Background
The client is a provider of GPU leasing and model-API resale to AI companies, procuring upstream GPUs and cloud on one side and reselling via Token metering on the other. The business involves cross-border compute scheduling, prepaid fund pools, and high-volume standardized online contracts; the supply-side compliance boundary had not been systematically reviewed.
Key Challenges
- Secondary clearing & licensing: Prepaid Token fund pools and collection/disbursement arrangements touched the “secondary clearing” (unlicensed settlement) boundary and value-added telecom licensing.
- Cross-border compute & data export: Scheduling offshore GPUs to process onshore user data may constitute data export, requiring path determination and filing.
- Resale liability allocation: Among underlying model provider, reseller, and customer, data responsibility and IP ownership were unclear.
- Missing contract standardization: High-volume online transactions lacked uniform, defensible service and data-processing agreements.
Geason’s Approach
- Licensing & fund boundary: Mapped prepaid and collection/disbursement structures, proposing secondary-clearing risk isolation and a value-added telecom licensing path.
- Cross-border export determination: Determined the data-export path for offshore-GPU-processing-onshore-data chains, clarifying the applicability of security assessment / standard contract / certification.
- Resale agreement system: Built API-resale service agreements, DPAs, and liability-allocation clauses clarifying the tripartite relationship.
- Standardized contracts: Delivered signable online service-agreement templates and SLAs with a uniform defensive basis.
The Non-Obvious Judgment
Supply-side compliance is often equated with “writing clear contracts.” Our view: compute/Token risk runs along two intersecting lines—first, prepaid fund pools may cross the “secondary clearing” red line, requiring fund isolation rather than mere contract wording; second, cheap offshore compute processing onshore user data is no longer a pure procurement issue but may trigger data-export obligations. The latter is the most overlooked supply-side intersection: the company thinks it bought “cheap compute,” while the regulator sees “data left the border.” Both lines must be addressed at business-design stage, not after disputes arise.
Key Outcomes
- Prepaid and collection/disbursement structures achieved secondary-clearing risk isolation, with a clarified value-added telecom licensing path.
- Offshore-compute-processing-onshore-data chains received data-export path determination and applicability conclusions.
- Tripartite API-resale agreement system and standardized online contracts landed, forming a uniform defensive basis.
Client names and commercial data are anonymized. The rules, regulatory procedures and deliverable types described are as they occurred, not simplified.