Robinhood Wallet and Fomo Memo Buying raise questions about bank card network cryptocurrency rules

Digital transaction apps allow credit cards to purchase memin without KYC verification

Two digital transaction apps now allow users to purchase memin using credit cards with little knowledge of cryptocurrency and no need to fill out an additional authentication form at checkout, all through a code commonly used in the media payment world.

It was found that this solution could be significant because it eliminated one of the main obstacles facing the retail cryptocurrency market-the transfer of fiat currency to the blockchain via mobile phones in the shortest possible time. If a standard credit card checkout allows one-click purchase of memin, the potential target audience will far exceed those willing to transfer funds to exchanges. However, this payment method appears to violate certain credit card networks 'rules on cryptocurrency payments, which is currently being investigated by at least one major bank and one state agency.

One-click payment without KYC is like buying a cup of coffee

Users who use Robinhood Wallet and Fomo can choose any token (such as dogwifhat) and pay with a credit card via Apple Pay or Google Pay. There is no need to fill out an additional "Know Your Customer" form when trading using these two apps. Cryptocurrency payment company Crossmint is responsible for the entire transaction process, transferring tokens directly into customers 'wallets.

Its appeal lies in convenience. Se Yong Park, CEO of Fomo, said that buying memin should be no different from buying a cup of coffee in the morning. Fonz Olvera, head of strategy at Crossmint, said this KYC-free structure is proprietary, with some content being a "secret recipe" and the rest closely integrating checkout functions into mobile applications.

Crossmint indicates that the effect is significant. Its report on Fomo integration noted that within one week of launch, the number of active traders increased sevenfold, and Crossmint's system has processed transactions from more than 68,000 new clients. In June this year, the company completed a $75 million Series B financing, with a valuation of $550 million. Robinhood also added Crossmint payment options to his wallet last month.

The code shows "movie" rather than "cryptocurrency"

The problem is how to classify these transactions. According to the survey, transactions using Visa and Mastercard to purchase WIF were assigned the merchant category code MCC5815. According to Visa's Merchant Data Standards Manual, MCC 5815 refers to "digital goods" and covers "audio-visual media including books, movies and music." In addition, purchases in New York State also earn regular credit card points.

Transactions in the cryptocurrency space should have been different. For transactions involving cryptocurrencies, according to Visa's April 2026 manual, MCC 6012 or 6051 should be used with a special condition indicator 7 and a quasi-cash transaction signal. According to Mastercard's June 2026 regulations, cryptocurrency transactions should be assigned MCC6051 (quasi-cash: merchant) and transaction category code TCC U. If floating cryptocurrencies and additional tokens are involved, the transaction type identifier is P70, and if fiat backed stablecoins and central bank digital currencies are involved, it is P76.

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Additional issues caused by the reward policy

The points reward policy brings another complicating factor. Chase Sapphire Preferred's ultimate reward plan agreement treats cryptocurrency transactions as cash-based transactions, so it does not qualify for purchase and points cannot be earned. Chase explained to investigators that the relevant Visa transaction was not classified as cryptocurrency and the category was displayed incorrectly, so points should not be awarded, and had submitted a complaint to Visa. At the same time, the New York State Attorney General has learned of the situation and is investigating.

Crossmint's defense and issues that may not be resolved

Crossmint stated that the MCC 5815 classification has been reviewed with relevant partners at the time of access and is applicable to qualified digital collectibles. The company cited the U.S. Securities and Exchange Commission's position that certain memes are similar to collectibles rather than securities. In an employee statement dated February 27, 2025, the SEC's corporate finance department pointed out that typical memocoins are purchased for entertainment, social interaction and cultural purposes, and the price is mainly driven by speculation and demand, describing them as "may be similar to collectibles", and said that transactions involving such memocoins usually do not constitute securities issuance, but emphasized that specific circumstances still require specific analysis.

However, securities law and credit card network classification are two different issues. Payment experts say a token may not be regulated by federal securities regulations, but may still be considered a cryptocurrency by payment network rules. Crossmint said its checkout system uses anti-money laundering monitoring and fraud control measures even if customers do not encounter a separate KYC form.

The impact goes far beyond these two apps. According to reports, in August this year, more than 99% of Robinhood Chain's trading volume came from memin activity, although the network focuses on tokenized stocks. Making these assets as easy as any other credit card purchase could attract more retail money into one of the most speculative corners of cryptocurrency, while also forcing issuers, acquirers and credit card networks to decide where the boundaries of "digital collectibles" are and where cryptocurrency transactions begin.