Mankiw Research | Are Web3 project campus ambassadors reliable?

In the past few days, the Web3 Chinese social media discourse regarding "certain CEX offering contract experience funds to college students" has been continuously fermenting. The incident originated from a post on the X platform that involved sensitive keywords such as "CEX", "college students", and "gamblers", triggering a lot of attention and discussion.

Lawyer Mankun reviewed the comments under the post and found that the mainstream opinion generally opposed this promotional approach, 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 titled "Please Immediately Stop the Practice of Promoting Contract Experience Funds to College Students," directly pointing out that such behavior is essentially "gambling inducement disguised as financial enlightenment"; Yu Sen from Slow Fog Technology also retweeted in support, advocating for a comprehensive boycott. However, some voices expressed that they are "not surprised" by this. Some people mentioned that they had encountered similar promotions during their university years, while others believe that university students are adults with civil capacity, and that their willingness to gamble and accept the consequences is a personal choice. It is precisely this divergence of viewpoints that made Lawyer Mankun realize that campus promotions defined as education, enlightenment, and technology dissemination, similar to the "Campus Ambassador" program, have already been effectively implemented in many campuses, becoming a path for some Web3 project brands and even conventional customer acquisition. As a law firm focusing on serving the Web3.0 industry, Mr. Mankiw has also cooperated with the University Chain Association for many times to jointly hold compliance lectures and other activities. In these processes, we observe a common problem: both individual students and student organizations represented by the Chain Association generally lack the basic judgment ability of "whether the promotion behavior is compliant" when facing Web3 project cooperation. So, a key question arises: Can college students participate in the Web3 campus ambassador program? In collaboration with Web3 projects, which behaviors are safe? Which ones might cross the line? Is the campus ambassador program for virtual asset trading platforms reliable? The "contract experience gold" event that has sparked widespread discussion has almost no controversy regarding its compliance issues. According to our current regulatory system, whether it is domestic entities or foreign platforms, as long as they promote unregistered high-risk financial derivatives, such as contract trading and leveraged products, to domestic residents, they are suspected of illegal financial activities. Even if packaged as "experience funds," as long as the behavior essentially constitutes guiding transactions, it lacks legality. But compliance issues do not stop there. In recent years, many CEX ambassador programs launched on campuses are no longer limited to "trading incentives" alone, but have also introduced more seemingly harmless yet actually ambiguous promotional models, including but not limited to:

*Screenshot of campus promotion task for a certain platform

1. App promotion and registration guidance Some campus ambassador programs require participants to guide their peers in downloading and installing the exchange app, and completing registration, sometimes also in conjunction with reward mechanisms such as "invite to earn rewards" and "bind to receive gifts". Such behaviors are packaged in platform promotions as "new user education" or "usage guidance", but their essence is very close to unauthorized financial promotions. According to relevant Chinese laws, any behavior that promotes financial products to unspecified parties or guides them to open accounts and trade within the territory must have the corresponding financial business license. University students, although they have not signed formal agency agreements in such promotional activities, essentially act as de facto marketing representatives or traffic conduits. Once a trading dispute occurs or regulatory intervention is triggered, the responsibility is not ambiguous.
2. Brand Promotion and Content Output There is also a more subtle mechanism for ambassadors to assist in the branding of the exchange, such as sharing brand promotion articles on social media communities, participating in social media interactions, organizing seminars, etc. This kind of operation is often understood as "content internship" and "publicity volunteer", but its actual effect has already had an impact on the platform's image and trust building. In China, there are regulatory thresholds 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 commitments", they are highly likely to be deemed as unauthorized financial advertising. For organizers, it remains impossible to evade legal responsibilities.
3. Technical Lectures and Industry Popular Science Some platforms will collaborate with campus organizations to hold events through "Web3 Technology Open Classes," "Blockchain Introductory Lectures," and "Industry Development Sharing Sessions." On the surface, this type of content does not directly lead to registration or trading, and seems to carry lower risks. However, two points need to be noted: first, whether the organizer clearly indicates the platform identity; second, whether there are elements of platform traffic diversion or product exposure in the content. If it is initiated under the name of a certain CEX and introduces its product structure, trading advantages, and other related content during the seminar, even if the theme of the seminar is "The Current Situation of the Cryptocurrency Industry", it may still be regarded as a borderline financial promotion behavior. 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 set up by Web3 projects seem much milder. They often do not touch on trading products, do not promise returns, but instead guide students to participate in co-construction. But is this type of ambassador mechanism safe? Many people may tend to think: "This is just knowledge dissemination" "Not touching coins is not illegal." However, from the perspective of legal practice, whether something is "compliant" depends on the function and impact of the behavior, rather than 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:
4. Ambassador/Community Building Some Web3 project teams invite students to become "campus ambassadors," encouraging them to represent the project in promoting or speaking on social media and offline events. For example, a well-known public chain's Chinese community is recruiting campus ambassadors for 2024, requiring participating students to create high-quality content, manage the community, disseminate ecological information, and organize offline events on campus, among other things. Or become a campus community organizer/builder, guiding college students to help the project with user acquisition. For example, in 2023, a certain decentralized social platform publicly recruited campus ambassadors at universities worldwide to establish and expand the campus user community for the project. Such collaborations are often packaged as "content contribution", "community autonomy", and "decentralized culture", downplaying their commercial attributes and blurring the legal boundaries between participants and project parties. However, in practice, students have effectively taken on the dual roles of brand communicators and traffic participants through producing articles, publishing videos, and organizing activities. Potential compliance risks of such behavior include: Actual endorsement but ambiguous identity Although the project party may not have explicitly authorized it, when the content of student ambassadors is "structured, regular, and interactive", and even appears in official account retweets and co-branded posters, their dissemination behavior can easily be misinterpreted by the outside world as the official stance of the project. Once the content involves sensitive information such as future plans, token structures, and ecological incentives, students may be regarded as "de facto promoters". The diversion path is implicit but the result is clear. In articles or event promotions published by students, there may be embedded task entries such as registration paths, joining communities, filling in wallet addresses, and binding email addresses. Although there is no promised profit, they are often linked to airdrop points, testing qualifications, or future governance rights. This "non-transaction path diversion" still poses potential financial activity reach risks in China. The incentive mechanism makes it difficult to assign responsibility. The ambassador program often includes structures such as "content ranking", "project points", and "DAO internal reputation system". In the early stages, because project parties do not directly issue tokens or monetary incentives, students find it difficult to realize the importance of their roles and legal responsibilities. However, once the platform is investigated for violations later on, the students' content may become part of the evidence chain.
5. Brand Cooperation/Co-hosted Events Apart from individual university students participating, another common collaboration model for Web3 projects on campus is to co-host events or brand co-building with student organizations (especially blockchain associations). For example, conducting online and offline joint activities under the names of "technical lectures", "DAO open classes", "developer hackathons", "Web3 trend seminars", etc., or embedding brand exposure in event materials, speaker arrangements, and promotional channels through sponsorship. Such collaborations often do not involve explicit monetary transactions, with project parties participating as "content supporters" or "joint organizers," while the blockchain association is responsible for implementation and connecting campus resources. Since no funds are transferred, student organizations often regard it as purely a technical exchange or industry learning project, lacking a basic recognition of compliance issues. However, in reality, once there is a display of content related to virtual assets during the activity, a user guidance path, or cooperation that has not been approved and filed by the school, student organizations may be substantially involved in the legal risks of "assisting illegal financial activities." For example: The activity format is neutral, and the content essentially drives traffic. Some activities, although labeled under the banner of "technology themes", actually include project mechanism introductions, economic model breakdowns, and announcements of airdrop qualifications, or involve pathways for participation such as scanning QR codes, joining project groups, and filling out test forms in PPTs/speeches. If such traffic diversion behavior is not disclosed and restricted, even if student organizations do not directly profit, they may still be regarded as promotional assistants. The project's identity is unclear, and the boundaries of cooperation are not defined. If some project parties are overseas DAOs, unregistered entities, or "proposed token issuance platforms," their legal qualifications are unclear. If student organizations assist them in spreading information and organizing activities on campus, it may be seen as providing convenience for overseas unregistered VASPs, which touches upon policy red lines. Unapproved on-campus brand exposure Some student organizations may directly use the project's logo, official website link, and even co-branding "Organizer/Partner" alongside the project party in promotional posters during events. If they do not apply to the school for permission for on-campus promotion or brand collaboration, it may result in the organization being in an unprotected state both legally and according to school regulations. Once a complaint or dispute arises regarding the event, the student organization may become the accountable party. Mankun's lawyer suggests 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, Attorney Mankun strongly supports college students in participating in technological innovation and ecological co-construction, and encourages university blockchain associations to become important nodes for promoting industry awareness. However, "participation" does not equal "tolerance"; therefore, we suggest starting from the following three directions, setting an operational framework based on the principle of "what can be done and how to do it more safely": Clarify participation positioning, do not act as a "spokesperson". If you are a project ambassador, content creator, or community contributor, it is recommended to clearly state "personal opinion, not representing the project's official stance" in your personal profile and posts to avoid misleading others or bearing the responsibility of factual representation. At the same time, it is not recommended to participate in drafting content related to project token mechanisms, governance structures, and other aspects involving future income or distribution rights. Especially when disseminating on domestic platforms, terms such as "expected returns," "airdrop timing," and "price outlook" should be avoided. Keep risk records when participating in on-chain activities. If you are ready to participate in project beta testing, on-chain interactions, wallet binding, and other activities, it is recommended to keep screenshots of the original project rules and instructions, confirming that they do not involve contract trading, leveraged guidance, or asset fundraising; if you need to invite others to participate, you should proactively remind them that "the project is not registered or filed within China, and related rights and interests are uncertain," to avoid misleading or joint liability resulting from the invitation. Student organization cooperation needs to follow the "on-campus compliance path". Before conducting joint activities with any Web3 project, the blockchain association/student organization should complete three actions: Clarify the identity of the project party and its legal registration location; Submit the cooperation content to the school for approval (if it includes external brands, online activities, funding, etc.); Create a risk warning page or compliance disclaimer to mitigate the legal liability of the organizer for the content of the event. Compliance is not about rejecting exploration, but rather about making exploration a worthwhile long-term endeavor. We welcome students to join the construction of Web3 and also encourage project parties to establish co-creation mechanisms with campuses. However, please clarify legal boundaries in advance under the premise of cooperation to ensure that each attempt is "traceable, retraceable, and exempt from liability." If you or your organization plan to carry out joint activities with Web3 projects, apply for support, or participate in technical co-construction, please feel free to contact attorney Mankun for specialized compliance advice.

/ END. Author of this article: Iris, Lu Wenlong