Recently, discussions in Chinese Web3 social media regarding 'some CEX offering contract experience coupons to college students' have been intensifying. The incident originated from a post on platform X, which involved sensitive keywords such as 'CEX', 'college students', and 'gamblers', attracting a lot of attention and discussion.
Mankun Lawyer found that mainstream voices generally oppose this type of promotion method in comments under the post, believing that college students have not yet established mature values and risk awareness, and should not be targeted for promotion. For instance, media BlockBeats published an article (urging all trading platforms to immediately stop promoting contract experience coupons to college students), directly pointing out that such behaviors are essentially 'gambling inducements disguised as financial enlightenment'; Yu Sen of Slow Fog Technology also shared support for comprehensive resistance.
However, there are also some voices that express 'nothing new'. Some people say they encountered similar promotions during their university years, while others believe that college students are adults, have civil capacity, and that willing to gamble and accept losses is a personal choice.
It is this divergence of viewpoints that made Mankun Lawyer realize: Campus promotions defined as education, enlightenment, and technology dissemination, similar to 'Campus Ambassador' programs, have already taken root in many campuses and become a pathway for some Web3 projects' branding and even routine customer acquisition.
As a law firm focused on serving the Web3.0 industry, Mankun Lawyer has also cooperated multiple times with university chain associations to jointly hold compliance lectures and other activities. During these processes, we observed a common issue: whether for individual students or for student organizations represented by chain associations, there is a general lack of basic judgment capability regarding 'whether promotional behaviors are compliant' when facing Web3 project cooperation.
Thus, a key question arises: Can college students participate in Web3 campus ambassador programs? In collaboration with Web3 project parties, which behaviors are safe? Which ones might cross the line?
Are campus ambassador programs for virtual asset trading platforms reliable?
The 'contract experience coupon' incident that has sparked widespread discussion has compliance issues that almost do not require debate.
According to China's current regulatory framework, whether domestic entities or foreign platforms, any promotion of unregistered high-risk financial derivatives, like contract trading or leveraged products, aimed at domestic residents is suspected of illegal financial activities. Even if packaged as 'experience coupons', as long as the essence of the behavior constitutes guiding transactions, it lacks legality.
But compliance issues do not stop there.
In recent years, many CEX campus ambassador programs have emerged, not limited to 'trading incentives' itself, but also more seemingly harmless yet actually ambiguous risk promotion models, including but not limited to:
* Screenshot of a certain exchange's campus promotion task
1. App Promotion and Registration Guidance
Some campus ambassador programs require participants to guide classmates to download trading platform apps and complete registrations, sometimes coupled with incentives like 'invite to win prizes' or 'binding rewards'. These behaviors are often packaged as 'new user education' or 'usage guidance' in platform promotions, but their essence is very close to unauthorized financial promotions.
According to relevant Chinese laws, any behavior promoting financial products or guiding account trading to unspecified targets within the country requires appropriate financial business licenses. In such promotional activities, although college students do not sign formal agency agreements, their actions effectively constitute factual marketing representatives or dividers. If trading disputes arise or regulatory interventions occur, responsibilities are not ambiguous.
2. Brand Promotion and Content Output
Another more covert mechanism involves ambassadors assisting in exchange brand promotion, such as sharing brand promotional articles in social media communities, participating in social media interactions, organizing lectures, etc. These operations are often understood as 'content internships' or 'promotion volunteers', but their actual effects have already impacted platform image and trust building.
In China, external promotion and brand communication involving financial platforms also have regulatory thresholds. Especially when these contents touch on sensitive information like 'trading experiences', 'asset security', or 'compliance commitments', they are highly likely to be deemed as unauthorized financial advertising. For organizers, legal responsibilities cannot be avoided.
3. Technical Lectures and Industry Popularization
Some platforms hold activities jointly with campus organizations through 'Web3 Technology Public Courses', 'Blockchain Introduction Lectures', 'Industry Development Sharing Sessions', etc. On the surface, such content does not directly guide registration or trading, appearing to have lower risks.
But two points need attention: firstly, whether the organizer clearly marks the platform identity, and secondly, whether there is platform diversion or product exposure in the content. If initiated under the name of a certain CEX and introduces its product structure, trading advantages, etc., even if the lecture topic is 'current state of the crypto industry', it may still be seen as a borderline financial promotion.
Is the campus ambassador program for Web3 projects safer?
Compared to the high-risk marketing paths of virtual asset trading platforms, many 'campus ambassador' programs established by Web3 project parties appear much milder. They often do not touch on trading products or promise earnings but instead guide students to participate in co-construction.
But is this type of ambassador mechanism safe?
Many people may lean towards thinking: 'This is just knowledge dissemination, it doesn't touch on currencies, so it’s not illegal.'
However, from a legal practice perspective, 'whether compliant' depends on the function and impact of the behavior, not on whether the project itself is decentralized or non-profit. For example, the following two types are the most common but easily misjudged forms of cooperation:
1. Ambassador/Community Building
Some Web3 project parties invite students to become 'campus ambassadors', encouraging them to represent the project in promotions or speeches in social media and offline events. For example, a well-known public chain's Chinese community recruited campus ambassadors in 2024, requiring participating students to create quality content, manage communities, disseminate ecological information, and organize offline activities on campus, etc.
Or becoming campus community organizers/builders, guiding college students to help projects with user diversion. For example, in 2023, a decentralized social platform publicly recruited campus ambassadors in universities worldwide to establish and expand the project's campus user community.
Such collaborations are often packaged as 'content contribution', 'community autonomy', and 'decentralized culture', downplaying their commercial nature and blurring the legal boundaries between participants and project parties. However, in practice, students have substantially taken on the dual roles of brand communicators and diversion participants through producing articles, publishing videos, and organizing activities.
Potential compliance risks of such behaviors include:
Actual endorsement but ambiguous identity
Although project parties may not have explicitly authorized, when the content created by student ambassadors is 'structured, regular, and interconnected', and even appears in official account retweets or co-branded posters, their dissemination can easily be misinterpreted as the project's official stance by outsiders. Once the content involves sensitive information like future plans, token structures, or ecological incentives, students may be recognized as 'de facto promoters'.
Diversion paths are implicit but results are clear
In articles or event promotions published by students, there may be embedded tasks such as registration paths, joining communities, filling in wallet addresses, binding email addresses, etc. Although no earnings are promised, these tasks are often linked to airdrop points, testing qualifications, or future governance rights. This 'non-transactional diversion' still constitutes potential financial activity risks in China.
Difficulties in Accountability of Incentive Mechanisms
Ambassador programs are often structured as 'content rankings', 'project points', 'DAO reputation systems', etc. Initially, since project parties do not directly distribute tokens or monetary incentives, it makes it difficult for students to recognize the importance and legal responsibilities of their roles. Yet, once the platform is investigated for violations later, student content may become part of the evidence chain.
2. Brand Cooperation/Joint Events
In addition to individual college student participation, another common cooperation model for Web3 project parties on campus is to jointly hold activities or co-build brands with student organizations (especially chain associations). For instance, conducting online and offline joint activities under the guise of 'technical lectures', 'DAO public classes', 'developer hackathons', 'Web3 trend discussions', etc., or embedding brand exposure in event materials, speaker arrangements, and promotional channels through sponsorship.
Such collaborations often do not involve explicit monetary transactions; project parties participate as 'content supporters' or 'co-organizers', with the chain association responsible for execution and connecting with on-campus resources. Since there is no flow of funds, student organizations often view it as purely technical exchanges or industry learning projects, lacking basic recognition of compliance issues.
However, in reality, if any content display related to virtual assets, user guidance paths, or collaborations occur without school approval and record, student organizations may be substantially involved in the legal risks of 'aiding illegal financial activities'. For example:
Activity forms are neutral, but content substantially diverts
Some events, though labeled as 'technical themed', actually contain segments like project mechanism introductions, economic model breakdowns, and airdrop qualification previews, or include QR codes for scanning, joining project groups, filling out testing forms, etc., during PPTs/lectures. If such diversion behaviors are not disclosed and restricted, even if student organizations do not directly profit, they may be regarded as promotional assistants.
Project identity is unclear, cooperation boundaries are vague
If some project parties are foreign DAOs, unregistered entities, or 'proposed token issuance platforms', their legal qualifications are unclear. If student organizations assist them in on-campus dissemination or organizing activities, it may be viewed as providing convenience for foreign unregistered VASPs, touching upon policy red lines.
Unauthorized on-campus brand exposure
Some student organizations may directly use project logos, official website links during events, or even co-sign 'hosts/co-organizers' on promotional posters. If they have not applied for on-campus promotion or brand cooperation permission from the school, it may lead to the organization being in a legally or school rule unprotected state. Once a complaint or dispute arises, the student organization may become the accountable party.
Mankun Lawyer's Recommendation
In the rapidly developing Web3 industry, college students, as the most active technology adopters and community builders, indeed have a natural enthusiasm for participation and construction value. Therefore, Mankun Lawyer strongly supports college students participating in technological innovation and ecological co-construction, and encourages university chain associations to become important nodes in promoting industry awareness.
However, 'participation' does not equal 'allowance'. Therefore, we recommend starting from the following three directions, setting operational frameworks based on the principles of 'what can be done, how to do it more safely':
Clearly define participation roles, do not act as 'endorsers'
If you are a project ambassador, content creator, or community contributor, it is recommended to clearly state in your personal profile and posts that 'these are personal views and do not represent the official position of the project' to avoid misleading others or taking on de facto endorsement responsibilities.
At the same time, it is not recommended to participate in writing content involving project token mechanisms, governance structures, etc., related to future earnings or distribution rights, especially when disseminating on domestic platforms, terms like 'expected earnings', 'airdrop timing', 'price outlook', etc., should be avoided.
Retain risk records when participating in on-chain activities
If you plan to participate in project internal testing, on-chain interactions, wallet binding, etc., it is recommended to keep screenshots of the original project rules to confirm they do not involve contract trading, leverage guidance, or asset solicitation. If you need to invite others to participate, actively remind them that 'this project is not registered or filed within China, and related rights may have uncertainties' to avoid misleading or liability sharing due to the invitation.
Student organization cooperation must follow the 'on-campus compliance path'
Before conducting joint activities with any Web3 project, the chain association/student organization should complete three actions:
Clearly identify the project party's identity and legal registration location;
Submit cooperative content for school approval (if it involves external brands, online activities, funding, etc.);
Create risk warning pages or compliance disclaimers to mitigate the legal responsibilities of the organizing parties regarding the event content.
Compliance does not mean rejecting exploration, but rather making exploration a worthwhile long-term investment.
We welcome students to join Web3 construction and also welcome project parties to establish co-creation mechanisms with campuses, but please clarify legal boundaries in advance under cooperation premises to ensure every attempt is 'traceable, retrievable, and exempt from liability'.
If you or your organization plan to conduct joint activities with Web3 projects, apply for support, or participate in technical co-construction, please contact Mankun Lawyer for specialized compliance advice.