[Web3 x Welfare] How I obtained a 'completely white' stamp of approval from the Financial Services Agency using only text for a wallet that doesn't touch cryptocurrency

Introduction: 'Soyogi Pocket' in action at the front lines of welfare

I am currently engaged in activities to support people who fall through the cracks of existing welfare systems (such as young carers, those with severe social withdrawal, the economically disadvantaged, and victims of financial abuse). To solve the issues I observed, I developed and have already begun operating 'Soyogi Pocket,' a web wallet specialized for welfare.

Its greatest feature is that 'users can use it without ever touching blockchain or cryptocurrency.' In other words, because it can be used without leaving a history on the blockchain, it is designed to be difficult for perpetrators of financial abuse to discover.
Behind the scenes, it makes full use of Web3 technologies like the Japanese Yen stablecoin 'JPYC' and SBTs (Soulbound Tokens), but the user experience is no different from a typical point app. Furthermore, I avoided words like 'wallet' that evoke thoughts of purses or money, intentionally choosing 'pocket' instead, which is a deliberate choice to ensure that even if it is seen by a perpetrator of financial abuse, it is less likely to be exploited.

However, in implementing and sustaining such a new payment scheme in society, there was a major wall that could not be avoided. That was legal regulation, such as the 'Payment Services Act'.

The high hurdle of consulting with the Financial Services Agency, and my commitment to a 'text-based' approach

If our scheme were to fall under strict regulations such as 'Prepaid Payment Instruments,' 'Funds Transfer Services,' or 'Electronic Payment Instrument Exchange Services,' it would become difficult to continue our current support activities. Looking ahead to the full-scale expansion of the service, it was necessary to conduct a prior consultation on legal interpretations with the Financial Services Agency (the fintech-related help desk), which is the regulatory authority.

Here, I had another personal challenge.
Due to a chronic illness (for health reasons), long meetings or calls, whether online or in person, were difficult for me. While it is generally assumed that consulting with government agencies means 'first visiting the office or explaining the situation via phone or online meeting,' I decided to take the approach of 'completing everything using only text (email or documents).'

Preparation is everything: The '3-layer' technical specification that moved the government

To have government officials understand a complex Web3 system and make a legal judgment using only text, I needed 'perfect documentation' above all else.

Therefore, I structurally separated the system's behavior into the following '3 layers' based on their legal and technical characteristics, and created a technical specification that clarified the flow of funds and the location of rights for each.

1. Off-chain layer (Free points): Payment and benefit units for users

2. On-chain layer (SBT): Valueless proof of social contribution

3. On-chain layer (JPYC): Fund settlement via the operator's own account (gasless donations and merchant settlement)

Furthermore, I emphasized the core of the design—that 'there is zero path for users to pay money to top up' and 'users do not come into contact with stablecoins like JPYC at all'—and thoroughly organized the legal points (why we believe it does not fall under certain regulations) before sending the consultation email.

Result: Obtained a 'completely white' response in just a few hours

The result was smoother than I had imagined.

The response I received from the Financial Services Agency official was the clearest possible answer: as long as it is a scheme for granting completely free points and JPYC settlement via our own account as we constructed, 'it is considered that registration for Prepaid Payment Instruments, Electronic Payment Instrument Exchange Services, or Funds Transfer Services is not required.'

By organizing the thick specification and the legal points from the start, I reduced unnecessary back-and-forth with the government and was able to obtain a 'completely white' stamp of approval based solely on text, without putting a strain on my health.

Early support for the Kaia chain paid off

There was one other event that significantly moved the project forward this time.
Our service utilizes 'JPYC' as the foundation for donations and payments. Initially, we proceeded with development assuming only the Polygon chain, but after confirming that JPYC had begun supporting a new chain called 'Kaia' and that transaction volume was increasing rapidly, we updated our system at an early stage to a design that seamlessly supports both the Polygon and Kaia chains.

The fact that we were the first to complete this multi-chain support in a production environment—which automatically detects the network the user is connected to and allows processing on any chain without the user bearing gas fees (POL or Kaia)—ultimately proved to be a major success. Maintaining such high technical agility has become a significant driving force and source of confidence, allowing us to overcome legal barriers and push the project further forward.

Six months since the ideathon. The day I brought everything to life on my own.

Looking back, the origin of this 'Soyogi Pocket' was an ideathon I participated in about six months ago.

At the time, I was grateful to receive an overall 3rd place ranking for the idea, but I did not want to let it end as a mere 'concept.' Rather than outsourcing the development to someone else, I insisted on writing all the code myself by making full use of AI, adding numerous improvements for actual operation, and implementing it with my own hands.

The day I received the stamp of approval for legal clearance from the Financial Services Agency was a deeply moving day for me, as I realized that the idea from six months ago had truly taken a solid 'form' and had firmly reached the starting line for social implementation.

To the next step

I have completely dispelled the anxiety that 'the activities might stop,' and I can now confidently step on the gas toward the full-scale operation and expansion of the system utilizing JPYC.

Depending on how it is used, Web3 technology can become a powerful infrastructure to support people who could not be saved under existing frameworks. I would like to continue sharing on this note how we overcome the barriers of technology, law, and my own physical condition to advance social implementation.

[Three Support Windows] We have prepared three windows for those who wish to support our challenge.

Donations to the LEAF project (development of an attachment that can fulfill the role of a guide dog just by being attached) and support for our activities in general (Giveth)
☆Cryptocurrency support⇩

Support for our activities in general. If you would like to support the activities we carry out daily to help the socially vulnerable, please support us with even a small amount via this link.
☆Credit card and e-money support⇩

☆Support with JPYC (stablecoin)⇩ *Automatically supports both Polygon and Kaia JPYC