Observation: From Ctrip's Trial of Stablecoin Payments, to the Construction of Criminal Risk Isolation and Compliance Frameworks for Chinese Companies Going Global - Part 2

The first part of this article takes the specific case of Ctrip's overseas version's trial of stablecoin payments as a starting point to deeply analyze the most fundamental criminal risk prevention and control strategies for Chinese companies going global.

Author: Lawyer Shao Shiwei

On December 25, 2025, media reported that Trip.com, the overseas platform under the Trip.com Group, had launched stablecoin payment functionality for global users, supporting the use of USDT and USDC to book hotels and flights. This move unexpectedly puts it at the forefront of many Chinese internet giants in the field of digital payment innovation—previously, Ant Group and JD.com had both "suspended" their stablecoin plans in Hong Kong.

Ctrip's attempt should not be viewed merely as a simple upgrade to its payment methods, but rather as a highly representative strategic choice against the backdrop of a still ambiguous global regulatory environment for digital assets. It not only explores possible paths forward for its own business but also provides an important case study and reference point for the entire industry.

The first part of this article used the specific case of Ctrip's overseas version's trial of stablecoin payments to deeply analyze the most fundamental criminal risk prevention strategies for Chinese companies going global. We mentioned that merely establishing the company's main entity overseas as "structural isolation" is a major misconception, and systematically elaborated on the three cornerstones of achieving "substantive compliance": overseas business operations, overseas personnel, and overseas capital. The aim was to build a cognitive framework for fundamentally isolating domestic legal risks.

Three core points for companies going global to build a substantive compliance framework

4. Capital outflow overseas

In this context, "capital outflow" primarily refers to whether and how business profits flow back to the domestic market. The risks at this stage vary greatly, often becoming the key to determining whether a business has truly achieved "risk isolation."

If profits generated from overseas operations are not repatriated but instead remain with the overseas entity for reinvestment locally or distribution to overseas shareholders, the risk is relatively controllable. This approach effectively severs the financial umbilical cord between sensitive overseas operations and the domestic entity. The overseas subsidiary, as an independent profit center responsible for its own profits and losses, sends a clear signal to regulators:

This is a purely overseas business, and its success or failure and risks are borne entirely by the overseas entity. It will not directly affect the domestic financial system and economic order through capital flows. Therefore, the urgency and justification for holding it accountable based on the principles of "personal jurisdiction" or "territorial jurisdiction" are greatly reduced.

Conversely, if profits from overseas operations flow back into the country through various channels (including cryptocurrency exchange, fictitious trade, underground banks, etc.), the nature of the transaction is entirely different. This not only provides regulators with clear leads for financial investigations, but more importantly, it constitutes substantial evidence that relevant domestic individuals or entities have directly profited from overseas "gray market" activities.

For example, one reason why many of the platforms handled by Attorney Shao's firm, despite operating overseas, were still investigated by domestic judicial authorities is that the profits these platforms earned overseas were either channeled back to China in the form of virtual currency or other means. Once profits flow back, they provide a basis for domestic law enforcement agencies to conduct penetrating supervision.

Leveraging external resources: Ctrip's overseas compliance path and market selection strategy

After establishing a basic framework for mitigating domestic legal risks, the next key challenge for companies going global is how to achieve localized compliant operations in target markets. Ctrip has adopted a strategy of "licensed cooperation and scenario-based entry," leveraging licensed partners to address the most complex financial compliance issues while focusing on its strengths in tourism scenario operations and user services.

Trip.com's recently launched stablecoin payment feature does not handle cryptocurrency payments directly. The service is entirely supported and compliant by its partner, Triple-A, a licensed cryptocurrency payment institution in Singapore.

This means that Ctrip itself does not need to directly apply for complex cryptocurrency payment licenses in various countries, but instead "outsources" its professional technology and compliance responsibilities to partners who have already obtained licenses from authoritative institutions such as the Monetary Authority of Singapore (MAS). This approach greatly reduces the compliance threshold and time costs for Ctrip when entering new markets.

A concrete example is its implementation in the Vietnamese market. Why can users in Vietnam use stablecoins to pay for hotels and flights through Trip.com? Although neither Trip.com nor Triple-A has disclosed specific details, this is most likely due to leveraging Vietnam's flexible regulatory pilot framework.

In recent years, Vietnam's attitude toward cryptocurrencies has undergone a significant shift, moving from a complete ban to a regulatory experiment aimed at legalization.

In particular, in 2025, the Vietnamese government launched a five-year pilot program for the cryptocurrency market[i], aiming to establish a controlled “regulatory sandbox” environment. Previously, Da Nang and other locations had discussed pilot programs for stablecoin payments to international tourists[ii]. It can be inferred that Triple-A, as a licensed service provider, likely leverages its Singapore master license to connect with Vietnam’s local regulatory sandbox or specific exemption framework, thereby enabling its payment services to legally cover Vietnam’s tourism consumption scenarios.

This market choice is inextricably linked to Vietnam's extremely high adoption rate of crypto assets. Data shows that the total value of Vietnam's cryptocurrency market has exceeded $220 billion, boasting a massive user base. A Chainalysis report also points out that Vietnam consistently ranks among the top in global cryptocurrency acceptance. Choosing a market with a clear shift in regulatory attitude and significant real-world demand as a starting point not only reduces market education costs but also makes a cooperation model based on a "regulatory sandbox" more feasible.

In conclusion, Ctrip's approach offers clear insights for companies expanding overseas: when developing cutting-edge businesses such as stablecoin payments, instead of struggling alone to apply for high-threshold licenses in unfamiliar jurisdictions, it's better to prioritize partnerships with compliant service providers already holding stringent licenses in major financial centers (such as Singapore), and precisely select countries and regions undergoing regulatory innovation with significant market potential as testing grounds. This is essentially a "leveraging existing resources" strategy, efficiently capturing market opportunities through professional specialization while controlling risk.

Implications and Recommendations: Building a Sustainable Framework for Going Global in a Dynamic Balance

It's important to clarify that Ctrip's foray into stablecoin payments on its overseas platform is essentially a dynamic balancing act between business innovation and compliance in a global regulatory environment where standards are still evolving. This article uses this as an example to provide a reference for risk management for companies expanding overseas, rather than making a definitive judgment that their business model is "fully compliant."

In multinational business, risk is never an absolute question of "present" or "absent," but rather a relative assessment of "high" or "low" depending on the time period and policy environment. Based on the foregoing analysis, we offer the following framework recommendations for payment companies or technology companies seeking similar overseas expansion:

First, architecture and risk isolation.

Enterprises should operate innovative businesses by establishing completely independent overseas legal entities, thereby building a clear legal, financial, and operational "firewall" between themselves and their domestic entities. The core of this approach is to pre-define the boundaries of risk and liability in a legal sense, ensuring that potential disputes or regulatory investigations arising from overseas operations do not directly penetrate and impact the core domestic entity, thus achieving truly effective risk isolation.

Second, a prudent compliance strategy.

When entering a new market, priority should be given to establishing partnerships with local licensed institutions that already possess full qualifications, while participating as a "technology service provider" or "scenario provider." This is essentially a smart "borrowing a boat to cross the sea" strategy, which helps companies avoid the huge costs, long cycles, and policy uncertainties of directly applying for high-threshold financial licenses in the early stages, thereby leveraging the existing qualifications of partners to enter the market quickly and steadily.

Third, differentiated KYC/AML design.

While meeting global regulatory bottom lines on anti-money laundering and customer due diligence, companies should adopt flexible and pragmatic strategies. The key lies in implementing differentiated processes based on the actual risk level of the transaction: for low-risk, small-amount, high-frequency transactions (such as hotel bookings), simplified verification processes that prioritize user experience can be adopted; while for high-risk, large-amount, or special-nature transactions (such as airline ticket purchases and cross-border transfers), stringent industry regulatory requirements must be followed. This approach aims to maintain core compliance requirements while seeking the optimal balance between user experience and compliance.

Fourth, precise market selection.

The first step in going global, market selection, is itself a crucial risk decision. Companies should prioritize entry points into regions that are "regulatory friendly" and have genuine demand, such as Southeast Asia or Latin America, where regulatory sandboxes or pilot programs have been launched, fiat currencies are highly volatile, and traditional payment services have insufficient penetration. This not only effectively reduces uncertainty caused by sudden policy changes but also ensures a solid user base and application scenarios, thereby increasing the probability of successful pilot programs and accumulating valuable local compliance experience for future expansion.

Fifth, the business logic of deep integration.

We must adhere to a scenario-driven approach, rather than a payment tool-driven one. Successful innovative payments should not be isolated financial functions, but rather deeply embedded in a company's existing and mature business chain (such as e-commerce platforms, travel bookings, or digital services). The goal is to directly address users' specific pain points, such as convenient cross-border payments or asset preservation needs, thereby building a complete value loop of "service + payment." Only in this way can payments evolve from a simple transaction channel into a core component that enhances user stickiness and strengthens business barriers, avoiding becoming an isolated adventure detached from the core business.

In summary, the goal of compliance practices for enterprises going global is not to create an absolutely safe zone without any risk. Rather, it is to systematically identify, assess, and manage various risks by recognizing that risks are inevitable, through building a rigorous legal framework, selecting reliable local partners, and continuously deepening understanding of the target market and regulatory environment. Ultimately, in the dynamically changing global market, risks are kept within acceptable limits, thereby supporting the business in seizing opportunities and achieving steady and sustainable long-term development.

[i] Asia's RWA Window: Vietnam's Policy Floodgates and Hong Kong's Standardization Race | PANews https://www.panewslab.com/zh/articles/7vborc8go5t5

[ii] Vietnam launches pilot program for crypto asset market | Nhan Dan Online https://cn.nhandan.vn/article-post142446.html

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