Authors: Iris, Lu Wenlong
In the past two days, the public opinion about "some CEXs providing contract experience bonuses to college students" has continued to ferment in Web3 Chinese social media. The cause of the incident was a revelation post published on the X platform, which attracted a lot of attention and discussion because it involved sensitive keywords such as "CEX", "college students" and "gamblers".
Lawyer Mankiw read the comments under the post and found that the mainstream voice generally opposed this promotion method, believing that college students have not yet established mature values and risk awareness and should not be targeted for promotion. For example, the media BlockBeats published an article "Please all trading platforms immediately stop promoting contract experience gold to college students", directly pointing out that such behavior is essentially "gambling inducement in the guise of financial enlightenment"; Yu Xian of SlowMist Technology also forwarded the support and supported a comprehensive boycott.
However, some people said that they were not surprised by this. Some people said that they had come across similar promotions during their college years, while others believed that college students were adults and had civil capacity, and that it was a personal choice to accept the loss.
It is this difference in views that made attorney Mankiw realize that campus promotions such as the "Campus Ambassador" program, which are defined as education, enlightenment, and technology communication, have actually been implemented in many campuses and have become a path for some Web3 project brands and even regular customer acquisition.
As a law firm that focuses on serving the Web3.0 industry, Mankiw has also worked with the University Chain Association on many occasions to jointly organize compliance lectures and other activities. In these processes, we have observed a common problem: whether it is individual students or student organizations represented by the Chain Association, when facing Web3 project cooperation, they generally lack the basic ability to judge whether the promotion behavior is compliant.
As a result, a key question has surfaced: Can college students participate in the Web3 Campus Ambassador Program? Which behaviors are safe when cooperating with Web3 project parties? Which behaviors may cross the line?
Is the campus ambassador program of the virtual asset trading platform reliable?
There is almost no dispute about the compliance issues of the "contract experience money" incident that has sparked widespread discussion.
According to my country's current regulatory system, whether it is a domestic entity or an overseas platform, as long as it promotes unregistered high-risk financial derivatives, such as contract trading and leveraged products, to domestic residents, it is suspected of illegal financial activities. Even if it is packaged as "experience money", as long as the behavior essentially constitutes guiding transactions, it is not legal.
But the compliance issues don’t end there.
In recent years, many CEX ambassador programs on campus are no longer limited to "trading incentives" themselves. There are also more seemingly harmless but actually risky promotion models, including but not limited to:
*Screenshot of a campus promotion mission of an exchange
1. App promotion and registration guidance
Some campus ambassador programs require participants to guide classmates to download and install exchange apps and complete registration, and sometimes they also provide incentive mechanisms such as "invite for prizes" and "bind and get bonuses". Such behavior is packaged as "new user education" or "usage guidance" in platform promotions, but in essence it is very close to unauthorized financial promotion.
According to relevant Chinese laws, any act of promoting financial products to unspecified individuals or guiding account opening and trading within the country requires a corresponding financial business license. Although college students have not signed a formal agency agreement in such promotional activities, their actions essentially constitute de facto marketing representatives or traffic diversion parties. Once a transaction dispute occurs or regulatory intervention is triggered, the responsibility is not ambiguous.
2. Brand promotion and content output
There is also a more covert mechanism, where ambassadors assist in the brand promotion of exchanges, such as sharing brand promotion articles in social media communities, participating in social media interactions, organizing lectures, etc. This type of operation is often understood as "content internship" or "promotion volunteer", but its actual effect has already affected the platform's image and trust building.
In China, there are also regulatory barriers for external promotion and brand communication involving financial platforms. Especially when these contents touch on sensitive information such as "trading experience", "asset security" and "compliance commitment", they are likely to be identified as unauthorized financial advertisements. For organizers, they still cannot evade legal responsibilities.
3. Technical lectures and industry science popularization
Some platforms will cooperate with campus clubs to carry out activities through "Web3 technology open courses", "blockchain introductory lectures", "industry development sharing sessions", etc. On the surface, this kind of content does not directly lead to registration or transactions, and seems to be less risky.
However, two points should be noted: first, whether the organizer clearly marks the platform identity, and second, whether there is platform diversion or product exposure in the content. If it is initiated by a certain CEX and introduces its product structure, trading advantages and other related content in the lecture, even if the lecture theme is "Current Status of the Crypto Industry", it may be regarded as a financial promotion behavior that skirts the rules.
Is the Web3 project's campus ambassador program safer?
Compared with the high-risk marketing path of virtual asset trading platforms, the "campus ambassador" programs set up by many Web3 project parties seem much milder. They often do not touch on trading products or promise returns, but guide students to participate in co-construction.
But is this kind of ambassador mechanism safe?
Many people may tend to think: "This is just the dissemination of knowledge" and "It is not illegal not to touch the currency."
However, from the perspective of legal practice , “compliance” depends on the function and impact of the behavior, not whether the project itself is decentralized or non-profit. For example, the following two categories are the most common but easily misjudged forms of cooperation:
1. Promotional Ambassador/Community Building
Some Web3 project owners will invite students to become "campus ambassadors" and encourage them to promote or speak on behalf of the project on social media and offline events. For example, in 2024, the Chinese community of a well-known public chain recruited campus ambassadors, requiring students participating in the program to create high-quality content, operate the community, disseminate ecological information, and hold offline events on campus, etc.
Or they can become campus community organizers/builders, guiding college students to help the project divert users. For example, in 2023, a decentralized social platform publicly recruited campus ambassadors from universities around the world to build and expand the project's campus user community.
This type of cooperation is often packaged as "content contribution", "community autonomy" and "decentralized culture", which downplays its commercial attributes and blurs the legal boundaries between participants and project parties. However, in terms of actual results, students have essentially assumed the dual roles of brand communicators and traffic participants by producing articles, publishing videos and organizing activities.
Potential compliance risks of such behavior include:
Actual endorsement but unclear identity
Although the project may not have explicitly authorized it, when the student ambassadors’ content is “structured, regular, and interconnected” and even appears in official account reposts and poster co-signs, their dissemination behavior can easily be mistaken by the outside world as the official position of the project. Once the content involves sensitive information such as future plans, token structure, and ecological incentives, students may be identified as “de facto promoters.”
The diversion path is hidden but the result is clear
In the articles or activity promotions published by students, there may be embedded task entrances such as registration paths, joining communities, filling in wallet addresses, and binding email addresses. Although no income is promised, it is often linked to airdrop points, testing qualifications, or future governance rights. This "non-transaction path diversion" still poses a potential risk of financial activity exposure in China.
Incentive mechanisms are difficult to judge
Ambassador programs are mostly structured as "content rankings", "project points", "reputation system within DAO", etc. In the early stage, since the project party does not directly issue coins or monetary incentives, it is difficult for students to realize the importance of their roles and legal responsibilities. However, once the platform is investigated for violations afterwards, the student content may become part of the chain of evidence.
2. Brand cooperation/joint events
In addition to individual university student participation, another common cooperation model for Web3 project parties on campus is to jointly organize activities or build brands with student organizations (especially blockchain associations). For example, online and offline joint activities are carried out under the names of "technical lectures", "DAO open classes", "developer hackathons", "Web3 trend seminars", etc., or brand exposure is embedded in event materials, speaker arrangements, and publicity channels through sponsorship.
This type of cooperation often does not involve explicit monetary transactions. Project parties often participate as "content supporters" or "co-organizers", and the Chain Association is responsible for implementation and docking with campus resources. Since there is no capital flow, student organizations often regard it as a pure technical exchange or industry learning project, lacking basic recognition of compliance issues.
However, in reality, once virtual assets-related content displays and user guidance paths appear in activities, or cooperation is not approved and registered by the school, student organizations may be substantially involved in the legal risk of "assisting illegal financial activities". For example:
The activity form is neutral, and the content is substantive
Although some activities are under the banner of "technical themes", the actual content includes project mechanism introduction, economic model disassembly, airdrop qualification notice and other links, or QR code scanning, joining the project group, filling out test forms and other participation paths in the PPT/speech. If this kind of promotion behavior is not disclosed and restricted, even if the student organization does not directly make a profit, it may be identified as a promotion assisting party.
The project identity is unclear and the boundaries of cooperation are unclear
If some project parties are overseas DAOs, unregistered entities or "proposed coin issuance platforms", their legal qualifications themselves are unclear. If student organizations assist them in spreading and organizing activities on campus, they may be regarded as providing convenience for overseas unregistered VASPs, touching the policy red line.
Unapproved brand exposure on campus
Some student organizations may directly use project logos and official website links in activities, or even be listed as "organizers/partners" in promotional posters alongside the project owners. If they do not apply to the school for permission for on-campus promotion or brand cooperation, the organization may be left without protection under the law or school discipline. Once complaints or disputes arise during an event, student organizations may be held accountable.
Attorney Mankiw recommends
As the Web3 industry is developing rapidly, college students, as the most active technology adopters and community building forces, do have a natural enthusiasm for participation and construction value. Therefore, Attorney Mankiw strongly supports college students to participate in technological innovation and ecological co-construction, and encourages the University Chain Association to become an important node in promoting industry awareness.
However, "participation" does not mean "letting go", so we suggest starting from the following three directions, and setting up a practical framework based on the principle of "what can be done and how to do it more safely":
Clearly participate in the positioning, do not be a "spokesperson"
If you are a project ambassador, content creator, or community contributor, it is recommended that you clearly indicate "personal opinions, not official project opinions" in your profile and posts to avoid misleading others or taking responsibility for factual endorsements;
At the same time, it is not recommended to participate in the writing of content involving future income or distribution rights such as project token mechanisms and governance structures. Especially when disseminating on domestic platforms, words such as "expected income", "airdrop time", and "price outlook" should be avoided.
Keep risk records when participating in on-chain activities
If you plan to participate in project internal testing, on-chain interaction, wallet binding and other activities, it is recommended to keep a screenshot of the original project rules and regulations to confirm that it does not involve contract transactions, leverage guidance or asset fundraising; if you need to invite others to participate, you should actively remind them that "the project has not been registered or filed in China, and there is uncertainty about related rights and interests" to avoid misleading or joint liability due to invitation behavior.
Student organization cooperation needs to follow the "on-campus compliance path"
Before engaging in joint activities with any Web3 project, the blockchain association/student organization should complete three actions:
Clarify the identity and legal registration place of the project party;
Submit the cooperation content to the school for approval (such as external brands, online activities, funding, etc.);
Create a risk warning page or compliance disclaimer to reduce the organizer’s legal liability for event content.
Compliance does not mean rejecting exploration, but making exploration a career worthy of long-term investment.
We welcome students to join the construction of Web3, and we also welcome project parties to establish a co-creation mechanism with the campus. However, under the premise of cooperation, please draw clear legal boundaries in advance to ensure that every attempt is "traceable, traceable, and exempt from liability."
