Why operations, BD and community staff in Web3 cases may also face scrutiny in illegal business probes
A commentary published by MarsBit and written by lawyer Gao Mengyang argues that in criminal cases involving Web3 projects, investigators do not stop at job titles. The key question is often where an employee directed users and what role that person played in bringing users into the project’s business flow. According to the article, operations staff, business development personnel and community managers do not automatically bear criminal liability just because a project is later investigated for suspected illegal business activity, nor are they automatically safe simply because they never handled company funds. The piece says liability turns on several factors: whether the employee recognized the project’s illegal risk, whether the employee’s work advanced the project’s core business, and what part that person played in user acquisition, transaction conversion and fund payments. It cites a February 2026 notice from eight Chinese authorities led by the People’s Bank of China, as well as a July 23, 2026 notice by the Shenzhen Cyberspace Administration involving crypto-related promotional accounts. The article also lays out four lines of review — content, customer acquisition, trading and funds — and urges employees under scrutiny to preserve contracts, payroll records, work instructions and communication logs rather than delete chats or coordinate statements with colleagues.








