Author: Iris, Lawyer Liu Honglin

In Web3, "holding events" has almost become a standard action for every project team. Do you want exposure? Do you want collaboration? Organizing and participating in events is definitely one of the best ways to address these two questions.

I wonder if anyone attended the recent Web3 Festival held in Hong Kong. In addition to the large main summit, the surrounding events were diverse, ranging from cocktail parties, after-parties, technical salons, to meetups, closed-door meetings, hackathons, and forums. It can be said that the entire month of April in Hong Kong was saturated with Web3 activities.

However, many organizers may think: organizing an event is just about planning a process, inviting guests, finding a venue or platform, and doing some promotion—it's very simple!

But in reality, organizing an event involves many compliance issues, especially since Web3 is an industry that has financial attributes, technical characteristics, and cross-border features. The compliance risks of offline events are far higher than those in ordinary industries, and ignoring these compliance issues is often a big taboo.

Therefore, in this article, Lawyer Mankun will systematically outline common legal issues in Web3 events and practical response strategies from the perspective of event organizers, combining real hosting logic and operational key points, to help project teams and operational teams truly achieve "legal and compliant event organization."

Three Steps of Compliance Logic for Organizing Events

The sensitivity of Web3 events is not just because they have the shadow of "tokens," but because they involve too many gray areas across industries, regions, and identities.

Thus, the real question that event organizers should consider is: In the three stages of event planning, execution, and follow-up, have I fulfilled my "due diligence" and anticipated and controlled all potential risks?

Step 1: Event Planning Stage

What kind of event do you want to hold? This is the first step in all compliance judgments.

Many Web3 organizers often only focus on superficial labels like "technical sharing" or "community gathering" when planning events. However, from a regulatory perspective, what truly matters is the substantive content and purpose of your event—

Are you promoting a token? Are you organizing fundraising? Are you facilitating the operations of an overseas platform within the country?

These factors determine the compliance risk level of your event, rather than the name you use to package it.

Here, based on personal experience and judgment, Lawyer Mankun categorizes Web3 offline events into three risk levels based on substantive content:

Low-Risk Activities

For example, purely technical-oriented hackathons (like ETHGlobal), R&D workshops, and closed-door developer exchanges. These activities focus on code and products, do not involve fundraising or token promotion, and have relatively low overall risk. However, care should be taken to avoid using tokens for prizes or connecting results to token projects to prevent doubts about "using technology to package token issuance."

Medium-Risk Activities

Typically, activities such as industry summits, press conferences, project meetups, and cocktail parties that have a "promotion" or "market warming" nature. They may seem like light social events, but if guest speeches involve project tokens, media follow-ups are too enthusiastic, or participants have complex identities, they can easily be questioned as "disguised marketing." Therefore, organizers need to carefully select attendees, especially speakers; it is also best not to arrange for crypto KOLs to host, to avoid forming a "token association chain."

High-Risk Activities

These are generally related to investment or tokens, such as closed-door financing meetings, private investor meetups, and token roadshows. Once these scenarios target investors from mainland China, they can easily cross the red lines of illegal securities issuance or illegal fundraising. To reduce such risks, entry barriers can be set in advance (e.g., limiting to licensed foreign institutions/not involving tokens), materials can be directed only to overseas audiences, and the entire process should avoid discussing "price expectations" or "investment returns," while keeping compliance backup records.

Many organizers might think: "My event is in Hong Kong, how could there be a problem?" But please note: if your content or dissemination reaches users in mainland China, even if the venue is overseas, it may still be regarded by regulators as "providing services to domestic residents."

Therefore, the risk of an event does not only depend on where it is held or what it is called, but rather on what is said, who is listening, and whether there is any flow of funds.

Additionally, when involving foreign personnel, minors, or specific professional identities (such as financial practitioners), some regional laws and regulations may require event registration or specific permits. Ignoring these requirements, even if the event itself is not illegal, may lead to inquiries or actions due to inadequate identity verification.

Thus, when planning an event, Lawyer Mankun suggests that three things must be done:

1) Substantively classify the type of event based on actual content and goals;

2) Confirm the boundaries of the event, especially whether it involves users from mainland China, sensitive countries or regions, or cross-border promotion;

3) Set a "content compliance line" in advance, specifying what should not be said, what materials should not be distributed, and who should not be invited.

Remember: you are not planning an event process; you are crafting a narrative of compliance behavior. Misclassifying can lead to mistakes later, no matter how careful you are.

Step 2: Event Execution Stage

Once the process is set, it’s time to move into the actual "on-the-ground execution" phase. However, it is precisely at this stage that compliance issues are most easily triggered due to overlooked details.

Anyone who has organized an event knows that planning is one thing, and execution is another. In reality, many issues arise not from intentional planning but from "accidentally crossing the red line" during execution.

Lawyer Mankun summarizes the key issues in the event execution phase into three aspects:

(1) Is the promotional content crossing the line?

Many organizers, when designing event materials, creating PPTs, or publishing promotional articles, can easily mislead due to inappropriate wording, especially the following high-frequency "risk phrases" should be particularly noted:

• "Coming soon / token issuance / listing"

• "Airdrop," "early subscription," "X times potential token"

• "XX investment institution leading the investment," "well-known VC endorsing"

• Price predictions, return expectations, investment return descriptions

Once these expressions appear, they may be deemed by regulators as having tendencies towards "token sales promotion" or "public fundraising," which are illegal financial activities.

Therefore, it is recommended to establish a unified compliance review mechanism for promotional materials. It is best to have legal counsel or a lawyer assist in reviewing and pre-evaluating all external posters, tweets, event manuals, guest PPTs, etc., to clarify which information is "only to be discussed privately, not to be publicly stated."

(2) Are there risks in on-site speeches?

In forum or meetup-type events, the content of guest speeches is often uncontrollable. However, please note that as long as the event is organized by the host, the content responsibility may "revert back to you."

In practice, regulatory agencies often do not only look at whether the organizer "personally promotes." As long as you are the event organizer or hosting platform, whether a guest "leaks" information on-site, a PPT shows a token roadmap, or an interview hints at token trading opportunities, regulators may determine that you have not fulfilled your content review obligations, thus bearing joint risks.

Another typical "compliance hidden danger" is indirect support for foreign platforms or services. For example, if a project arranges a platform representative to speak, provides QR codes for registration, or embeds technical product demonstrations during the event. Although the organizer does not directly involve tokens or provide trading access, due to "facilitating the operations of foreign platforms within the country," it may ultimately be classified as assisting illegal financial activities.

Therefore, event organizers must review guest speech content in advance and remind speakers on-site, especially regarding shares involving tokens, platforms, or projects, to avoid guiding investments, displaying trading logic, or hinting at price trends. At the same time, during the speech, efforts should be made to control the venue as much as possible.

(3) Are there loopholes in funding and venue aspects?

Do not underestimate the compliance sensitivity behind "charging admission" or "accepting sponsorship." Collecting admission fees in crypto assets or accepting token sponsorships has significant compliance differences in different regions. For example, in strictly regulated areas like mainland China, regulatory agencies have repeatedly emphasized that virtual currencies cannot be used as payment tools. If an event charges fees through tokens like USDT, it may be seen as providing virtual currency payment services, thus being classified as "illegal financial activities."

Even in relatively open regions like Hong Kong and Dubai, if the sponsor is an unlicensed foreign trading platform or sensitive entities like crypto investment institutions, the event organizer may also be considered to be "assisting unlicensed virtual asset service providers," especially when the event content includes project promotion or brand exposure, the risk is even higher.

At the same time, the choice of event venue also has compliance standards, such as whether the venue is legal, whether it is open to the public, whether temporary registration is required, whether it exceeds the maximum number of attendees, and whether there are foreign attendees or representatives from sensitive countries. Many organizers do not consider these issues clearly in the initial planning, but in some jurisdictions, such as mainland China, crossing the line may directly be classified as "illegal assembly" or "foreign operations." In places like Hong Kong, attention should also be paid to using commercial venues and clearly communicating the event content to the owner or management agency to avoid venue disputes arising from "crypto" attributes.

In addition to the three aspects mentioned above, the use of data and images is becoming a new high-risk compliance area. Common practices during events, such as full audio and video recording, collecting attendee information, and live streaming on social media, if not authorized or if the purpose is not disclosed, may infringe on attendees' portrait rights and privacy rights, and even trigger compliance red lines in cross-border data flow scenarios.

Step 3: Event Review Stage

Once the event is over, is everything "all good"? Lawyer Mankun believes: not necessarily.

In actual law enforcement, many projects are not held accountable because of issues at the event site, but rather due to the "traces" left after the event. Especially in the areas of social media records, data archiving, and the flow of sponsorship funds, if not handled properly, they can easily become a breakthrough point for subsequent investigations.

Therefore, Lawyer Mankun reminds: a truly complete compliance loop must include post-event review management.

(1) Are there "compliance records"?

After the event, project teams must organize and retain the following key materials to respond to potential investigations or inquiries:

• Guest speeches, PPTs, or versions of speech summaries;

• On-site video/audio materials (if recorded);

• Final versions of promotional materials and lists of distribution channels;

• Basic registration of attendees' information (if there is a registration process);

• Venue rental, sponsorship agreements, and other contractual documents;

• Detailed income and expenditure records of the event, especially explanations regarding tokens.

These materials are not for "proactive registration," but can help the project demonstrate the compliance intent of the event and that the organizer has fulfilled reasonable review obligations in the future if faced with compliance inquiries.

(2) Is there a "speech traceability" mechanism?

If token-related content appears during the event, the organizer needs to establish a speech traceability mechanism, clarifying who provided which content and whether the statements were reviewed.

Especially for guest spontaneous speeches, it is recommended to clarify the legal responsibility for their statements by signing a responsibility statement or risk reminder letter before the event, to avoid situations where "guests overstep and the organizer takes the blame."

Additionally, whether the recorded content will be made public should also be planned in advance: which content can be disseminated in the public domain, and which is for internal archiving only. If the content involves token information, its potential legal impact on specific groups (such as mainland users) should be assessed.

(3) Is there a "post-event public opinion handling plan"?

Web3 events often come with high exposure and community fermentation. An event intended for "internal communication" may suddenly trend on social media due to a comment from a KOL.

In such scenarios, organizers should have basic response plans:

• Are you monitoring the dissemination of content related to the event in a timely manner?

• If misleading statements or risky comments appear, can you quickly clarify or take them down?

• Can you unify your voice in the community to explain the compliance boundaries of the event?

If you allow the dissemination to ferment and distorted descriptions such as "the organizer publicly promotes the project" or "domestic promotion of tokens" arise, then even if the event itself is designed to be compliant, it may still cross the line in "secondary dissemination."

Therefore, from a compliance perspective, the "wrap-up" of the event review stage also determines whether the risk loop of this event is truly completed.

Summary by Lawyer Mankun

Holding a Web3 event is never just about process arrangements and guest invitations.

A truly safe offline event relies not on "not having issues," but on incorporating legal compliance into every aspect from the very beginning. The earlier compliance is involved, the more control you have, and the more at ease you can be in "going out."

In the increasingly tightening global regulatory context, every offline event in Web3 is essentially a signal released by the project to the outside world, and the organizer and the event itself naturally become windows for bearing risks. You may think it's just a cocktail party or a meetup, but in the eyes of regulators, it could be marketing, fundraising, or business operations.

Therefore, for organizers, the optimal path has always been to "control the maximum risk at the minimum cost."

It is foreseeable that Web3 events will become increasingly diverse, and the institutional construction behind these events has already begun.

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