In the field of cryptocurrency investment, crypto investment sharing communities have become one of the important channels for investors to obtain information. They often follow group leaders (such as KOLs) through social media and join the Web3 investment groups they create to get the latest updates and investment analyses in the crypto space in a timely manner. However, many of these communities charge a significant entry fee. As a result, a new model of information sharing in the crypto space, the "paid information transfer group," has emerged - users can join the group for a very low entry fee to access high-quality crypto investment information curated by the group leader.

At first glance, the operation of transferring information seems unproblematic. However, in reality, group leaders need to pay attention to numerous legal compliance issues.

What is a Paid Transfer Group?

The group leaders/operators of paid information transfer groups in the crypto space (hereinafter referred to as "crypto transfer groups") typically claim to have subscribed to multiple high-value paid communities in the crypto space and can use the "keyword capture" function of bots to transfer internal information from other paid communities in real-time. "One entry fee, multiple group insights" indeed attracts many people to pay.

The operational model of these crypto transfer groups usually includes the following characteristics:

• Multi-source integration, with information in the group potentially coming from multiple paid communities, covering various fields such as Web3 market news and player investment analyses.

• Automated transfer, as many group leaders use bots to set keywords for automatic capture and forwarding of information from target communities.

• Real-time updates, as these groups are often considered capable of timely transferring crypto news due to the use of bots for automatic capture and forwarding.

• Low-price strategy, where group leaders often emphasize that membership fees are far lower than those of the source communities, for example, "Spend a few hundred U to experience strategies worth over 20,000 U from paid groups."

• Value-added services, in addition to forwarding information, some group leaders also provide simple interpretations or suggestions, attempting to create additional value for users.

Taking a currently promoted transfer group as an example, the platform claims to have paid to join over 30 top-quality paid communities and provides group members with multidimensional information including but not limited to contract trading, spot market trends, and short selling strategies through real-time updates via bots.

What Crypto Transfer Group Leaders Need to Know

The characteristics of paid information transfer groups in the crypto space can usually attract a large number of Web3 investment users to pay for membership, achieving a win-win situation for users and group leaders. However, lawyer Mankun believes that during this process, crypto transfer group leaders must pay attention to some legal compliance issues. For instance, a previous article published by Mankun Law Firm titled “Operating a TG Telegram Group Resulted in Imprisonment! How Should Web3 Communities Operate Compliantly?” has already analyzed the compliance issues related to charging cryptocurrency membership fees and providing investment advice. Meanwhile, as a crypto transfer group leader, attention should also be paid to the following aspects:

(1) Information Transfer Infringement Issues

In the model of paid information transfer groups, an unavoidable issue is the infringement of other KOLs' intellectual property rights.

KOLs typically enjoy copyright protection for their original content published in paid communities, such as in-depth market analyses and exclusive project evaluations. Moreover, based on the community rules and daily statements of KOLs, most paid communities explicitly prohibit members from disseminating information outside the group, which can also be seen as KOLs taking further protection of their copyrights.

In this case, if a group leader copies and disseminates unauthorized original information for profit, it not only violates the service contract with the original community KOL but may also constitute an infringement of intellectual property rights, leading to accountability from the respective KOL.

Furthermore, operating one's community by transferring paid content from other communities may also be viewed as an act of unfair competition through the means of infringing on trade secrets, violating laws and business ethics, and harming the legitimate rights and interests of the original creators.

(2) Information Review Deficiency Issues

Group leaders of transfer groups must also consider the authenticity and accuracy of group messages.

The paid model of transfer groups determines that group leaders and members are not merely "netizens" but have established a service relationship: members pay an entry fee, and the group leader regularly publishes crypto investment news. Therefore, group leaders should ensure service quality and avoid disseminating false or erroneous information that could mislead group members.

However, most transfer groups use automated tools to capture information, making it difficult to review each piece of information individually. This leads to potential legal compliance issues for group leaders if members invest based on unverified information and incur losses:

• Breach of contract issues: If members suffer investment losses due to reliance on false or erroneous information, the group leader may be deemed in breach of contract and face the risk of civil liability.

• Fraud issues: If the group leader continues to disseminate information despite knowing it may be problematic, it could even be viewed as constituting fraudulent behavior.

• Regulatory penalties: In certain cases, if the disseminated false information has severe negative impacts, it may attract the attention and penalties from regulatory authorities.

(3) Project Promotion Issues

Additionally, many transfer groups may accept promotional invitations from Web3 project parties to advertise specific projects within the group.

According to Article 148 of the Civil Code, if the group leader's false statements lead investors to have a misunderstanding and purchase tokens or participate in projects, resulting in financial losses, their actions will constitute civil fraud, and investors have the right to seek compensation.

More seriously, if the group leader has the intent to illegally possess investors' assets and uses deceptive means to obtain funds from investors for the project party, ultimately causing financial losses to investors, their actions are likely to violate Article 266 of the Criminal Law regarding fraud and bear criminal responsibility.

Mankun Lawyer's Summary

As an emerging information dissemination model, paid information transfer groups in the crypto space have become an important avenue for community leaders to develop memberships, but they also bring significant legal compliance issues that cannot be ignored. Therefore, crypto transfer group leaders should recognize the legal boundaries of their actions. Mankun Lawyer suggests the following measures to regulate management:

• Obtain authorization: Establish formal cooperative relationships with KOLs or community leaders of original content to obtain clear authorization for content reproduction.

• Clearly indicate sources: For reproduced or quoted content, it is essential to clearly indicate the original author and source, respecting the intellectual property rights of the original creators.

• Enhance information review: Conduct manual reviews of information captured by bots to ensure its authenticity and reliability.

• Clarify disclaimers: Clearly state disclaimers in group rules, reminding group members to independently assess the authenticity of information.

• Compliant promotion: When promoting projects, conduct compliance investigations and avoid exaggerated claims or promises of returns, ensuring the objectivity of promotional content.

The emergence of paid information transfer groups reflects the market's demand for high-quality, low-cost information. However, while enjoying the convenience, both community leaders and group members should be aware of potential legal compliance points and work together to maintain a healthy and compliant information exchange environment. If issues arise in creating or operating a crypto paid transfer group, please contact a lawyer for compliance consultation in a timely manner.

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