LANA is exchange, not refund
Rules for partners who accept LANA directly. Closed-loop only. No fiat refund schemes. No exceptions.
Why this page exists
Gašper and I designed LANA Coin as a closed-loop community token. A LANA Friendly Partner accepts LANA directly into their own wallet and delivers goods or services in return. Simple, legal, transparent.
But we have seen a dangerous pattern in crypto: projects allow users to 'pay' in tokens, then quietly refund the fiat equivalent. That is not payment — it is an unlicensed off-ramp disguised as commerce. It triggers money-transmitter regulation, MiCA CASP rules, and puts both the partner and the user at legal risk.
This page draws a bright line: what is allowed, what is forbidden, and why. If a partner crosses it, they are no longer a LANA Friendly Partner.
Allowed — closed-loop LANA commerce
Direct LANA payment for goods/services
Partner displays a price in LANA (e.g. 'This massage costs 500 LANA'). Customer sends LANA to the partner's wallet. Partner delivers the service. No fiat step. No refund promise.
LANA voucher / promo pack discounts
A partner may sell pre-paid vouchers (e.g. 'Buy a 10-visit pass for 4,000 LANA, get 10% off'). The voucher is redeemed for services. No cash-back. No conversion to fiat.
LANA Ambassador referral commissions
A partner may reward ambassadors who bring new customers. Commission is paid in LANA from the partner's own balance or via the platform's internal ledger. It is a closed-loop reward, not a fiat payout.
Displaying LANA as a payment option
Partner may display 'We accept LANA' alongside EUR, cards, or other methods. They may explain how to acquire LANA (e.g. via LOVE Exchange). They may NOT guarantee any fiat value or buy-back.
Loyalty points / cashback in LANA
A partner may give loyalty rewards denominated in LANA (e.g. 'Earn 5% back in LANA on every visit'). The reward stays in the ecosystem. It is not convertible to fiat by the partner.
Forbidden — refund & conversion schemes
'Refund' model: pay LANA, get fiat back
Any arrangement where the customer pays in LANA and later receives EUR/USD (or any fiat) back — whether as 'refund', 'reimbursement', 'cashback', or 'withdrawal'. This is an unlicensed fiat off-ramp and may breach MiCA CASP / money-transmitter law.
Guaranteed fiat conversion / buy-back promise
A partner may NOT promise 'We will always buy your LANA back at €0.01' or 'Your LANA is worth €5'. LANA has no guaranteed fiat value. Its market price floats on Stellar DEX. Any fixed-price promise is misleading and potentially fraudulent.
Centralized custody of customer LANA
A partner may NOT hold customer LANA in a pooled wallet and promise to 'manage' it. Users must maintain self-custody. The partner only receives LANA at the moment of payment, like receiving cash at a till.
Fiat cashback on LANA purchases
Giving EUR/USD cashback ('Spend 1,000 LANA, get €10 back') is a disguised fiat off-ramp. It treats LANA as a voucher redeemable for cash, which triggers e-money and payment-services regulation. Not allowed.
Presenting LANA as an 'investment' to customers
Partners must not tell customers 'Buy LANA, it will go up' or 'LANA is a great investment'. LANA is a utility token for community payments, not a security or investment product. See our /our-stance-on-investing page.
Examples — allowed vs forbidden language
| Scenario | Allowed | Forbidden |
|---|---|---|
| Price display | 'This product costs 2,000 LANA' | 'This product costs €20 (payable in LANA)' with guaranteed EUR value |
| Voucher sale | 'Buy 5 massage vouchers for 8,000 LANA — redeem at our studio' | 'Buy 5 vouchers for €80 worth of LANA — we refund unused balance in EUR' |
| Ambassador pitch | 'Refer friends and earn 5% of their LANA spend as a reward' | 'Refer friends and earn €50 cash for every signup' |
| Wallet instructions | 'Send LANA to our LOVE SAFE address: G...' | 'Deposit LANA with us and we guarantee €0.01 buy-back' |
Legal risk — why refunds are dangerous
Under EU MiCA (Markets in Crypto-Assets Regulation), a 'refund' model where crypto is accepted and fiat is returned constitutes a crypto-to-fiat exchange service. This requires a CASP (Crypto-Asset Service Provider) licence. Most small businesses do not have this.
Under Slovenian ZPSI-2 (Zakon o preprečevanju pranja denarja), unlicensed exchange of virtual currency for fiat is a regulatory offence. Fines can reach €500,000 for legal persons.
Under US FinCEN guidance, any person accepting virtual currency and transmitting fiat is a money transmitter. This requires state-by-state licences and federal registration. A small coffee shop cannot comply.
Dr. Miran Cerar would say: this is not in accordance with the law. We must do it differently.
What this means for partners
- You may accept LANA as a payment method for your own goods/services, exactly as you would accept cash.
- You may NOT act as an exchange, ATM, or fiat off-ramp for your customers. If they want fiat, they use a licensed exchange.
- You may offer discounts, vouchers, and loyalty rewards in LANA — as long as they stay in the LANA/LOVE ecosystem.
- You must keep your own LANA wallet (LOVE SAFE or Stellar-compatible). The platform does not hold funds on your behalf.
- You must not give investment or financial advice about LANA. Its price moves. You are a merchant, not a broker.
Published as a public, permanent commitment by the LOVE Coin legal team.
LANA Friendly Partners directory · Our stance on investing · Regulatory posture
