On December 25, 2025, Chinese travel giant Trip.com, the overseas platform of Ctrip Group, reportedly enabled global users to pay for hotel and flight bookings using the stablecoins USDT and USDC. This move positions the company ahead of other major Chinese internet firms in digital payment innovation, following reports that Ant Group and JD.com had “paused” their stablecoin initiatives in Hong Kong. This trial represents more than a simple payment upgrade. It is a strategic maneuver in the context of ambiguous global digital asset regulation, serving as a significant case study for the industry. This analysis, building on a previous discussion of fundamental criminal risk prevention for Chinese companies expanding abroad, examines the core components of building a substantive compliance framework, with a focus on capital management. **Capital Repatriation as a Key Risk Indicator** A critical aspect of risk isolation is whether and how profits from overseas operations are repatriated to China. The risk profile varies significantly. Keeping profits within the overseas entity for local reinvestment or distribution to foreign shareholders presents a relatively controlled risk. This approach severs the financial link between sensitive overseas operations and the domestic parent, signaling to regulators that the overseas subsidiary is an independent profit center. Consequently, the rationale for jurisdiction-based prosecution is substantially reduced. Conversely, repatriating profits through channels like virtual currency conversion or underground banks alters the situation entirely. It provides clear evidence for investigations and establishes a direct financial benefit for domestic entities from potentially “grey” overseas operations, offering grounds for regulatory intervention. **Leveraging Partnerships for Local Compliance** After establishing a foundational risk isolation framework, the next challenge is achieving local compliance. Trip.com adopted a “licensing partnership and scenario integration” strategy. It collaborates with licensed partners to handle complex financial compliance, while focusing on its core competency of travel services. Trip.com’s stablecoin payment feature is not processed directly by the company. The service is fully supported by its partner, Triple-A, a licensed crypto payments institution in Singapore. This partnership allows Trip.com to bypass the need to obtain complex cryptocurrency payment licenses in various jurisdictions, significantly lowering compliance barriers. A practical example is its implementation in Vietnam. The ability for users in Vietnam to pay with stablecoins likely leverages the country’s evolving regulatory pilot framework. In 2025, the Vietnamese government initiated a five-year pilot program for the crypto asset market, creating a controlled “regulatory sandbox.” It is plausible that Triple-A, using its Singapore license, accessed a local sandbox or specific exemption to legally offer its payment services in Vietnam’s tourism sector. This market choice aligns with Vietnam’s high crypto adoption rates and clear regulatory shift. **Framework for Sustainable Overseas Expansion** Trip.com’s trial represents a dynamic balance between innovation and compliance in an uncertain regulatory landscape. The following framework is suggested for firms considering similar paths: 1. **Structure and Risk Isolation:** Operate innovative businesses through completely independent overseas legal entities to create clear legal, financial, and operational firewalls from domestic parents. 2. **Prudent Compliance Strategy:** Prioritize partnerships with locally licensed institutions, positioning oneself as a “technology service provider” or “scenario facilitator” to leverage existing licenses for market entry. 3. **Differentiated KYC/AML Design:** Implement flexible, risk-based customer verification processes, balancing user experience with core compliance requirements for anti-money laundering. 4. **Strategic Market Selection:** Target “regulation-friendly” jurisdictions with genuine demand, such as regions with regulatory sandboxes or pilot programs, to reduce policy uncertainty. 5. **Deep Business Integration:** Ensure payment innovations are driven by and deeply embedded within existing business scenarios (e.g., travel booking) to solve user pain points, rather than being isolated financial tools. In conclusion, effective overseas compliance does not aim for absolute risk elimination. It involves systematically identifying, assessing, and managing risks through robust legal structures, reliable local partnerships, and continuous market monitoring. The goal is to control risks to a tolerable level, enabling businesses to seize opportunities for sustainable long-term growth.