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Zama Protocol: The FHE Unicorn Building Blockchain's Confidentiality Layer

· 11 min read
Dora Noda
Software Engineer

Zama has established itself as the definitive leader in Fully Homomorphic Encryption (FHE) for blockchain, becoming the world's first FHE unicorn in June 2025 with a $1 billion valuation after raising over $150 million. The Paris-based company doesn't compete with blockchains—it provides the cryptographic infrastructure enabling any EVM chain to process encrypted smart contracts without ever decrypting the underlying data. With its mainnet launched on Ethereum in late December 2025 and the $ZAMA token auction beginning January 12, 2026, Zama sits at a critical inflection point where theoretical cryptographic breakthroughs meet production-ready deployment.

The strategic significance cannot be overstated: while Zero-Knowledge proofs prove computation correctness and Trusted Execution Environments rely on hardware security, FHE uniquely enables computation on encrypted data from multiple parties—solving the fundamental blockchain trilemma between transparency, privacy, and compliance. Institutions like JP Morgan have already validated this approach through Project EPIC, demonstrating confidential tokenized asset trading with full regulatory compliance. Zama's positioning as infrastructure rather than a competing chain means it captures value regardless of which L1 or L2 ultimately dominates.


Technical architecture enables encrypted computation without trust assumptions

Fully Homomorphic Encryption represents a breakthrough in cryptography that has existed in theory since 2009 but only recently became practical. The term "homomorphic" refers to the mathematical property where operations performed on encrypted data, when decrypted, yield identical results to operations on the original plaintext. Zama's implementation uses TFHE (Torus Fully Homomorphic Encryption), a scheme distinguished by fast bootstrapping—the fundamental operation that resets accumulated noise in ciphertexts and enables unlimited computation depth.

The fhEVM architecture introduces a symbolic execution model that elegantly solves blockchain's performance constraints. Rather than processing actual encrypted data on-chain, smart contracts execute using lightweight handles (pointers) while actual FHE computations are offloaded asynchronously to specialized coprocessors. This design means host chains like Ethereum require no modifications, non-FHE transactions experience no slowdown, and FHE operations can execute in parallel rather than sequentially. The architecture comprises five integrated components: the fhEVM library for Solidity developers, coprocessor nodes performing FHE computation, a Key Management Service using 13 MPC nodes with threshold decryption, an Access Control List contract for programmable privacy, and a Gateway orchestrating cross-chain operations.

Performance benchmarks demonstrate rapid improvement. Bootstrapping latency—the critical metric for FHE—dropped from 53 milliseconds initially to under 1 millisecond on NVIDIA H100 GPUs, with throughput reaching 189,000 bootstraps per second across eight H100s. Current protocol throughput stands at 20+ TPS on CPU, sufficient for all encrypted Ethereum transactions today. The roadmap projects 500-1,000 TPS by end of 2026 with GPU migration, scaling to 100,000+ TPS with dedicated ASICs in 2027-2028. Unlike TEE solutions vulnerable to hardware side-channel attacks, FHE's security rests on lattice-based cryptographic hardness assumptions that provide post-quantum resistance.


Developer tooling has matured from research to production

Zama's open-source ecosystem comprises four interconnected products that have attracted over 5,000 developers, representing approximately 70% market share in blockchain FHE. The TFHE-rs library provides a pure Rust implementation with GPU acceleration via CUDA, FPGA support through AMD Alveo hardware, and multi-level APIs ranging from high-level operations to core cryptographic primitives. The library supports encrypted integers up to 256 bits with operations including arithmetic, comparisons, and conditional branching.

Concrete functions as a TFHE compiler built on LLVM/MLIR infrastructure, transforming standard Python programs into FHE-equivalent circuits. Developers require no cryptography expertise—they write normal Python code and Concrete handles the complexity of circuit optimization, key generation, and ciphertext management. For machine learning applications, Concrete ML provides drop-in replacements for scikit-learn models that automatically compile to FHE circuits, supporting linear models, tree-based ensembles, and even encrypted LLM fine-tuning. Version 1.8 demonstrated fine-tuning a LLAMA 8B model on 100,000 encrypted tokens in approximately 70 hours.

The fhEVM Solidity library enables developers to write confidential smart contracts using familiar syntax with encrypted types (euint8 through euint256, ebool, eaddress). An encrypted ERC-20 transfer, for example, uses TFHE.le() to compare encrypted balances and TFHE.select() for conditional logic—all without revealing values. The September 2025 partnership with OpenZeppelin established standardized confidential token implementations, sealed-bid auction primitives, and governance frameworks that accelerate enterprise adoption.


Business model captures value as infrastructure provider

Zama's funding trajectory reflects accelerating institutional confidence: a $73 million Series A in March 2024 led by Multicoin Capital and Protocol Labs, followed by a $57 million Series B in June 2025 led by Pantera Capital that achieved unicorn status. The investor roster reads as blockchain royalty—Juan Benet (Filecoin founder and board member), Gavin Wood (Ethereum and Polkadot co-founder), Anatoly Yakovenko (Solana co-founder), and Tarun Chitra (Gauntlet founder) all participated.

The revenue model employs BSD3-Clear dual licensing: technologies remain free for non-commercial research and prototyping, while production deployment requires purchasing patent usage rights. By March 2024, Zama had signed over $50 million in contract value within six months of commercialization, with hundreds of additional customers in pipeline. Transaction-based pricing applies for private blockchain deployments, while crypto projects often pay in tokens. The upcoming Zama Protocol introduces on-chain economics: operators stake $ZAMA to qualify for encryption and decryption work, with fees ranging from $0.005 - $0.50 per ZKPoK verification and $0.001 - $0.10 per decryption operation.

The team represents the largest dedicated FHE research organization globally: 96+ employees across 26 nationalities, with 37 holding PhDs (~40% of staff). Co-founder and CTO Pascal Paillier invented the Paillier encryption scheme used in billions of smart cards and received the prestigious IACR Fellowship in 2025. CEO Rand Hindi previously founded Snips, an AI voice platform acquired by Sonos. This concentration of cryptographic talent creates substantial intellectual property moats—Paillier holds approximately 25 patent families protecting core innovations.


Competitive positioning as the picks-and-shovels play for blockchain privacy

The privacy solution landscape divides into three fundamental approaches, each with distinct trade-offs. Trusted Execution Environments (TEEs), used by Secret Network and Oasis Network, offer near-native performance but rely on hardware security with a trust threshold of one—if the enclave is compromised, all privacy breaks. The October 2022 disclosure of TEE vulnerabilities affecting Secret Network underscored these risks. Zero-Knowledge proofs, employed by Aztec Protocol ($100M Series B from a16z), prove computation correctness without revealing inputs but cannot compute on encrypted data from multiple parties—limiting their applicability for shared state applications like lending pools.

FHE occupies a unique position: mathematically guaranteed privacy with configurable trust thresholds, no hardware dependencies, and the crucial ability to process encrypted data from multiple sources. This enables use cases impossible with other approaches—confidential AMMs computing over encrypted reserves from liquidity providers, or lending protocols managing encrypted collateral positions.

Within FHE specifically, Zama operates as the infrastructure layer while others build chains on top. Fhenix ($22M raised) builds an optimistic rollup L2 using Zama's TFHE-rs via partnership, having deployed CoFHE coprocessor on Arbitrum as the first practical FHE implementation. Inco Network ($4.5M raised) provides confidentiality-as-a-service for existing chains using Zama's fhEVM, offering both TEE-based fast processing and FHE+MPC secure computation. Both projects depend on Zama's core technology—meaning Zama captures value regardless of which FHE chain gains dominance. This infrastructure positioning mirrors how OpenZeppelin profits from smart contract adoption without competing with Ethereum directly.


Use cases span DeFi, AI, RWAs, and compliant payments

In DeFi, FHE fundamentally solves MEV (Maximal Extractable Value). Because transaction parameters remain encrypted until block inclusion, front-running and sandwich attacks become mathematically impossible—there is simply no visible mempool data to exploit. The ZamaSwap reference implementation demonstrates encrypted AMM swaps with fully encrypted balances and pool reserves. Beyond MEV protection, confidential lending protocols can maintain encrypted collateral positions and liquidation thresholds, enabling on-chain credit scoring computed over private financial data.

For AI and machine learning, Concrete ML enables privacy-preserving computation across healthcare (encrypted medical diagnosis), finance (fraud detection on encrypted transactions), and biometrics (authentication without revealing identity). The framework supports encrypted LLM fine-tuning—training language models on sensitive data that never leaves encrypted form. As AI agents proliferate across Web3 infrastructure, FHE provides the confidential computation layer ensuring data privacy without sacrificing utility.

Real-World Asset tokenization represents perhaps the largest opportunity. The JP Morgan Kinexys Project EPIC proof-of-concept demonstrated institutional asset tokenization with encrypted bid amounts, hidden investor holdings, and KYC/AML checks on encrypted data—maintaining full regulatory compliance. This addresses the fundamental barrier preventing traditional finance from using public blockchains: the inability to hide trading strategies and positions from competitors. With tokenized RWAs projected as a $100+ trillion addressable market, FHE unlocks institutional participation that private blockchains cannot serve.

Payment and stablecoin privacy completes the picture. The December 2025 mainnet launch included the first confidential stablecoin transfer using cUSDT. Unlike mixing-based approaches (Tornado Cash), FHE enables programmable compliance—developers define access control rules determining who can decrypt what, enabling regulatory-compliant privacy rather than absolute anonymity. Authorized auditors and regulators receive appropriate access without compromising general transaction privacy.


Regulatory landscape creates tailwinds for compliant privacy

The EU's MiCA framework, fully effective since December 30, 2024, creates strong demand for privacy solutions that maintain compliance. The Travel Rule requires crypto asset service providers to share originator and beneficiary data for all transfers, with no de minimis threshold—making privacy-by-default approaches like mixing impractical. FHE's selective disclosure mechanisms align precisely with this requirement: transactions remain encrypted from general observation while authorized parties access necessary information.

In the United States, the July 2025 signing of the GENIUS Act established the first comprehensive federal stablecoin framework, signaling regulatory maturation that favors compliant privacy solutions over regulatory evasion. The Asia-Pacific region continues advancing progressive frameworks, with Hong Kong's stablecoin regulatory regime effective August 2025 and Singapore maintaining leadership in crypto licensing. Across jurisdictions, the pattern favors solutions enabling both privacy and regulatory compliance—precisely Zama's value proposition.

The 2025 enforcement shift from reactive prosecution to proactive frameworks creates opportunity for FHE adoption. Projects building with compliant privacy architectures from inception—rather than retrofitting privacy-first designs for compliance—will find easier paths to institutional adoption and regulatory approval.


Technical and market challenges require careful navigation

Performance remains the primary barrier, though the trajectory is clear. FHE operations currently run approximately 100x slower than plaintext equivalents—acceptable for low-frequency high-value transactions but constraining for high-throughput applications. The scaling roadmap depends on hardware acceleration: GPU migration in 2026, FPGA optimization, and ultimately purpose-built ASICs. The DARPA DPRIVE program funding Intel, Duality, SRI, and Niobium for FHE accelerator development represents significant government investment accelerating this timeline.

Key management introduces its own complexities. The current 13-node MPC committee for threshold decryption requires honest majority assumptions—collusion among threshold nodes could enable "silent attacks" undetectable by other participants. The roadmap targets expansion to 100+ nodes with HSM integration and post-quantum ZK proofs, strengthening these guarantees.

Competition from TEE and ZK alternatives should not be dismissed. Secret Network and Oasis offer production-ready confidential computing with substantially better current performance. Aztec's $100M backing and team that invented PLONK—the dominant ZK-SNARK construction—means formidable competition in privacy-preserving rollups. The TEE performance advantage may persist if hardware security improves faster than FHE acceleration, though hardware trust assumptions create a fundamental ceiling ZK and FHE solutions don't share.


Conclusion: Infrastructure positioning captures value across ecosystem growth

Zama's strategic genius lies in its positioning as infrastructure rather than competing chain. Both Fhenix and Inco—the leading FHE blockchain implementations—build on Zama's TFHE-rs and fhEVM technology, meaning Zama captures licensing revenue regardless of which protocol gains adoption. The dual licensing model ensures open-source developer adoption drives commercial enterprise demand, while the $ZAMA token launching in January 2026 creates on-chain economics aligning operator incentives with network growth.

Three factors will determine Zama's ultimate success: execution on the performance roadmap from 20 TPS today to 100,000+ TPS with ASICs; institutional adoption following the JP Morgan validation; and developer ecosystem growth beyond current 5,000 developers to mainstream Web3 penetration. The regulatory environment has shifted decisively in favor of compliant privacy, and FHE's unique capability for encrypted multi-party computation addresses use cases neither ZK nor TEE can serve.

For Web3 researchers and investors, Zama represents the canonical "picks and shovels" opportunity in blockchain privacy—infrastructure that captures value as the confidential computing layer matures across DeFi, AI, RWAs, and institutional adoption. The $1 billion valuation prices significant execution risk, but successful delivery of the technical roadmap could position Zama as essential infrastructure for the next decade of blockchain development.

The GENIUS Act Turns Stablecoins into Real Payment Rails — Here’s What It Unlocks for Builders

· 8 min read
Dora Noda
Software Engineer

U.S. stablecoins just graduated from a legal gray area to a federally regulated payments instrument. The new GENIUS Act establishes a comprehensive rulebook for issuing, backing, redeeming, and supervising USD-pegged stablecoins. This newfound clarity doesn’t stifle innovation—it standardizes the core assumptions that developers and businesses can safely build upon, unlocking the next wave of financial infrastructure.


What the Law Locks In

The Act creates a stable foundation by codifying several non-negotiable principles for payment stablecoins.

  • Full-Reserve, Cash-Like Design: Issuers must maintain 1:1 identifiable reserves in highly liquid assets, such as cash, demand deposits, short-dated U.S. Treasuries, and government money market funds. They are required to publish the composition of these reserves on their website monthly. Crucially, rehypothecation—lending out or reusing customer assets—is strictly prohibited.
  • Disciplined Redemption: Issuers must publish a clear redemption policy and disclose all associated fees. The ability to halt redemptions is removed from the issuer’s discretion; limits can only be imposed when ordered by regulators under extraordinary circumstances.
  • Rigorous Supervision and Reporting: Monthly reserve reports must be examined by a PCAOB-registered public accounting firm, with the CEO and CFO personally certifying their accuracy. Compliance with Anti-Money Laundering (AML) and sanctions rules is now an explicit requirement.
  • Clear Licensing Paths: The Act defines who can issue stablecoins. The framework includes bank subsidiaries, federally licensed nonbank issuers supervised by the OCC, and state-qualified issuers under a $10 billion threshold, above which federal oversight generally applies.
  • Securities and Commodities Clarity: In a landmark move, a compliant payment stablecoin is explicitly defined as not being a security, commodity, or a share in an investment company. This resolves years of ambiguity and provides a clear path for custody providers, brokers, and market infrastructure.
  • Consumer Protection in Failure: Should an issuer fail, stablecoin holders are granted first-priority access to the required reserves. The law directs courts to begin distributing these funds quickly, protecting end-users.
  • Self-Custody and P2P Carve-Outs: The Act acknowledges the nature of blockchains by explicitly protecting direct, lawful peer-to-peer transfers and the use of self-custody wallets from certain restrictions.
  • Standards and Timelines: Regulators have approximately one year to issue implementing rules and are empowered to set interoperability standards. Builders should anticipate forthcoming API and specification updates.

The “No-Interest” Rule and the Rewards Debate

A key provision in the GENIUS Act bars issuers from paying any form of interest or yield to holders simply for holding the stablecoin. This cements the product’s identity as digital cash, not a deposit substitute.

However, a potential loophole has been widely discussed. While the statute restricts issuers, it doesn’t directly block exchanges, affiliates, or other third parties from offering "rewards" programs that function like interest. Banking associations are already lobbying for this gap to be closed. This is an area where builders should expect further rulemaking or legislative clarification.

Globally, the regulatory landscape is varied but trending toward stricter rules. The EU’s MiCA framework, for instance, prohibits both issuers and service providers from paying interest on certain stablecoins. Hong Kong has also launched a licensing regime with similar considerations. For those building cross-border solutions, designing for the strictest venue from the start is the most resilient strategy.


Why This Unlocks New Markets for Blockchain Infrastructure

With a clear regulatory perimeter, the focus shifts from speculation to utility. This opens up a greenfield opportunity for building the picks-and-shovels infrastructure that a mature stablecoin ecosystem requires.

  • Proof-of-Reserves as a Data Product: Transform mandatory monthly disclosures into real-time, on-chain attestations. Build dashboards, oracles, and parsers that provide alerts on reserve composition, tenor, and concentration drift, feeding directly into institutional compliance systems.
  • Redemption-SLA Orchestration: Create services that abstract away the complexity of ACH, FedNow, and wire rails. Offer a unified "redeem at par" coordinator with transparent fee structures, queue management, and incident workflows that meet regulatory expectations for timely redemption.
  • Compliance-as-Code Toolkits: Ship embeddable software modules for BSA/AML/KYC, sanctions screening, Travel Rule payloads, and suspicious activity reporting. These toolkits can come pre-mapped to the specific controls required by the GENIUS Act.
  • Programmable Allowlists: Develop policy-driven allow/deny logic that can be deployed at RPC gateways, custody layers, or within smart contracts. This logic can be enforced across different blockchains and provide a clear audit trail for regulators.
  • Stablecoin Risk Analytics: Build sophisticated tools for wallet and entity heuristics, transaction classification, and de-peg stress monitoring. Offer circuit-breaker recommendations that issuers and exchanges can integrate into their core engines.
  • Interoperability and Bridge Policy Layers: With the Act encouraging interoperability standards, there is a clear need for policy-aware bridges that can propagate compliance metadata and redemption guarantees across Layer-1 and Layer-2 networks.
  • Bank-Grade Issuance Stacks: Provide the tooling for banks and credit unions to run their own issuance, reserve operations, and custody within their existing control frameworks, complete with regulatory capital and risk reporting.
  • Merchant Acceptance Kits: Develop SDKs for point-of-sale systems, payout APIs, and accounting plugins that deliver a card-network-like developer experience for stablecoin payments, including fee management and reconciliation.
  • Failure-Mode Automation: Since holder claims have statutory priority in an insolvency, create resolution playbooks and automated tools that can snapshot holder balances, generate claim files, and orchestrate reserve distributions if an issuer fails.

Architecture Patterns That Will Win

  • Event-Sourced Compliance Plane: Stream every transfer, KYC update, and reserve change to an immutable log. This allows for the compilation of explainable, auditable reports for both bank and state supervisors on demand.
  • Policy-Aware RPC and Indexers: Enforce rules at the infrastructure level (RPC gateways, indexers), not just within applications. Instrumenting this layer with policy IDs makes auditing straightforward and comprehensive.
  • Attestation Pipelines: Treat reserve reports like financial statements. Build pipelines that ingest, validate, attest, and notarize reserve data on-chain. Expose this verified data via a simple /reserves API for wallets, exchanges, and auditors.
  • Multi-Venue Redemption Router: Orchestrate redemptions across multiple bank accounts, payment rails, and custodians using best-execution logic that optimizes for speed, cost, and counterparty risk.

Open Questions to Track (and How to De-Risk Now)

  • Rewards vs. Interest: Expect further guidance on what affiliates and exchanges can offer. Until then, design rewards to be non-balance-linked and non-duration-based. Use feature flags for anything that resembles yield.
  • Federal–State Split at $10B Outstanding: Issuers approaching this threshold will need to plan their transition to federal oversight. The smart play is to build your compliance stack to federal standards from day one to avoid costly rewrites.
  • Rulemaking Timeline and Spec Drift: The next 12 months will see evolving drafts of the final rules. Budget for schema changes in your APIs and attestations, and seek early alignment with regulatory expectations.

A Practical Builder’s Checklist

  1. Map your product to the statute: Identify which GENIUS Act obligations directly impact your service, whether it’s issuance, custody, payments, or analytics.
  2. Instrument transparency: Produce machine-readable artifacts for your reserve data, fee schedules, and redemption policies. Version them and expose them via public endpoints.
  3. Bake in portability: Normalize your system for the strictest global regulations now—like MiCA’s rules on interest—to avoid forking your codebase for different markets later.
  4. Design for audits: Log every compliance decision, whitelist change, and sanctions screening result with a hash, timestamp, and operator identity to create a one-click view for examiners.
  5. Scenario test failure modes: Run tabletop exercises for de-pegging events, bank partner outages, and issuer failures. Wire the resulting playbooks to actionable buttons in your admin consoles.

The Bottom Line

The GENIUS Act does more than just regulate stablecoins; it standardizes the interface between financial technology and regulatory compliance. For infrastructure builders, this means less time guessing at policy and more time shipping the rails that enterprises, banks, and global platforms can adopt with confidence. By designing to the rulebook today—focusing on reserves, redemptions, reporting, and risk—you can build the foundational platforms that others will plug into as stablecoins become the internet’s default settlement asset.

Note: This article is for informational purposes only and is not legal advice. Builders should consult legal counsel for specifics on licensing, supervision, and product design under the Act.