses go global and scale, the single-license model often encounters bottlenecks. Multi-license collaboration is not a compliance stunt, but a structural evolution. It addresses a very real problem: how to operate a large-scale encrypted payment network within a fragmented global regulatory framework. For the emerging PayFi project, this is likely a crucial question it will have to answer in the coming years. (Recommended course, original author: Lawyer Shao Jiadian)