Background
Chiliz Chain is an ecosystem, based on CHZ and fan-token infrastructure. Chiliz planned to expand its operations and token-related products into new markets where crypto-asset regulation, consumer protection rules, and AML/sanctions requirements vary significantly. The key task was to build a defensible legal framework for distributing tokens and operating a consumer-facing platform while mitigating enforcement, licensing, and reputational risks.
Legal issues
Multi-jurisdiction market entry support, including a comprehensive risk model, regulatory positioning for token distribution, and a full set of legally binding documents.
Our role
We delivered an end-to-end legal program focused on three pillars: risk modelling, documentation, and regulatory justification for distribution.
We designed a product-by-product risk model covering:
- token classification risks (utility vs. security/financial instrument/e-money scenarios depending on rights, marketing, and structure);
- licensing/perimeter analysis (roles and regulated activities across target jurisdictions);
- AML/CFT and sanctions exposure (KYC/KYB segmentation, screening, transaction monitoring, escalation and record-keeping);
- consumer protection and marketing compliance (disclosures, fair marketing, complaints handling);
- data protection and cybersecurity (GDPR roles, DPIA triggers, security-by-design);
- IP and commercial risks related to sports brands and partnerships.
Key challenges
- Structuring token distribution and marketing in a way that avoids triggering securities/e-money characterisation and related licensing requirements across multiple jurisdictions
- Aligning product design and user flows with evolving crypto-asset rules while maintaining a consistent user experience, and
- Building AML/sanctions and consumer-protection controls that are strong enough for regulators and partners, yet practical to operate at scale (including geo-fencing, eligibility checks, disclosures, and complaints handling).
Outcome
We drafted and adapted a complete set of legal documents for both token distribution and platform operations, including:
- token terms, risk disclosures and distribution rules (including territorial/eligibility restrictions);
- platform Terms of Use / Terms of Sale, complaints and refunds framework;
- privacy and cookie documentation, data processing clauses and vendor templates;
- AML/CFT policies (KYC/KYB, sanctions, monitoring, escalation, record retention);
- commercial agreements with partners, including IP licensing provisions, compliance allocation, and distribution mechanics.
The client received:
- A structured risk model enabling ongoing compliance management and executive decision-making.
- A launch-ready documentation package supporting token distribution and platform operations.
- A clear regulatory positioning for tokens and product flows, with practical controls (eligibility, geo-fencing, disclosures, AML/sanctions) designed to reduce enforcement and partner-risk exposure.
- A scalable governance framework that can be replicated as the product expands into additional jurisdictions.
Why this case matters
It remains a significant example of how structured legal defence can prevent disproportionate restrictions on access to global digital resources. This matter illustrates the importance of:
- evidentiary standards in copyright enforcement;
- limits of intermediary liability;
- proportionality in website blocking measures;
- cross-border consistency in digital regulation.
