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Stablecoins and the Trillion‑Dollar Payment Shift

· 10 min read
Dora Noda
Software Engineer

perspectives from Paolo Ardoino, Charles Cascarilla and Rob Hadick

Background: Stablecoins are maturing into a payments rail

  • Rapid growth: Stablecoins began as collateral for trading on crypto exchanges, but by mid‑2025 they had become an important part of global payments. The market cap of dollar‑denominated stablecoins exceeded US$210 billion by the end of 2024 and transaction volume reached US$26.1 trillion, growing 57 % year‑on‑year. McKinsey estimated that stablecoins settle roughly US$30 billion of transactions each day and their yearly transaction volume reached US$27 trillion – still less than 1 % of all money flows but rising quickly.
  • Real payments, not just trading: The Boston Consulting Group estimates that 5–10 % (≈US$1.3 trillion) of stablecoin volumes at the end of 2024 were genuine payments such as cross‑border remittances and corporate treasury operations. Cross‑border remittances account for roughly 10 % of the transaction count. By early 2025 stablecoins were used for ≈3 % of the US$200 trillion cross‑border payments market, with capital‑markets use still less than 1 %.
  • Drivers of adoption: Emerging markets: In countries where local currencies depreciate by 50–60 % per year, stablecoins provide a digital dollar for savers and businesses. Adoption is particularly strong in Turkey, Argentina, Vietnam, Nigeria and parts of Africa. Technology and infrastructure: New orchestration layers and payment service providers (e.g., Bridge, Conduit, MoneyGram/USDC via MoneyGram) link blockchains with bank rails, reducing friction and improving compliance. Regulation: The GENIUS Act (2025) established a U.S. federal framework for payment stablecoins. The law sets strict reserve, transparency and AML requirements and creates a Stablecoin Certification Review Committee to decide whether state regimes are "substantially similar". It allows state‑qualified issuers with less than US$10 billion in circulation to operate under state oversight when standards meet federal levels. This clarity encouraged legacy institutions such as Visa to test stablecoin‑funded international transfers, with Visa's Mark Nelsen noting that the GENIUS Act "changed everything" by legitimising stablecoins

Paolo Ardoino (CEO, Tether)

Vision: a “digital dollar for the unbanked”

  • Scale and usage: Ardoino says USDT serves 500 million users across emerging markets; about 35 % use it as a savings account, and 60–70 % of transactions involve only stablecoins (not crypto trading). He emphasises that USDT is now “the most used digital dollar in the world” and acts as “the dollar for the last mile, for the unbanked”. Tether estimates that 60 % of its market‑cap growth comes from grassroots use in Asia, Africa and Latin America.
  • Emerging‑market focus: Ardoino notes that in the U.S. the payment system already works well, so stablecoins offer only incremental benefits. In emerging economies, however, stablecoins improve payment efficiency by 30–40 % and protect savings from high inflation. He describes USDT as a financial lifeline in Turkey, Argentina and Vietnam where local currencies are volatile.
  • Compliance and regulation: Ardoino publicly supports the GENIUS Act. In a 2025 Bankless interview he said the Act sets “a strong framework for domestic and foreign stablecoins” and that Tether, as a foreign issuer, intends to comply. He highlighted Tether’s monitoring systems and cooperation with over 250 law‑enforcement agencies, emphasising that high compliance standards help the industry mature. Ardoino expects the U.S. framework to become a template for other countries and predicted that reciprocal recognition would allow Tether’s offshore USDT to circulate widely.
  • Reserves and profitability: Ardoino underscores that Tether’s tokens are fully backed by cash and equivalents. He said the company holds about US$125 billion in U.S. Treasuries and has US$176 billion of total equity, making Tether one of the largest holders of U.S. government debt. In 2024 Tether generated US$13.7 billion profit and he expects this to grow. He positions Tether as a decentralised buyer of U.S. debt, diversifying global holders.
  • Infrastructure initiatives: Ardoino announced an ambitious African energy project: Tether plans to build 100 000–150 000 solar‑powered micro‑stations, each serving villages with rechargeable batteries. The subscription model (~US$3 per month) allows villagers to swap batteries and use USDT for payments, supporting a decentralised economy. Tether also invests in peer‑to‑peer AI, telecoms and social media platforms to expand its ecosystem.
  • Perspective on the payment shift: Ardoino views stablecoins as transformational for financial inclusion, enabling billions without bank accounts to access a digital dollar. He argues that stablecoins complement rather than replace banks; they provide an on‑ramp into the U.S. financial system for people in high‑inflation economies. He also claims the growth of USDT diversifies demand for U.S. Treasuries, benefiting the U.S. government.

Charles Cascarilla (Co‑Founder & CEO, Paxos)

Vision: modernising the U.S. dollar and preserving its leadership

  • National imperative: In testimony before the U.S. House Financial Services Committee (March 2025), Cascarilla argued that “stablecoins are a national imperative” for the United States. He warned that failure to modernise could erode dollar dominance as other countries deploy digital currencies. He compared the shift to moving from physical mail to email; programmable money will enable instantaneous, near‑zero‑cost transfers accessible via smartphones.
  • Regulatory blueprint: Cascarilla praised the GENIUS Act as a good baseline but urged Congress to add cross‑jurisdictional reciprocity. He recommended that the Treasury set deadlines to recognise foreign regulatory regimes so that U.S.‑issued stablecoins (and Singapore‑issued USDG) can be used abroad. Without reciprocity, he warned that U.S. firms might be locked out of global markets. He also advocated an equivalence regime where issuers choose either state or federal oversight, provided state standards meet or exceed federal rules.
  • Private sector vs. CBDCs: Cascarilla believes the private sector should lead innovation in digital dollars, arguing that a central bank digital currency (CBDC) would compete with regulated stablecoins and stifle innovation. During congressional testimony he said there is no immediate need for a U.S. CBDC, because stablecoins already deliver programmable digital money. He emphasised that stablecoin issuers must hold 1:1 cash reserves, offer daily attestations, restrict asset rehypothecation, and comply with AML/KYC/BSA standards.
  • Cross‑border focus: Cascarilla stressed that the U.S. must set global standards to enable interoperable cross‑border payments. He noted that high inflation in 2023–24 pushed stablecoins into mainstream remittances and the U.S. government’s attitude shifted from resistance to acceptance. He told lawmakers that only New York currently issues regulated stablecoins but a federal floor would raise standards across states.
  • Business model and partnerships: Paxos positions itself as a regulated infrastructure provider. It issues the white‑label stablecoins used by PayPal (PYUSD) and Mercado Libre and provides tokenisation services for Mastercard, Robinhood and others. Cascarilla notes that eight years ago people asked how stablecoins could make money; today every institution that moves dollars across borders is exploring them.
  • Perspective on the payment shift: For Cascarilla, stablecoins are the next evolution of money movement. They will not replace traditional banks but will provide a programmable layer on top of the existing banking system. He believes the U.S. must lead by creating robust regulations that encourage innovation while protecting consumers and ensuring the dollar remains the world’s reserve currency. Failure to do so could allow other jurisdictions to set the standards and threaten U.S. monetary primacy.

Rob Hadick (General Partner, Dragonfly)

Vision: stablecoins as a disruptive payment infrastructure

  • Stablecoins as a disruptor: In a June 2025 article (translated by Foresight News), Hadick wrote that stablecoins are not meant to improve existing payment networks but to completely disrupt them. Stablecoins allow businesses to bypass traditional payment rails; when payment networks are built on stablecoins, all transactions are simply ledger updates rather than messages between banks. He warned that merely connecting legacy payment channels underestimates stablecoins’ potential; instead, the industry should reimagine payment channels from the ground up.
  • Cross‑border remittances and market size: At the TOKEN2049 panel, Hadick disclosed that ≈10 % of remittances from the U.S. to India and Mexico already use stablecoins, illustrating the shift from traditional remittance rails. He estimated that the cross‑border payments market is about US$200 trillion, roughly eight times the entire crypto market. He emphasised that small and medium‑sized enterprises (SMEs) are underserved by banks and need frictionless capital flows. Dragonfly invests in “last‑mile” companies that handle compliance and consumer interaction rather than mere API aggregators.
  • Stablecoin market segmentation: In a Blockworks interview, Hadick referenced data showing that business‑to‑business (B2B) stablecoin payments were annualising US$36 billion, surpassing person‑to‑person volumes of US$18 billion. He noted that USDT dominates 80–90 % of B2B payments, while USDC captures roughly 30 % of monthly volume. He was surprised that Circle (USDC) had not gained more share, though he observed signs of growth on the B2B side. Hadick interprets this data as evidence that stablecoins are shifting from retail speculation to institutional usage.
  • Orchestration layers and compliance: Hadick emphasises the importance of orchestration layers—platforms that bridge public blockchains with traditional bank rails. He notes that the biggest value will accrue to settlement rails and issuers with deep liquidity and compliance capabilities. API aggregators and consumer apps face increasing competition from fintech players and commoditisation. Dragonfly invests in startups that offer direct bank partnerships, global coverage and high‑level compliance, rather than simple API wrappers.
  • Perspective on the payment shift: Hadick views the shift to stablecoin payments as a “gold rush”. He believes we are only at the beginning: cross‑border volumes are growing 20–30 % month‑over‑month and new regulations in the U.S. and abroad have legitimised stablecoins. He argues that stablecoins will eventually replace legacy payment rails, enabling instant, low‑cost, programmable transfers for SMEs, contractors and global trade. He cautions that winners will be those who navigate regulation, build deep integrations with banks and abstract away blockchain complexity.

Conclusion: Alignments and differences

  • Shared belief in stablecoins’ potential: Ardoino, Cascarilla and Hadick agree that stablecoins will drive a trillion‑dollar shift in payments. All three highlight growing adoption in cross‑border remittances and B2B transactions and see emerging markets as early adopters.
  • Different emphases: Ardoino focuses on financial inclusion and grassroots adoption, portraying USDT as a dollar substitute for the unbanked and emphasising Tether’s reserves and infrastructure projects. Cascarilla frames stablecoins as a national strategic imperative and stresses the need for robust regulation, reciprocity and private‑sector leadership to preserve the dollar’s dominance. Hadick takes the venture investor’s view, emphasising disruption of legacy payment rails, the growth of B2B transactions, and the importance of orchestration layers and last‑mile compliance.
  • Regulation as catalyst: All three consider clear regulation—especially the GENIUS Act—essential for scaling stablecoins. Ardoino and Cascarilla advocate reciprocal recognition to allow offshore stablecoins to circulate internationally, while Hadick sees regulation enabling a wave of startups.
  • Outlook: The stablecoin market is still in its early phases. With transaction volumes already in the trillions and use cases expanding beyond trading into remittances, treasury management and retail payments, the “book is just beginning to be written.” The perspectives of Ardoino, Cascarilla and Hadick illustrate how stablecoins could transform payments—from providing a digital dollar for billions of unbanked people to enabling businesses to bypass legacy rails—if regulators, issuers and innovators can build trust, scalability and interoperability.

Google’s Agent Payments Protocol (AP2)

· 34 min read
Dora Noda
Software Engineer

Google’s Agent Payments Protocol (AP2) is a newly announced open standard designed to enable secure, trustworthy transactions initiated by AI agents on behalf of users. Developed in collaboration with over 60 payments and technology organizations (including major payment networks, banks, fintechs, and Web3 companies), AP2 establishes a common language for “agentic” payments – i.e. purchases and financial transactions that an autonomous agent (such as an AI assistant or LLM-based agent) can carry out for a user. AP2’s creation is driven by a fundamental shift: traditionally, online payment systems assumed a human is directly clicking “buy,” but the rise of AI agents acting on user instructions breaks this assumption. AP2 addresses the resulting challenges of authorization, authenticity, and accountability in AI-driven commerce, while remaining compatible with existing payment infrastructure. This report examines AP2’s technical architecture, purpose and use cases, integrations with AI agents and payment providers, security and compliance considerations, comparisons to existing protocols, implications for Web3/decentralized systems, and the industry adoption/roadmap.

Technical Architecture: How AP2 Works

At its core, AP2 introduces a cryptographically secure transaction framework built on verifiable digital credentials (VDCs) – essentially tamper-proof, signed data objects that serve as digital “contracts” of what the user has authorized. In AP2 terminology these contracts are called Mandates, and they form an auditable chain of evidence for each transaction. There are three primary types of mandates in the AP2 architecture:

  • Intent Mandate: Captures the user’s initial instructions or conditions for a purchase, especially for “human-not-present” scenarios (where the agent will act later without the user online). It defines the scope of authority the user gives the agent – for example, “Buy concert tickets if they drop below $200, up to 2 tickets”. This mandate is cryptographically signed upfront by the user and serves as verifiable proof of consent within specific limits.
  • Cart Mandate: Represents the final transaction details that the user has approved, used in “human-present” scenarios or at the moment of checkout. It includes the exact items or services, their price, and other particulars of the purchase. When the agent is ready to complete the transaction (e.g. after filling a shopping cart), the merchant first cryptographically signs the cart contents (guaranteeing the order details and price), and then the user (via their device or agent interface) signs off to create a Cart Mandate. This ensures what-you-see-is-what-you-pay, locking in the final order exactly as presented to the user.
  • Payment Mandate: A separate credential that is sent to the payment network (e.g. card network or bank) to signal that an AI agent is involved in the transaction. The Payment Mandate includes metadata such as whether the user was present or not during authorization and serves as a flag for risk management systems. By providing the acquiring and issuing banks with cryptographically verifiable evidence of user intent, this mandate helps them assess the context (for example, distinguishing an agent-initiated purchase from typical fraud) and manage compliance or liability accordingly.

All mandates are implemented as verifiable credentials signed by the relevant party’s keys (user, merchant, etc.), yielding a non-repudiable audit trail for every agent-led transaction. In practice, AP2 uses a role-based architecture to protect sensitive information – for instance, an agent might handle an Intent Mandate without ever seeing raw payment details, which are only revealed in a controlled way when needed, preserving privacy. The cryptographic chain of user intent → merchant commitment → payment authorization establishes trust among all parties that the transaction reflects the user’s true instructions and that both the agent and merchant adhered to those instructions.

Transaction Flow: To illustrate how AP2 works end-to-end, consider a simple purchase scenario with a human in the loop:

  1. User Request: The user asks their AI agent to purchase a particular item or service (e.g. “Order this pair of shoes in my size”).
  2. Cart Construction: The agent communicates with the merchant’s systems (using standard APIs or via an agent-to-agent interaction) to assemble a shopping cart for the specified item at a given price.
  3. Merchant Guarantee: Before presenting the cart to the user, the merchant’s side cryptographically signs the cart details (item, quantity, price, etc.). This step creates a merchant-signed offer that guarantees the exact terms (preventing any hidden changes or price manipulation).
  4. User Approval: The agent shows the user the finalized cart. The user confirms the purchase, and this approval triggers two cryptographic signatures from the user’s side: one on the Cart Mandate (to accept the merchant’s cart as-is) and one on the Payment Mandate (to authorize payment through the chosen payment provider). These signed mandates are then shared with the merchant and the payment network respectively.
  5. Execution: Armed with the Cart Mandate and Payment Mandate, the merchant and payment provider proceed to execute the transaction securely. For example, the merchant submits the payment request along with the proof of user approval to the payment network (card network, bank, etc.), which can verify the Payment Mandate. The result is a completed purchase transaction with a cryptographic audit trail linking the user’s intent to the final payment.

This flow demonstrates how AP2 builds trust into each step of an AI-driven purchase. The merchant has cryptographic proof of exactly what the user agreed to buy at what price, and the issuer/bank has proof that the user authorized that payment, even though an AI agent facilitated the process. In case of disputes or errors, the signed mandates act as clear evidence, helping determine accountability (e.g. if the agent deviated from instructions or if a charge was not what the user approved). In essence, AP2’s architecture ensures that verifiable user intent – rather than trust in the agent’s behavior – is the basis of the transaction, greatly reducing ambiguity.

Purpose and Use Cases for AP2

Why AP2 is Needed: The primary purpose of AP2 is to solve emerging trust and security issues that arise when AI agents can spend money on behalf of users. Google and its partners identified several key questions that today’s payment infrastructure cannot adequately answer when an autonomous agent is in the loop:

  • Authorization: How to prove that a user actually gave the agent permission to make a specific purchase? (In other words, ensuring the agent isn’t buying things without the user’s informed consent.)
  • Authenticity: How can a merchant know that an agent’s purchase request is genuine and reflects the user’s true intent, rather than a mistake or AI hallucination?
  • Accountability: If a fraudulent or incorrect transaction occurs via an agent, who is responsible – the user, the merchant, the payment provider, or the creator of the AI agent?

Without a solution, these uncertainties create a “crisis of trust” around agent-led commerce. AP2’s mission is to provide that solution by establishing a uniform protocol for secure agent transactions. By introducing standardized mandates and proofs of intent, AP2 prevents a fragmented ecosystem of each company inventing its own ad-hoc agent payment methods. Instead, any compliant AI agent can interact with any compliant merchant/payment provider under a common set of rules and verifications. This consistency not only avoids user and merchant confusion, but also gives financial institutions a clear way to manage risk for agent-initiated payments, rather than dealing with a patchwork of proprietary approaches. In short, AP2’s purpose is to be a foundational trust layer that lets the “agent economy” grow without breaking the payments ecosystem.

Intended Use Cases: By solving the above issues, AP2 opens the door to new commerce experiences and use cases that go beyond what’s possible with a human manually clicking through purchases. Some examples of agent-enabled commerce that AP2 supports include:

  • Smarter Shopping: A customer can instruct their agent, “I want this winter jacket in green, and I’m willing to pay up to 20% above the current price for it”. Armed with an Intent Mandate encoding these conditions, the agent will continuously monitor retailer websites or databases. The moment the jacket becomes available in green (and within the price threshold), the agent automatically executes a purchase with a secure, signed transaction – capturing a sale that otherwise would have been missed. The entire interaction, from the user’s initial request to the automated checkout, is governed by AP2 mandates ensuring the agent only buys exactly what was authorized.
  • Personalized Offers: A user tells their agent they’re looking for a specific product (say, a new bicycle) from a particular merchant for an upcoming trip. The agent can share this interest (within the bounds of an Intent Mandate) with the merchant’s own AI agent, including relevant context like the trip date. The merchant agent, knowing the user’s intent and context, could respond with a custom bundle or discount – for example, “bicycle + helmet + travel rack at 15% off, available for the next 48 hours.” Using AP2, the user’s agent can accept and complete this tailored offer securely, turning a simple query into a more valuable sale for the merchant.
  • Coordinated Tasks: A user planning a complex task (e.g. a weekend trip) delegates it entirely: “Book me a flight and hotel for these dates with a total budget of $700.” The agent can interact with multiple service providers’ agents – airlines, hotels, travel platforms – to find a combination that fits the budget. Once a suitable flight-hotel package is identified, the agent uses AP2 to execute multiple bookings in one go, each cryptographically signed (for example, issuing separate Cart Mandates for the airline and the hotel, both authorized under the user’s Intent Mandate). AP2 ensures all parts of this coordinated transaction occur as approved, and even allows simultaneous execution so that tickets and reservations are booked together without risk of one part failing mid-way.

These scenarios illustrate just a few of AP2’s intended use cases. More broadly, AP2’s flexible design supports both conventional e-commerce flows and entirely new models of commerce. For instance, AP2 can facilitate subscription-like services (an agent keeps you stocked on essentials by purchasing when conditions are met), event-driven purchases (buying tickets or items the instant a trigger event occurs), group agent negotiations (multiple users’ agents pooling mandates to bargain for a group deal), and many other emerging patterns. In every case, the common thread is that AP2 provides the trust framework – clear user authorization and cryptographic auditability – that allows these agent-driven transactions to happen safely. By handling the trust and verification layer, AP2 lets developers and businesses focus on innovating new AI commerce experiences without re-inventing payment security from scratch.

Integration with Agents, LLMs, and Payment Providers

AP2 is explicitly designed to integrate seamlessly with AI agent frameworks and with existing payment systems, acting as a bridge between the two. Google has positioned AP2 as an extension of its Agent2Agent (A2A) protocol and Model Context Protocol (MCP) standards. In other words, if A2A provides a generic language for agents to communicate tasks and MCP standardizes how AI models incorporate context/tools, then AP2 adds a transactions layer on top for commerce. The protocols are complementary: A2A handles agent-to-agent communication (allowing, say, a shopping agent to talk to a merchant’s agent), while AP2 handles agent-to-merchant payment authorization within those interactions. Because AP2 is open and non-proprietary, it’s meant to be framework-agnostic: developers can use it with Google’s own Agent Development Kit (ADK) or any AI agent library, and likewise it can work with various AI models including LLMs. An LLM-based agent, for example, could use AP2 by generating and exchanging the required mandate payloads (guided by the AP2 spec) instead of just free-form text. By enforcing a structured protocol, AP2 helps transform an AI agent’s high-level intent (which might come from an LLM’s reasoning) into concrete, secure transactions.

On the payments side, AP2 was built in concert with traditional payment providers and standards, rather than as a rip-and-replace system. The protocol is payment-method-agnostic, meaning it can support a variety of payment rails – from credit/debit card networks to bank transfers and digital wallets – as the underlying method for moving funds. In its initial version, AP2 emphasizes compatibility with card payments, since those are most common in online commerce. The AP2 Payment Mandate is designed to plug into the existing card processing flow: it provides additional data to the payment network (e.g. Visa, Mastercard, Amex) and issuing bank that an AI agent is involved and whether the user was present, thereby complementing existing fraud detection and authorization checks. Essentially, AP2 doesn’t process the payment itself; it augments the payment request with cryptographic proof of user intent. This allows payment providers to treat agent-initiated transactions with appropriate caution or speed (for example, an issuer might approve an unusual-looking purchase if it sees a valid AP2 mandate proving the user pre-approved it). Notably, Google and partners plan to evolve AP2 to support “push” payment methods as well – such as real-time bank transfers (like India’s UPI or Brazil’s PIX systems) – and other emerging digital payment types. This indicates AP2’s integration will expand beyond cards, aligning with modern payment trends worldwide.

For merchants and payment processors, integrating AP2 would mean supporting the additional protocol messages (mandates) and verifying signatures. Many large payment platforms are already involved in shaping AP2, so we can expect they will build support for it. For example, companies like Adyen, Worldpay, Paypal, Stripe (not explicitly named in the blog but likely interested), and others could incorporate AP2 into their checkout APIs or SDKs, allowing an agent to initiate a payment in a standardized way. Because AP2 is an open specification on GitHub with reference implementations, payment providers and tech platforms can start experimenting with it immediately. Google has also mentioned an AI Agent Marketplace where third-party agents can be listed – these agents are expected to support AP2 for any transactional capabilities. In practice, an enterprise that builds an AI sales assistant or procurement agent could list it on this marketplace, and thanks to AP2, that agent can carry out purchases or orders reliably.

Finally, AP2’s integration story benefits from its broad industry backing. By co-developing the protocol with major financial institutions and tech firms, Google ensured AP2 aligns with existing industry rules and compliance requirements. The collaboration with payment networks (e.g. Mastercard, UnionPay), issuers (e.g. American Express), fintechs (e.g. Revolut, Paypal), e-commerce players (e.g. Etsy), and even identity/security providers (e.g. Okta, Cloudflare) suggests AP2 is being designed to slot into real-world systems with minimal friction. These stakeholders bring expertise in areas like KYC (Know Your Customer regulations), fraud prevention, and data privacy, helping AP2 address those needs out of the box. In summary, AP2 is built to be agent-friendly and payment-provider-friendly: it extends existing AI agent protocols to handle transactions, and it layers on top of existing payment networks to utilize their infrastructure while adding necessary trust guarantees.

Security, Compliance, and Interoperability Considerations

Security and trust are at the heart of AP2’s design. The protocol’s use of cryptography (digital signatures on mandates) ensures that every critical action in an agentic transaction is verifiable and traceable. This non-repudiation is crucial: neither the user nor merchant can later deny what was authorized and agreed upon, since the mandates serve as secure records. A direct benefit is in fraud prevention and dispute resolution – with AP2, if a malicious or buggy agent attempts an unauthorized purchase, the lack of a valid user-signed mandate would be evident, and the transaction can be declined or reversed. Conversely, if a user claims “I never approved this purchase,” but a Cart Mandate exists with their cryptographic signature, the merchant and issuer have strong evidence to support the charge. This clarity of accountability answers a major compliance concern for the payments industry.

Authorization & Privacy: AP2 enforces an explicit authorization step (or steps) from the user for agent-led transactions, which aligns with regulatory trends like strong customer authentication. The User Control principle baked into AP2 means an agent cannot spend funds unless the user (or someone delegated by the user) has provided a verifiable instruction to do so. Even in fully autonomous scenarios, the user predefines the rules via an Intent Mandate. This approach can be seen as analogous to giving a power-of-attorney to the agent for specific transactions, but in a digitally signed, fine-grained manner. From a privacy perspective, AP2 is mindful about data sharing: the protocol uses a role-based data architecture to ensure that sensitive info (like payment credentials or personal details) is only shared with parties that absolutely need it. For example, an agent might send a Cart Mandate to a merchant containing item and price info, but the user’s actual card number might only be shared through the Payment Mandate with the payment processor, not with the agent or merchant. This minimizes unnecessary exposure of data, aiding compliance with privacy laws and PCI-DSS rules for handling payment data.

Compliance & Standards: Because AP2 was developed with input from established financial entities, it has been designed to meet or complement existing compliance standards in payments. The protocol doesn’t bypass the usual payment authorization flows – instead, it augments them with additional evidence and flags. This means AP2 transactions can still leverage fraud detection systems, 3-D Secure checks, or any regulatory checks required, with AP2’s mandates acting as extra authentication factors or context cues. For instance, a bank could treat a Payment Mandate akin to a customer’s digital signature on a transaction, potentially streamlining compliance with requirements for user consent. Additionally, AP2’s designers explicitly mention working “in concert with industry rules and standards”. We can infer that as AP2 evolves, it may be brought to formal standards bodies (such as the W3C, EMVCo, or ISO) to ensure it aligns with global financial standards. Google has stated commitment to an open, collaborative evolution of AP2 possibly through standards organizations. This open process will help iron out any regulatory concerns and achieve broad acceptance, similar to how previous payment standards (EMV chip cards, 3-D Secure, etc.) underwent industry-wide collaboration.

Interoperability: Avoiding fragmentation is a key goal of AP2. To that end, the protocol is openly published and made available for anyone to implement or integrate. It is not tied to Google Cloud services – in fact, AP2 is open-source (Apache-2 licensed) and the specification plus reference code is on a public GitHub repository. This encourages interoperability because multiple vendors can adopt AP2 and still have their systems work together. Already, the interoperability principle is highlighted: AP2 is an extension of existing open protocols (A2A, MCP) and is non-proprietary, meaning it fosters a competitive ecosystem of implementations rather than a single-vendor solution. In practical terms, an AI agent built by Company A could initiate a transaction with a merchant system from Company B if both follow AP2 – neither side is locked into one platform.

One possible concern is ensuring consistent adoption: if some major players chose a different protocol or closed approach, fragmentation could still occur. However, given the broad coalition behind AP2, it appears poised to become a de facto standard. The inclusion of many identity and security-focused firms (for example, Okta, Cloudflare, Ping Identity) in the AP2 ecosystem Figure: Over 60 companies across finance, tech, and crypto are collaborating on AP2 (partial list of partners). suggests that interoperability and security are being jointly addressed. These partners can help integrate AP2 into identity verification workflows and fraud prevention tools, ensuring that an AP2 transaction can be trusted across systems.

From a technology standpoint, AP2’s use of widely accepted cryptographic techniques (likely JSON-LD or JWT-based verifiable credentials, public key signatures, etc.) makes it compatible with existing security infrastructure. Organizations can use their existing PKI (Public Key Infrastructure) to manage keys for signing mandates. AP2 also seems to anticipate integration with decentralized identity systems: Google mentions that AP2 creates opportunities to innovate in areas like decentralized identity for agent authorization. This means in the future, AP2 could leverage DID (Decentralized Identifier) standards or decentralized identifier verification for identifying agents and users in a trusted way. Such an approach would further enhance interoperability by not relying on any single identity provider. In summary, AP2 emphasizes security through cryptography and clear accountability, aims to be compliance-ready by design, and promotes interoperability through its open standard nature and broad industry support.

Comparison with Existing Protocols

AP2 is a novel protocol addressing a gap that existing payment and agent frameworks have not covered: enabling autonomous agents to perform payments in a secure, standardized manner. In terms of agent communication protocols, AP2 builds on prior work like the Agent2Agent (A2A) protocol. A2A (open-sourced earlier in 2025) allows different AI agents to talk to each other regardless of their underlying frameworks. However, A2A by itself doesn’t define how agents should conduct transactions or payments – it’s more about task negotiation and data exchange. AP2 extends this landscape by adding a transaction layer that any agent can use when a conversation leads to a purchase. In essence, AP2 can be seen as complementary to A2A and MCP, rather than overlapping: A2A covers the communication and collaboration aspects, MCP covers using external tools/APIs, and AP2 covers payments and commerce. Together, they form a stack of standards for a future “agent economy.” This modular approach is somewhat analogous to internet protocols: for example, HTTP for data communication and SSL/TLS for security – here A2A might be like the HTTP of agents, and AP2 the secure transactional layer on top for commerce.

When comparing AP2 to traditional payment protocols and standards, there are both parallels and differences. Traditional online payments (credit card checkouts, PayPal transactions, etc.) typically involve protocols like HTTPS for secure transmission, and standards like PCI DSS for handling card data, plus possibly 3-D Secure for additional user authentication. These assume a user-driven flow (user clicks and perhaps enters a one-time code). AP2, by contrast, introduces a way for a third-party (the agent) to participate in the flow without undermining security. One could compare AP2’s mandate concept to an extension of OAuth-style delegated authority, but applied to payments. In OAuth, a user can grant an application limited access to an account via tokens; similarly in AP2, a user grants an agent authority to spend under certain conditions via mandates. The key difference is that AP2’s “tokens” (mandates) are specific, signed instructions for financial transactions, which is more fine-grained than existing payment authorizations.

Another point of comparison is how AP2 relates to existing e-commerce checkout flows. For instance, many e-commerce sites use protocols like the W3C Payment Request API or platform-specific SDKs to streamline payments. Those mainly standardize how browsers or apps collect payment info from a user, whereas AP2 standardizes how an agent would prove user intent to a merchant and payment processor. AP2’s focus on verifiable intent and non-repudiation sets it apart from simpler payment APIs. It’s adding an additional layer of trust on top of the payment networks. One could say AP2 is not replacing the payment networks (Visa, ACH, blockchain, etc.), but rather augmenting them. The protocol explicitly supports all types of payment methods (even crypto), so it is more about standardizing the agent’s interaction with these systems, not creating a new payment rail from scratch.

In the realm of security and authentication protocols, AP2 shares some spirit with things like digital signatures in EMV chip cards or the notarization in digital contracts. For example, EMV chip card transactions generate cryptograms to prove the card was present; AP2 generates cryptographic proof that the user’s agent was authorized. Both aim to prevent fraud, but AP2’s scope is the agent-user relationship and agent-merchant messaging, which no existing payment standard addresses. Another emerging comparison is with account abstraction in crypto (e.g. ERC-4337) where users can authorize pre-programmed wallet actions. Crypto wallets can be set to allow certain automated transactions (like auto-paying a subscription via a smart contract), but those are typically confined to one blockchain environment. AP2, on the other hand, aims to be cross-platform – it can leverage blockchain for some payments (through its extensions) but also works with traditional banks.

There isn’t a direct “competitor” protocol to AP2 in the mainstream payments industry yet – it appears to be the first concerted effort at an open standard for AI-agent payments. Proprietary attempts may arise (or may already be in progress within individual companies), but AP2’s broad support gives it an edge in becoming the standard. It’s worth noting that IBM and others have an Agent Communication Protocol (ACP) and similar initiatives for agent interoperability, but those don’t encompass the payment aspect in the comprehensive way AP2 does. If anything, AP2 might integrate with or leverage those efforts (for example, IBM’s agent frameworks could implement AP2 for any commerce tasks).

In summary, AP2 distinguishes itself by targeting the unique intersection of AI and payments: where older payment protocols assumed a human user, AP2 assumes an AI intermediary and fills the trust gap that results. It extends, rather than conflicts with, existing payment processes, and complements existing agent protocols like A2A. Going forward, one might see AP2 being used alongside established standards – for instance, an AP2 Cart Mandate might work in tandem with a traditional payment gateway API call, or an AP2 Payment Mandate might be attached to a ISO 8583 message in banking. The open nature of AP2 also means if any alternative approaches emerge, AP2 could potentially absorb or align with them through community collaboration. At this stage, AP2 is setting a baseline that did not exist before, effectively pioneering a new layer of protocol in the AI and payments stack.

Implications for Web3 and Decentralized Systems

From the outset, AP2 has been designed to be inclusive of Web3 and cryptocurrency-based payments. The protocol recognizes that future commerce will span both traditional fiat channels and decentralized blockchain networks. As noted earlier, AP2 supports payment types ranging from credit cards and bank transfers to stablecoins and cryptocurrencies. In fact, alongside AP2’s launch, Google announced a specific extension for crypto payments called A2A x402. This extension, developed in collaboration with crypto-industry players like Coinbase, the Ethereum Foundation, and MetaMask, is a “production-ready solution for agent-based crypto payments”. The name “x402” is an homage to the HTTP 402 “Payment Required” status code, which was never widely used on the Web – AP2’s crypto extension effectively revives the spirit of HTTP 402 for decentralized agents that want to charge or pay each other on-chain. In practical terms, the x402 extension adapts AP2’s mandate concept to blockchain transactions. For example, an agent could hold a signed Intent Mandate from a user and then execute an on-chain payment (say, send a stablecoin) once conditions are met, attaching proof of the mandate to that on-chain transaction. This marries the AP2 off-chain trust framework with the trustless nature of blockchain, giving the best of both worlds: an on-chain payment that off-chain parties (users, merchants) can trust was authorized by the user.

The synergy between AP2 and Web3 is evident in the list of collaborators. Crypto exchanges (Coinbase), blockchain foundations (Ethereum Foundation), crypto wallets (MetaMask), and Web3 startups (e.g. Mysten Labs of Sui, Lightspark for Lightning Network) are involved in AP2’s development. Their participation suggests AP2 is viewed as complementary to decentralized finance rather than competitive. By creating a standard way for AI agents to interact with crypto payments, AP2 could drive more usage of crypto in AI-driven applications. For instance, an AI agent might use AP2 to seamlessly swap between paying with a credit card or paying with a stablecoin, depending on user preference or merchant acceptance. The A2A x402 extension specifically allows agents to monetize or pay for services through on-chain means, which could be crucial in decentralized marketplaces of the future. It hints at agents possibly running as autonomous economic actors on blockchain (a concept some refer to as DACs or DAOs) being able to handle payments required for services (like paying a small fee to another agent for information). AP2 could provide the lingua franca for such transactions, ensuring even on a decentralized network, the agent has a provable mandate for what it’s doing.

In terms of competition, one could ask: do purely decentralized solutions make AP2 unnecessary, or vice-versa? It’s likely that AP2 will coexist with Web3 solutions in a layered approach. Decentralized finance offers trustless execution (smart contracts, etc.), but it doesn’t inherently solve the problem of “Did an AI have permission from a human to do this?”. AP2 addresses that very human-to-AI trust link, which remains important even if the payment itself is on-chain. Rather than competing with blockchain protocols, AP2 can be seen as bridging them with the off-chain world. For example, a smart contract might accept a certain transaction only if it includes a reference to a valid AP2 mandate signature – something that could be implemented to combine off-chain intent proof with on-chain enforcement. Conversely, if there are crypto-native agent frameworks (some blockchain projects explore autonomous agents that operate with crypto funds), they might develop their own methods for authorization. AP2’s broad industry support, however, might steer even those projects to adopt or integrate with AP2 for consistency.

Another angle is decentralized identity and credentials. AP2’s use of verifiable credentials is very much in line with Web3’s approach to identity (e.g. DIDs and VCs as standardized by W3C). This means AP2 could plug into decentralized identity systems – for instance, a user’s DID could be used to sign an AP2 mandate, which a merchant could verify against a blockchain or identity hub. The mention of exploring decentralized identity for agent authorization reinforces that AP2 may leverage Web3 identity innovations for verifying agent and user identities in a decentralized way, rather than relying only on centralized authorities. This is a point of synergy, as both AP2 and Web3 aim to give users more control and cryptographic proof of their actions.

Potential conflicts might arise only if one envisions a fully decentralized commerce ecosystem with no role for large intermediaries – in that scenario, could AP2 (initially pushed by Google and partners) be too centralized or governed by traditional players? It’s important to note AP2 is open source and intended to be standardizable, so it’s not proprietary to Google. This makes it more palatable to the Web3 community, which values open protocols. If AP2 becomes widely adopted, it might reduce the need for separate Web3-specific payment protocols for agents, thereby unifying efforts. On the other hand, some blockchain projects might prefer purely on-chain authorization mechanisms (like multi-signature wallets or on-chain escrow logic) for agent transactions, especially in trustless environments without any centralized authorities. Those could be seen as alternative approaches, but they likely would remain niche unless they can interact with off-chain systems. AP2, by covering both worlds, might actually accelerate Web3 adoption by making crypto just another payment method an AI agent can use seamlessly. Indeed, one partner noted that “stablecoins provide an obvious solution to scaling challenges [for] agentic systems with legacy infrastructure”, highlighting that crypto can complement AP2 in handling scale or cross-border scenarios. Meanwhile, Coinbase’s engineering lead remarked that bringing the x402 crypto extension into AP2 “made sense – it’s a natural playground for agents... exciting to see agents paying each other resonate with the AI community”. This implies a vision where AI agents transacting via crypto networks is not just a theoretical idea but an expected outcome, with AP2 acting as a catalyst.

In summary, AP2 is highly relevant to Web3: it incorporates crypto payments as a first-class citizen and is aligning with decentralized identity and credential standards. Rather than competing head-on with decentralized payment protocols, AP2 likely interoperates with them – providing the authorization layer while the decentralized systems handle the value transfer. As the line between traditional finance and crypto blurs (with stablecoins, CBDCs, etc.), a unified protocol like AP2 could serve as a universal adapter between AI agents and any form of money, centralized or decentralized.

Industry Adoption, Partnerships, and Roadmap

One of AP2’s greatest strengths is the extensive industry backing behind it, even at this early stage. Google Cloud announced that it is “collaborating with a diverse group of more than 60 organizations” on AP2. These include major credit card networks (e.g. Mastercard, American Express, JCB, UnionPay), leading fintech and payment processors (PayPal, Worldpay, Adyen, Checkout.com, Stripe’s competitors), e-commerce and online marketplaces (Etsy, Shopify (via partners like Stripe or others), Lazada, Zalora), enterprise tech companies (Salesforce, ServiceNow, Oracle possibly via partners, Dell, Red Hat), identity and security firms (Okta, Ping Identity, Cloudflare), consulting firms (Deloitte, Accenture), and crypto/Web3 organizations (Coinbase, Ethereum Foundation, MetaMask, Mysten Labs, Lightspark), among others. Such a wide array of participants is a strong indicator of industry interest and likely adoption. Many of these partners have publicly voiced support. For example, Adyen’s Co-CEO highlighted the need for a “common rulebook” for agentic commerce and sees AP2 as a natural extension of their mission to support merchants with new payment building blocks. American Express’s EVP stated that AP2 is important for “the next generation of digital payments” where trust and accountability are paramount. Coinbase’s team, as noted, is excited about integrating crypto payments into AP2. This chorus of support shows that many in the industry view AP2 as the likely standard for AI-driven payments, and they are keen to shape it to ensure it meets their requirements.

From an adoption standpoint, AP2 is currently at the specification and early implementation stage (announced in September 2025). The complete technical spec, documentation, and some reference implementations (in languages like Python) are available on the project’s GitHub for developers to experiment with. Google has also indicated that AP2 will be incorporated into its products and services for agents. A notable example is the AI Agent Marketplace mentioned earlier: this is a platform where third-party AI agents can be offered to users (likely part of Google’s generative AI ecosystem). Google says many partners building agents will make them available in the marketplace with “new, transactable experiences enabled by AP2”. This implies that as the marketplace launches or grows, AP2 will be the backbone for any agent that needs to perform a transaction, whether it’s buying software from the Google Cloud Marketplace autonomously or an agent purchasing goods/services for a user. Enterprise use cases like autonomous procurement (one agent buying from another on behalf of a company) and automatic license scaling have been specifically mentioned as areas AP2 could facilitate soon.

In terms of a roadmap, the AP2 documentation and Google’s announcement give some clear indications:

  • Near-term: Continue open development of the protocol with community input. The GitHub repo will be updated with additional reference implementations and improvements as real-world testing happens. We can expect libraries/SDKs to emerge, making it easier to integrate AP2 into agent applications. Also, initial pilot programs or proofs-of-concept might be conducted by the partner companies. Given that many large payment companies are involved, they might trial AP2 in controlled environments (e.g., an AP2-enabled checkout option in a small user beta).
  • Standards and Governance: Google has expressed a commitment to move AP2 into an open governance model, possibly via standards bodies. This could mean submitting AP2 to organizations like the Linux Foundation (as was done with the A2A protocol) or forming a consortium to maintain it. The Linux Foundation, W3C, or even bodies like ISO/TC68 (financial services) might be in the cards for formalizing AP2. An open governance would reassure the industry that AP2 is not under single-company control and will remain neutral and inclusive.
  • Feature Expansion: Technically, the roadmap includes expanding support to more payment types and use cases. As noted in the spec, after cards, the focus will shift to “push” payments like bank wires and local real-time payment schemes, and digital currencies. This means AP2 will outline how an Intent/Cart/Payment Mandate works for, say, a direct bank transfer or a crypto wallet transfer, where the flow is a bit different than card pulls. The A2A x402 extension is one such expansion for crypto; similarly, we might see an extension for open banking APIs or one for B2B invoicing scenarios.
  • Security & Compliance Enhancements: As real transactions start flowing through AP2, there will be scrutiny from regulators and security researchers. The open process will likely iterate on making mandates even more robust (e.g., ensuring mandate formats are standardized, possibly using W3C Verifiable Credentials format, etc.). Integration with identity solutions (perhaps leveraging biometrics for user signing of mandates, or linking mandates to digital identity wallets) could be part of the roadmap to enhance trust.
  • Ecosystem Tools: An emerging ecosystem is likely. Already, startups are noticing gaps – for instance, the Vellum.ai analysis mentions a startup called Autumn building “billing infrastructure for AI,” essentially tooling on top of Stripe to handle complex pricing for AI services. As AP2 gains traction, we can expect more tools like agent-focused payment gateways, mandate management dashboards, agent identity verification services, etc., to appear. Google’s involvement means AP2 could also be integrated into its Cloud products – imagine AP2 support in Dialogflow or Vertex AI Agents tooling, making it one-click to enable an agent to handle transactions (with all the necessary keys and certificates managed in Google Cloud).

Overall, the trajectory of AP2 is reminiscent of other major industry standards: an initial launch with a strong sponsor (Google), broad industry coalition, open-source reference code, followed by iterative improvement and gradual adoption in real products. The fact that AP2 is inviting all players “to build this future with us” underscores that the roadmap is about collaboration. If the momentum continues, AP2 could become as commonplace in a few years as protocols like OAuth or OpenID Connect are today in their domains – an unseen but critical layer enabling functionality across services.

Conclusion

AP2 (Agents/Agent Payments Protocol) represents a significant step toward a future where AI agents can transact as reliably and securely as humans. Technically, it introduces a clever mechanism of verifiable mandates and credentials that instill trust in agent-led transactions, ensuring user intent is explicit and enforceable. Its open, extensible architecture allows it to integrate both with the burgeoning AI agent frameworks and the established financial infrastructure. By addressing core concerns of authorization, authenticity, and accountability, AP2 lays the groundwork for AI-driven commerce to flourish without sacrificing security or user control.

The introduction of AP2 can be seen as laying a new foundation – much like early internet protocols enabled the web – for what some call the “agent economy.” It paves the way for countless innovations: personal shopper agents, automatic deal-finding bots, autonomous supply chain agents, and more, all operating under a common trust framework. Importantly, AP2’s inclusive design (embracing everything from credit cards to crypto) positions it at the intersection of traditional finance and Web3, potentially bridging these worlds through a common agent-mediated protocol.

Industry response so far has been very positive, with a broad coalition signaling that AP2 is likely to become a widely adopted standard. The success of AP2 will depend on continued collaboration and real-world testing, but its prospects are strong given the clear need it addresses. In a broader sense, AP2 exemplifies how technology evolves: a new capability (AI agents) emerged that broke old assumptions, and the solution was to develop a new open standard to accommodate that capability. By investing in an open, security-first protocol now, Google and its partners are effectively building the trust architecture required for the next era of commerce. As the saying goes, “the best way to predict the future is to build it” – AP2 is a bet on a future where AI agents seamlessly handle transactions for us, and it is actively constructing the trust and rules needed to make that future viable.

Sources:

  • Google Cloud Blog – “Powering AI commerce with the new Agent Payments Protocol (AP2)” (Sept 16, 2025)
  • AP2 GitHub Documentation – “Agent Payments Protocol Specification and Overview”
  • Vellum AI Blog – “Google’s AP2: A new protocol for AI agent payments” (Analysis)
  • Medium Article – “Google Agent Payments Protocol (AP2)” (Summary by Tahir, Sept 2025)
  • Partner Quotes on AP2 (Google Cloud Blog)
  • A2A x402 Extension (AP2 crypto payments extension) – GitHub README

The GENIUS Act: Transforming the Stablecoin Landscape

· 9 min read
Dora Noda
Software Engineer

The clock is ticking on the most significant regulatory transformation in stablecoin history. As federal agencies race to finalize rules before the July 18, 2026 deadline, the GENIUS Act is reshaping how banks, crypto firms, and fintech companies operate in the $312 billion stablecoin market. The question isn't whether stablecoins will become regulated—it's whether your organization is ready for what's coming.

OKX Pay’s Vision: From Stablecoin Liquidity to Everyday Payments

· 5 min read
Dora Noda
Software Engineer

Here’s a concise, sourced brief on OKX Pay’s vision as it’s being signaled by Scotty James (ambassador), Sam Liu (Product Lead, OKX Pay), and Haider Rafique (Managing Partner & CMO).

TL;DR

  • Make on‑chain payments everyday‑useful. OKX Pay launched in Singapore, letting users scan GrabPay SGQR codes and pay with USDC/USDT while merchants still settle in SGD—a practical bridge between crypto and real‑world spending.
  • Unify stablecoin liquidity. OKX is building a Unified USD Order Book so compliant stablecoins share one market and deeper liquidity—framing OKX Pay as part of a broader “stablecoin liquidity center” strategy.
  • Scale acceptance via cards/rails. With Mastercard, OKX is introducing the OKX Card to extend stablecoin spending to mainstream merchant networks, positioned as “making digital finance more accessible, practical, and relevant to everyday life.”

What each person is emphasizing

1) Scotty James — Mainstream accessibility & culture

  • Role: OKX ambassador who co‑hosts conversations on the future of payments with OKX product leaders at TOKEN2049 (e.g., sessions with Sam Liu), helping translate the product story for a broader audience.
  • Context: He frequently fronts OKX stage moments and brand storytelling (e.g., TOKEN2049 fireside chats), underscoring the push to make crypto feel simple and everyday, not just technical.

Note: Scotty James is an ambassador rather than a product owner; his contribution is narrative and adoption‑focused, not the technical roadmap.

2) Sam Liu — Product architecture & fairness

  • Vision points he’s put forward publicly:
    • Fix stablecoin fragmentation with a Unified USD Order Book so “every compliant issuer can equally access liquidity”—principles of fairness and openness that directly support reliable, low‑spread payments.
    • Payments form factors: QR code payments now; Tap‑to‑Pay and the OKX Card coming in stages to extend acceptance.
  • Supporting infrastructure: the Unified USD Order Book is live (USD, USDC, USDG in one book), designed to simplify the user experience and deepen liquidity for spend‑use cases.

3) Haider Rafique — Go‑to‑market & everyday utility

  • Positioning: OKX Pay (and the Mastercard partnership) is framed as taking crypto from trading to everyday life:

    “Our strategic partnership with Mastercard to launch the OKX Card reflects our commitment to making digital finance more accessible, practical, and relevant to everyday life.” — Haider Rafique, CMO, in Mastercard’s press release.

  • Event leadership: At OKX’s Alphas Summit (on the eve of TOKEN2049), Haider joined CEO Star Xu and the SG CEO to discuss on‑chain payments and the OKX Pay rollout, highlighting the near‑term focus on Singapore and stablecoin payments that feel like normal checkout flows.

What’s already live (concrete facts)

  • Singapore launch (Sep 30, 2025):
    • Users in Singapore can scan GrabPay SGQR codes with the OKX app and pay using USDT or USDC (on X Layer); merchants still receive SGD. Collaboration with Grab and StraitsX handles the conversion.
    • Reuters corroborates the launch and flow: USDT/USDC → XSGD conversion → merchant receives SGD.
    • Scope details: Support is for GrabPay/SGQR codes presented by GrabPay merchants; PayNow QR is not supported yet (useful nuance when discussing QR coverage).

The near‑term arc of the vision

  1. Everyday, on‑chain spend
    • Start where payments are already ubiquitous (Singapore’s SGQR/GrabPay network), then expand acceptance via payment cards and new form factors (e.g., Tap‑to‑Pay).
  2. Stablecoin liquidity as a platform advantage
    • Collapse splintered stablecoin pairs into one Unified USD Order Book to deliver deeper liquidity and tighter spreads, improving both trading and payments.
  3. Global merchant acceptance via card rails
    • The OKX Card with Mastercard is the scale lever—extend stablecoin spending to everyday merchants through mainstream acceptance networks.
  4. Low fees and speed on L2
    • Use X Layer so consumer payments feel fast/cheap while staying on‑chain. (Singapore’s “scan‑to‑pay” specifically uses USDT/USDC on X Layer held in your Pay account.)
  5. Regulatory alignment where you launch
    • Singapore focus is underpinned by licensing progress and local rails (e.g., MAS licences; prior SGD connectivity via PayNow/FAST for exchange services), which helps position OKX Pay as compliant infrastructure rather than a workaround.

Related but separate: some coverage describes “self‑custody OKX Pay” with passkeys/MPC and “silent rewards” on deposits; treat that as the global product direction (wallet‑led), distinct from OKX SG’s regulated scan‑to‑pay implementation.

Why this is different

  • Consumer‑grade UX first: Scan a familiar QR, merchant still sees fiat settlement; no “crypto gymnastics” at checkout.
  • Liquidity + acceptance together: Payments work best when liquidity (stablecoins) and acceptance (QR + card rails) land together—hence Unified USD Order Book plus Mastercard/Grab partnerships.
  • Clear sequencing: Prove utility in a QR‑heavy market (Singapore), then scale out with cards/Tap‑to‑Pay.

Open questions to watch

  • Custody model by region: How much of OKX Pay’s rollout uses non‑custodial wallet flows vs. regulated account flows will likely vary by country. (Singapore docs clearly describe a Pay account using X Layer and Grab/StraitsX conversion.)
  • Issuer and network breadth: Which stablecoins and which QR/card networks come next, and on what timetable? (BlockBeats notes Tap‑to‑Pay and regional card rollouts “in some regions.”)
  • Economics at scale: Merchant economics and user incentives (fees, FX, rewards) as this moves beyond Singapore.

Quick source highlights

  • Singapore “scan‑to‑pay” launch (official + independent): OKX Learn explainer and Reuters piece.
  • What Sam Liu is saying (fairness via unified order book; QR/Tap‑to‑Pay; OKX Card): Alphas Summit recap.
  • Haider Rafique’s positioning (everyday relevance via Mastercard): Mastercard press release with direct quote.
  • Unified USD Order Book details (what it is and why it matters): OKX docs/FAQ.
  • Scotty James role (co‑hosting OKX Pay/future of payments sessions at TOKEN2049): OKX announcements/socials and prior TOKEN2049 appearances.

From Apps to Assets: Fintech’s Leap into Crypto

· 37 min read
Dora Noda
Software Engineer

Traditional fintech applications have fundamentally transformed from consumer-facing services into critical infrastructure for the global crypto economy, with five major platforms collectively serving over 700 million users and processing hundreds of billions in crypto transactions annually. This shift from apps to assets represents not merely product expansion but a wholesale reimagining of financial infrastructure, where blockchain technology becomes the foundational layer rather than an adjacent feature. Robinhood, Revolut, PayPal, Kalshi, and CoinGecko are executing parallel strategies that converge on a singular vision: crypto as essential financial infrastructure, not an alternative asset class.

The transformation gained decisive momentum in 2024-2025 as regulatory clarity emerged through Europe's MiCA framework and the U.S. GENIUS Act for stablecoins, institutional adoption accelerated through Bitcoin ETFs managing billions in assets, and fintech companies achieved technological maturity enabling seamless crypto integration. These platforms now collectively represent the bridge between 400 million traditional finance users and the decentralized digital economy, each addressing distinct aspects of the same fundamental challenge: making crypto accessible, useful, and trustworthy for mainstream audiences.

The regulatory breakthrough that enabled scale

The period from 2024-2025 marked a decisive shift in the regulatory environment that had constrained fintech crypto ambitions for years. Johann Kerbrat, General Manager of Robinhood Crypto, captured the industry's frustration: "We received our Wells notice recently. For me, the main takeaway is the need for regulatory clarity in the U.S. regarding what are securities and what are cryptocurrencies. We've met with the SEC 16 times to try to register." Yet despite this uncertainty, companies pressed forward with compliance-first strategies that ultimately positioned them to capitalize when clarity arrived.

The European Union's Markets in Crypto-Assets regulation provided the first comprehensive framework, enabling Revolut to launch crypto services across 30 European Economic Area countries and Robinhood to expand through its $200 million Bitstamp acquisition in June 2025. Mazen ElJundi, Global Business Head of Crypto at Revolut, acknowledged: "The MiCA framework has a lot of pros and cons. It is not perfect, but it has merit to actually exist, and it helps companies like ours to understand what we can offer to customers." This pragmatic acceptance of imperfect regulation over regulatory vacuum became the industry consensus.

In the United States, multiple breakthrough moments converged. Kalshi's victory over the CFTC in its lawsuit regarding political prediction markets established federal jurisdiction over event contracts, with the regulatory agency dropping its appeal in May 2025. John Wang, Kalshi's 23-year-old Head of Crypto appointed in August 2025, declared: "Prediction markets and event contracts are now being held at the same level as normal derivatives and stocks—this is genuinely like the new world's newest asset class." The Trump administration's establishment of a U.S. Federal Strategic Bitcoin Reserve through Executive Order in March 2025 and the passage of the GENIUS Act providing a regulated pathway for stablecoins created an environment where fintech companies could finally build with confidence.

PayPal epitomized the compliance-first approach by becoming one of the first companies to receive a full BitLicense from New York's Department of Financial Services in June 2022, years before launching its PayPal USD stablecoin in August 2023. May Zabaneh, Vice President of Product for Blockchain, Crypto, and Digital Currencies at PayPal, explained the strategy: "PayPal chose to become fully licensed because it was the best way forward to offer cryptocurrency services to its users, given the robust framework provided by the NYDFS for such services." This regulatory groundwork enabled PayPal to move swiftly when the SEC closed its PYUSD investigation without action in 2025, removing the final uncertainty barrier.

The regulatory transformation enabled not just permissionless innovation but coordinated infrastructure development across traditional and crypto-native systems. Robinhood's Johann Kerbrat noted the practical impact: "My goal is to make sure that we can work no matter which side is winning in November. I'm hopeful that it's been clear at this point that we need regulation, otherwise we're going to be late compared to the EU and other places in Asia." By late 2025, fintech platforms had collectively secured over 100 licenses across global jurisdictions, transforming from regulatory supplicants to trusted partners in shaping crypto's integration into mainstream finance.

Stablecoins emerge as the killer application for payments

The convergence of fintech platforms on stablecoins as core infrastructure represents perhaps the clearest signal of crypto's evolution from speculation to utility. May Zabaneh articulated the industry consensus: "For years, stablecoins have been deemed crypto's 'killer app' by combining the power of the blockchain with the stability of fiat currency." By 2025, this theoretical promise became operational reality as stablecoin circulation doubled to $250 billion within 18 months, with McKinsey forecasting $2 trillion by 2028.

PayPal's PayPal USD stablecoin exemplifies the strategic pivot from crypto as tradable asset to crypto as payment infrastructure. Launched in August 2023 and now deployed across Ethereum, Solana, Stellar, and Arbitrum blockchains, PYUSD reached $894 million in circulation by mid-2025 despite representing less than 1% of the total stablecoin market dominated by Tether and Circle. The significance lies not in market share but in use case: PayPal used PYUSD to pay EY invoices in October 2024, demonstrating real-world utility within traditional business operations. The company's July 2025 "Pay with Crypto" merchant solution, accepting 100+ cryptocurrencies but converting everything to PYUSD before settlement, reveals the strategic vision—stablecoins as the settlement layer bridging volatile crypto and traditional commerce.

Zabaneh emphasized the payments transformation: "As we see cross-border payments being a key area where digital currencies can provide real world value, working with Stellar will help advance the use of this technology and provide benefits for all users." The expansion to Stellar specifically targets remittances and cross-border payments, where traditional rails charge 3% on a $200 trillion global market. PayPal's merchant solution reduces cross-border transaction fees by 90% compared to traditional credit card processing through crypto-stablecoin conversion, offering a 0.99% promotional rate versus the average 1.57% U.S. credit card processing fee.

Both Robinhood and Revolut have signaled stablecoin ambitions, with Bloomberg reporting in September 2024 that both companies were exploring proprietary stablecoin issuance. For Revolut, which already contributes price data to Pyth Network supporting DeFi applications managing $15.2 billion in total value, a stablecoin would complete its transformation into crypto infrastructure provider. Mazen ElJundi framed this evolution: "Our partnership with Pyth is an important milestone in Revolut's journey to modernize finance. As DeFi continues to gain traction, Pyth's position as the backbone of the industry will help Revolut capitalize on this transformation."

The stablecoin strategy reflects deeper insights about crypto adoption. Rather than expecting users to embrace volatile assets, these platforms recognized that crypto's transformative power lies in its rails, not its assets. By maintaining fiat denomination while gaining blockchain benefits—instant settlement, programmability, 24/7 availability, lower costs—stablecoins offer the value proposition that 400 million fintech users actually want: better money movement, not speculative investments. May Zabaneh captured this philosophy: "In order for things to become mainstream, they have to be easily accessible, easily adoptable." Stablecoins, it turns out, are both.

Prediction markets become the trojan horse for sophisticated financial products

Kalshi's explosive growth trajectory—from 3.3% market share in early 2024 to 66% by September 2025, with a single-day record of $260 million in trading volume—demonstrates how prediction markets successfully package complex financial concepts for mainstream audiences. John Wang's appointment as Head of Crypto in August 2025 accelerated the platform's explicit strategy to position prediction markets as the gateway drug for crypto adoption. "I think prediction markets are similar to options that are packaged in the most accessible form possible," Wang explained at Token 2049 Singapore in October 2025. "So I think prediction markets are like the Trojan Horse for people to enter crypto."

The platform's CFTC-regulated status provides a critical competitive advantage over crypto-native competitors like Polymarket, which prepared for U.S. reentry by acquiring QCEX for $112 million. Kalshi's federal regulatory designation as a Designated Contract Market bypasses state gambling restrictions, enabling 50-state access while traditional sportsbooks navigate complex state-by-state licensing. This regulatory arbitrage, combined with crypto payment rails supporting Bitcoin, Solana, USDC, XRP, and Worldcoin deposits, creates a unique position: federally regulated prediction markets with crypto-native infrastructure.

Wang's vision extends beyond simply accepting crypto deposits. The launch of KalshiEco Hub in September 2025, with strategic partnerships on Solana and Base (Coinbase's Layer-2), positions Kalshi as a platform for developers to build sophisticated trading tools, analytics dashboards, and AI agents. "It can range anywhere from pushing data onchain from our API to, in the future, tokenizing Kalshi positions, providing margin and leveraged trading, and building third-party front ends," Wang outlined at Solana APEX. The developer ecosystem already includes tools like Kalshinomics for market analytics and Verso for professional-grade discovery, with Wang committing that Kalshi will integrate with "every major crypto app and exchange" within 12 months.

The Robinhood partnership announced in March 2025 and expanded in August exemplifies the strategic distribution play. By embedding Kalshi's CFTC-regulated prediction markets within Robinhood's app serving 25.2 million funded customers, both companies gain: Robinhood offers differentiated products without navigating gambling regulations, while Kalshi accesses mainstream distribution. The partnership initially focused on NFL and college football markets but expanded to politics, economics, and broader event contracts, with revenue split equally between platforms. Johann Kerbrat noted Robinhood's broader strategy: "We don't really see this distinction between a crypto company and a non-crypto company. Over time, anyone who is basically moving money or anyone who's in financial services is going to be a crypto company."

Kalshi's success validates Wang's thesis that simplified financial derivatives—yes/no questions on real-world events—can democratize sophisticated trading strategies. By removing the complexity of options pricing, Greeks, and contract specifications, prediction markets make probabilistic thinking accessible to retail audiences. Yet beneath this simplicity lies the same risk management, hedging, and market-making infrastructure that supports traditional derivatives markets. Wall Street firms including Susquehanna International Group provide institutional liquidity, while the platform's integration with Zero Hash for crypto processing and LedgerX for clearing demonstrates institutional-grade infrastructure. The platform's $2 billion valuation following its June 2025 Series C led by Paradigm and Sequoia reflects investor conviction that prediction markets represent a genuine new asset class—and crypto provides the ideal infrastructure to scale it globally.

Retail crypto trading matures into multi-asset wealth platforms

Robinhood's transformation from the company that restricted GameStop trading in 2021 to a crypto infrastructure leader generating $358 million in crypto revenue in Q4 2024 alone—representing 700% year-over-year growth—illustrates how retail platforms evolved beyond simple buy/sell functionality. Johann Kerbrat, who joined Robinhood over three years ago after roles at Iron Fish, Airbnb, and Uber, has overseen this maturation into comprehensive crypto-native financial services. "We think that crypto is actually the way for us to rebuild the entire Robinhood in the EU from the ground up, just using blockchain technology," Kerbrat explained at EthCC 2025 in Cannes. "We think that blockchain technology can make things more efficient, faster, and also include more people."

The $200 million Bitstamp acquisition completed in June 2025 marked Robinhood's decisive move into institutional crypto infrastructure. The 14-year-old exchange brought 50+ global licenses, 5,000 institutional clients, 500,000 retail users, and approximately $72 billion in trailing twelve-month trading volume—representing 50% of Robinhood's retail crypto volume. More strategically, Bitstamp provided institutional capabilities including lending, staking, white-label crypto-as-a-service, and API connectivity that position Robinhood to compete beyond retail. "The acquisition of Bitstamp is a major step in growing our crypto business," Kerbrat stated. "Through this strategic combination, we are better positioned to expand our footprint outside of the US and welcome institutional customers to Robinhood."

Yet the most ambitious initiative may be Robinhood's Layer-2 blockchain and stock tokenization program announced in June 2025. The platform plans to tokenize over 200 U.S. stocks and ETFs, including controversial derivatives tied to private company valuations like SpaceX and OpenAI tokens. "For the user, it's very simple; you will be able to tokenize any financial instrument in the future, not just US stocks, but anything," Kerbrat explained. "If you want to change brokers, you won't have to wait multiple days and wonder where your stocks are going; you'll be able to do it in an instant." Built on Arbitrum technology, the Layer-2 aims to provide compliance-ready infrastructure for tokenized assets, integrated seamlessly with Robinhood's existing ecosystem.

This vision extends beyond technical innovation to fundamental business model transformation. When asked about Robinhood's crypto ambitions, Kerbrat increasingly emphasizes technology over trading volumes: "I think this idea of blockchain as fundamental technology is really underexplored." The implication—Robinhood views crypto not as a product category but as the technological foundation for all financial services—represents a profound strategic bet. Rather than offering crypto alongside stocks and options, the company is rebuilding its core infrastructure on blockchain rails, using tokenization to eliminate settlement delays, reduce intermediary costs, and enable 24/7 markets.

The competitive positioning against Coinbase reflects this strategic divergence. While Coinbase offers 260+ cryptocurrencies versus Robinhood's 20+ in the U.S., Robinhood provides integrated multi-asset trading, 24/5 stock trading alongside crypto, lower fees for small trades (approximately 0.55% flat versus Coinbase's tiered structure starting at 0.60% maker/1.20% taker), and cross-asset functionality appealing to hybrid investors. Robinhood's stock quadrupled in 2024 versus Coinbase's 60% gain, suggesting markets reward the diversified fintech super-app model over pure-play crypto exchanges. Kerbrat's user insight validates this approach: "We have investors that are brand new to crypto, and they will just start going from trading one of their stocks to one of the coins, then get slowly into the crypto world. We are also seeing a progression from just holding assets to actually transferring them out using a wallet and getting more into Web3."

Global crypto banking bridges traditional and decentralized finance

Revolut's achievement of 52.5 million users across 48 countries with crypto-related wealth revenue surging 298% to $647 million in 2024 demonstrates how neobanks successfully integrated crypto into comprehensive financial services. Mazen ElJundi, Global Business Head of Crypto, Wealth & Trading, articulated the strategic vision on the Gen C podcast in May 2025: Revolut is "creating a bridge between traditional banking and Web3, driving crypto adoption through education and intuitive user experiences." This bridge manifests through products spanning the spectrum from beginner education to sophisticated trading infrastructure.

The Learn & Earn program, which onboarded over 3 million customers globally with hundreds of thousands joining monthly, exemplifies the education-first approach. Users complete interactive lessons on blockchain protocols including Polkadot, NEAR, Avalanche, and Algorand, receiving crypto rewards worth €5-€15 per course upon passing quizzes. The 11FS Pulse Report named Revolut a "top cryptocurrency star" in 2022 for its "fun and simple approach" to crypto education. ElJundi emphasized the strategic importance: "We're excited to continue our mission of making the complex world of blockchain technology more accessible to everyone. The appetite for educational content on web3 continues to increase at a promising and encouraging rate."

For advanced traders, Revolut X—launched in May 2024 for the UK and expanded to 30 EEA countries by November 2024—provides standalone exchange functionality with 200+ tokens, 0% maker fees, and 0.09% taker fees. The March 2025 mobile app launch extended this professional-grade infrastructure to on-the-go trading, with Leonid Bashlykov, Head of Crypto Exchange Product, reporting: "Tens of thousands of traders actively using the platform in UK; feedback very positive, with many already taking advantage of our near-zero fees, wide range of available assets, and seamless integration with their Revolut accounts." The seamless fiat-to-crypto conversion within Revolut's ecosystem—with no fees or limits for on/off-ramping between Revolut account and Revolut X—eliminates friction that typically impedes crypto adoption.

The partnership with Pyth Network announced in January 2025 signals Revolut's ambition to become crypto infrastructure provider, not merely consumer application. As the first banking data publisher to join Pyth Network, Revolut contributes proprietary digital asset price data to support 500+ real-time feeds securing DeFi applications managing $15.2 billion and handling over $1 trillion in total traded volume across 80+ blockchain ecosystems. ElJundi framed this as strategic positioning: "By working with Pyth to provide our reliable market data to applications, Revolut can influence digital economies by ensuring developers and users have access to the precise, real-time information they need." This data contribution allows Revolut to participate in DeFi infrastructure without capital commitment or active trading—a elegant solution to regulatory constraints on more direct DeFi engagement.

Revolut Ramp, launched in March 2024 through partnership with MetaMask, provides the critical on-ramp connecting Revolut's 52.5 million users to self-custody Web3 experiences. Users can purchase 20+ tokens including ETH, USDC, and SHIB directly into MetaMask wallets using Revolut account balances or Visa/Mastercard, with existing Revolut customers bypassing additional KYC and completing transactions within seconds. ElJundi positioned this as ecosystem play: "We are excited to announce our new crypto product Revolut Ramp, a leading on-ramp solution for the web3 ecosystem. Our on-ramp solution ensures high success rates for transactions done within the Revolut ecosystem and low fees for all customers."

The UK banking license obtained in July 2024 after a three-year application process, combined with Lithuanian banking license from the European Central Bank enabling MiCA-compliant operations, positions Revolut uniquely among crypto-friendly neobanks. Yet significant challenges persist, including €3.5 million fine from Bank of Lithuania in 2025 for AML failures related to crypto transactions and ongoing regulatory pressure on crypto-related banking services. Despite naming Revolut the "most crypto-friendly UK bank" with 38% of UK crypto firms using it for banking services, the company must navigate the perpetual tension between crypto innovation and banking regulation. ElJundi's emphasis on cross-border payments as the most promising crypto use case—"borderless payments represent one of the most promising use cases for cryptocurrency"—reflects pragmatic focus on defensible, regulation-compatible applications rather than pursuing every crypto opportunity.

Data infrastructure becomes the invisible foundation

CoinGecko's evolution from consumer-facing price tracker to enterprise data infrastructure provider processing 677 billion API requests annually reveals how data and analytics became essential plumbing for fintech crypto integration. Bobby Ong, Co-Founder and newly appointed CEO as of August 2025, explained the foundational insight: "We decided to pursue a data site because, quite simply, there's always a need for good quality data." That simple insight, formed when Bitcoin was trading at single-digit prices and Ong was mining his first coins in 2010, now underpins an enterprise serving Consensys, Chainlink, Coinbase, Ledger, Etherscan, Kraken, and Crypto.com.

The independence that followed CoinMarketCap's acquisition by Binance in 2020 became CoinGecko's defining competitive advantage. "The opposite happened, and users turned towards CoinGecko," Ong observed. "This happened because CoinGecko has always remained neutral & independent when giving numbers." This neutrality matters critically for fintech applications requiring unbiased data sources—Robinhood, Revolut, and PayPal cannot rely on data from competitors like Coinbase or exchanges with vested interests in specific tokens. CoinGecko's comprehensive coverage of 18,000+ cryptocurrencies across 1,000+ exchanges, plus 17 million tokens tracked through GeckoTerminal across 1,700 decentralized exchanges, provides fintech platforms the complete market visibility required for product development.

The Chainlink partnership exemplifies CoinGecko's infrastructure role. By providing cryptocurrency market data—price, trading volume, and market capitalization—for Chainlink's decentralized oracle network, CoinGecko enables smart contract developers to access reliable pricing for DeFi applications. "CoinGecko's cryptocurrency market data can now be easily called by smart contract developers when developing decentralized applications," the companies announced. "This data is available for Bitcoin, Ethereum, and over 5,700 coins that are currently being tracked on CoinGecko." This integration eliminates single points of failure by evaluating multiple data sources, maintaining oracle integrity crucial for DeFi protocols handling billions in locked value.

Ong's market insights, shared through quarterly reports, conference presentations including his Token 2049 Singapore keynote in October 2025 titled "Up Next: 1 Billion Tokens, $50 Trillion Market Cap," and his long-running CoinGecko Podcast, provide fintech companies valuable intelligence for strategic planning. His prediction that gaming would be the "dark horse" of crypto adoption—"hundreds of millions of dollars have gone into gaming studios to build web3 games in the past few years. All we need is just one game to become a big hit and suddenly we have millions of new users using crypto"—reflects the data-driven insights accessible to CoinGecko through monitoring token launches, DEX activity, and user behavior patterns across the entire crypto ecosystem.

The leadership transition from COO to CEO in August 2025, with co-founder TM Lee becoming President focused on long-term product vision and R&D, signals CoinGecko's maturation into institutionalized data provider. The appointment of Cedric Chan as CTO with mandate to embed AI into operations and deliver "real-time, high-fidelity crypto data" demonstrates the infrastructure investments required to serve enterprise customers. Ong framed the evolution: "TM and I started CoinGecko with a shared vision to empower the decentralized future. These values will continue to guide us forward." For fintech platforms integrating crypto, CoinGecko's comprehensive, neutral, and reliable data services represent essential infrastructure—the Bloomberg terminal for digital assets that enables everything else to function.

Technical infrastructure enables seamless user experiences

The transformation from crypto as separate functionality to integrated infrastructure required solving complex technical challenges around custody, security, interoperability, and user experience. These fintech platforms collectively invested billions in building the technical rails enabling mainstream crypto adoption, with architecture decisions revealing strategic priorities.

Robinhood's custody infrastructure holding $38 billion in crypto assets as of November 2024 employs industry-standard cold storage for the majority of funds, third-party security audits, and multi-signature protocols. The platform's licensing by New York State Department of Financial Services and FinCEN registration as money services business demonstrates regulatory-grade security. Yet the user experience abstracts this complexity entirely—customers simply see balances and execute trades within seconds. Johann Kerbrat emphasized this principle: "I think what makes us unique is that our UX and UI are pretty innovative. Compared to all the competition, this is probably one of the best UIs out there. I think that's what we want to bring to every product we build. Either the best-in-class type of pricing or the best-in-class UI UX."

The Crypto Trading API launched in May 2024 reveals Robinhood's infrastructure ambitions beyond consumer applications. Providing real-time market data access, programmatic portfolio management, automated trading strategies, and 24/7 crypto market access, the API enables developers to build sophisticated applications atop Robinhood's infrastructure. Combined with Robinhood Legend desktop platform featuring 30+ technical indicators, futures trading, and advanced order types, the company positioned itself as infrastructure provider for crypto power users, not merely retail beginners. The integration of Bitstamp's smart order routing post-acquisition provides institutional-grade execution across multiple liquidity venues.

PayPal's technical approach prioritizes seamless merchant integration over blockchain ideology. The Pay with Crypto solution announced in July 2025 exemplifies this philosophy: customers connect crypto wallets at checkout, PayPal sells cryptocurrency on centralized or decentralized exchanges, converts proceeds to PYUSD, then converts PYUSD to USD for merchant deposit—all happening transparently behind familiar PayPal checkout flow. Merchants receive dollars, not volatile crypto, eliminating the primary barrier to merchant adoption while enabling PayPal to capture transaction fees on what becomes a $3+ trillion addressable market of 650 million global crypto users. May Zabaneh captured the strategic insight: "As with almost anything with payments, consumers and shoppers should be given the choice in how they want to pay."

Revolut's multi-blockchain strategy—Ethereum for DeFi access, Solana for low-cost high-speed transactions, Stellar for cross-border payments—demonstrates sophisticated infrastructure architecture matching specific blockchains to use cases rather than single-chain maximalism. The staking infrastructure supporting Ethereum, Cardano, Polkadot, Solana, Polygon, and Tezos with automated staking for certain tokens reflects the deep integration required to abstract blockchain complexity from users. Over two-thirds of Revolut's Solana holdings in Europe are staked, suggesting users increasingly expect yield generation as default functionality rather than optional feature requiring technical knowledge.

Kalshi's partnership with Zero Hash for all crypto deposit processing—instantly converting Bitcoin, Solana, USDC, XRP, and other cryptocurrencies to USD while maintaining CFTC compliance—illustrates how infrastructure providers enable regulated companies to access crypto rails without becoming crypto custodians themselves. The platform supports $500,000 crypto deposit limits versus lower traditional banking limits, providing power users advantages while maintaining federal regulatory oversight. John Wang's vision for "purely additive" onchain initiatives—pushing event data onto blockchains in real-time, future tokenization of Kalshi positions, permissionless margin trading—suggests infrastructure evolution will continue expanding functionality while preserving the core regulated exchange experience for existing users.

The competitive landscape reveals collaborative infrastructure

The apparent competition between these platforms masks underlying collaboration on shared infrastructure that benefits the entire ecosystem. Kalshi's partnership with Robinhood, Revolut's integration with MetaMask and Pyth Network, PayPal's collaboration with Coinbase for fee-free PYUSD purchases, and CoinGecko's data provision to Chainlink oracles demonstrate how competitive positioning coexists with infrastructure interdependence.

The stablecoin landscape illustrates this dynamic. PayPal's PYUSD competes with Tether's USDT and Circle's USDC for market share, yet all three protocols require the same infrastructure: blockchain networks for settlement, crypto exchanges for liquidity, fiat banking partners for on/off ramps, and regulatory licenses for compliance. When Robinhood announced joining the Global Dollar Network for USDG stablecoin, it simultaneously validated PayPal's stablecoin strategy while creating competitive pressure. Both Robinhood and Revolut exploring proprietary stablecoins according to Bloomberg reporting in September 2024 suggests industry consensus that stablecoin issuance represents essential infrastructure for fintech platforms, not merely product diversification.

The blockchain network partnerships reveal strategic alignment. Kalshi's KalshiEco Hub supports both Solana and Base (Coinbase's Layer-2), Robinhood's Layer-2 builds on Arbitrum technology, PayPal's PYUSD deploys across Ethereum, Solana, Stellar, and Arbitrum, and Revolut integrates Ethereum, Solana, and prepares for Stellar expansion. Rather than fragmenting across incompatible networks, these platforms converge on the same handful of high-performance blockchains, creating network effects that benefit all participants. Bobby Ong's observation that "we're finally seeing DEXes challenge CEXes" following Hyperliquid's rise to 8th largest perpetuals exchange reflects how decentralized infrastructure matures to institutional quality, reducing advantages of centralized intermediaries.

The regulatory advocacy presents similar dynamics. While these companies compete for market share, they share interests in clear frameworks that enable innovation. Johann Kerbrat's statement that "my goal is to make sure that we can work no matter which side is winning in November" reflects industry-wide pragmatism—companies need workable regulation more than they need specific regulatory outcomes. The passage of the GENIUS Act for stablecoins, the Trump administration's establishment of a Strategic Bitcoin Reserve, and the SEC's closure of investigations into PYUSD without action all resulted from years of collective industry advocacy, not individual company lobbying. May Zabaneh's repeated emphasis that "there has to be some clarity that comes out, some standards, some ideas of the dos and the don'ts and some structure around it" articulates the shared priority that supersedes competitive positioning.

User adoption reveals mainstream crypto's actual use cases

The collective user bases of these platforms—over 700 million accounts across Robinhood, Revolut, PayPal, Venmo, and CoinGecko—provide empirical insights into how mainstream audiences actually use crypto, revealing patterns often divergent from crypto-native assumptions.

PayPal and Venmo's data shows 74% of users who purchased crypto continued holding it over 12 months, suggesting stability-seeking behavior rather than active trading. Over 50% chose Venmo specifically for "safety, security, and ease of use" rather than decentralization or self-custody—the opposite of crypto-native priorities. May Zabaneh's insight that customers want "choice in how they want to pay" manifests in payment functionality, not DeFi yield farming. The automatic "Cash Back to Crypto" feature on Venmo Credit Card reflects how fintech platforms successfully integrate crypto into existing behavioral patterns rather than requiring users to adopt new ones.

Robinhood's observation that users "start going from trading one of their stocks to one of the coins, then get slowly into the crypto world" and show "progression from just holding assets to actually transferring them out using a wallet and getting more into Web3" reveals the onboarding pathway—familiarity with platform precedes crypto experimentation, which eventually leads some users to self-custody and Web3 engagement. Johann Kerbrat's emphasis on this progression validates the strategy of integrating crypto into trusted multi-asset platforms rather than expecting users to adopt crypto-first applications.

Revolut's Learn & Earn program onboarding 3 million users with hundreds of thousands joining monthly demonstrates that education significantly drives adoption when paired with financial incentives. The UK's prohibition of Learn & Earn rewards in September 2023 due to regulatory changes provides natural experiment showing education alone less effective than education plus rewards. Mazen ElJundi's emphasis that "borderless payments represent one of the most promising use cases for cryptocurrency" reflects usage patterns showing cross-border payments and remittances as actual killer apps, not NFTs or DeFi protocols.

Kalshi's user demographics skewing toward "advanced retail investors, like options traders" seeking direct event exposure reveals prediction markets attract sophisticated rather than novice crypto users. The platform's explosive growth from $13 million monthly volume in early 2025 to a single-day record of $260 million in September 2025 (driven by sports betting, particularly NFL) demonstrates how crypto infrastructure enables scaling of financial products addressing clear user demands. John Wang's characterization of the "crypto community as the definition of power users, people who live and breathe new financial markets and frontier technology" acknowledges Kalshi's target audience differs from PayPal's mainstream consumers—different platforms serving different segments of the crypto adoption curve.

Bobby Ong's analysis of meme coin behavior provides contrasting insights: "In the long run, meme coins will probably follow an extreme case of power law, where 99.99% will fail." His observation that "the launch of TRUMPandTRUMP and MELANIA marked the top for meme coins as it sucked liquidity and attention out of all the other cryptocurrencies" reveals how speculative frenzies disrupt productive adoption. Yet meme coin trading represented significant volume across these platforms, suggesting user behavior remains more speculative than infrastructure builders prefer to acknowledge. The divergence between platform strategies emphasizing utility and stablecoins versus user behavior including substantial meme coin trading reflects ongoing tension in crypto's maturation.

The web3 integration challenge reveals philosophical divergence

The approaches these platforms take toward Web3 integration—enabling users to interact with decentralized applications, DeFi protocols, NFT marketplaces, and blockchain-based services—reveal fundamental philosophical differences despite superficial similarity in offering crypto services.

Robinhood's self-custody wallet, downloaded "hundreds of thousands of times in more than 100 countries" and supporting Ethereum, Bitcoin, Solana, Dogecoin, Arbitrum, Polygon, Optimism, and Base networks with cross-chain and gasless swaps, represents full embrace of Web3 infrastructure. The partnership with MetaMask through Robinhood Connect announced in April 2023 positions Robinhood as on-ramp to the broader Web3 ecosystem rather than walled garden. Johann Kerbrat's framing that blockchain technology will "rebuild the entire Robinhood in the EU from the ground up" suggests viewing Web3 as fundamental architecture, not adjacent feature.

PayPal's approach emphasizes utility within PayPal's ecosystem over interoperability with external Web3 applications. While PYUSD functions as standard ERC-20 token on Ethereum, SPL token on Solana, and maintains cross-chain functionality, PayPal's primary use cases—instant payments within PayPal/Venmo, merchant payments at PayPal-accepting merchants, conversion to other PayPal-supported cryptocurrencies—keep activity largely within PayPal's control. The Revolut Ramp partnership with MetaMask providing direct purchases into self-custody wallets represents more genuine Web3 integration, positioning Revolut as infrastructure provider for the open ecosystem. Mazen ElJundi's statement that "Revolut X along with our recent partnership with MetaMask, further consolidates our product offering in the world of Web3" frames integration as strategic priority.

The custody model differences crystallize the philosophical divergence. Robinhood's architecture where "once you purchase crypto on Robinhood, Robinhood believes you're the legal owner of the crypto" but Robinhood maintains custody creates tension with Web3's self-custody ethos. PayPal's custodial model where users cannot withdraw most cryptocurrencies to external wallets (except for specific tokens) prioritizes platform lock-in over user sovereignty. Revolut's model enabling crypto withdrawals of 30+ tokens to external wallets while maintaining staking and other services for platform-held crypto represents middle ground—sovereignty available but not required.

CoinGecko's role highlights infrastructure enabling Web3 without directly participating. By providing comprehensive data on DeFi protocols, DEXes, and token launches—tracking 17 million tokens across GeckoTerminal versus 18,000 more established cryptocurrencies on the main platform—CoinGecko serves Web3 developers and users without building competing products. Bobby Ong's philosophy that "anything that can be tokenized will be tokenized" embraces Web3's expansive vision while maintaining CoinGecko's focused role as neutral data provider.

The NFT integration similarly reveals varying commitment levels. Robinhood has largely avoided NFT functionality beyond basic holdings, focusing on tokenization of traditional securities instead. PayPal has not emphasized NFTs. Revolut integrated NFT data from CoinGecko in June 2023, tracking 2,000+ collections across 30+ marketplaces, though NFTs remain peripheral to Revolut's core offerings. This selective Web3 integration suggests platforms prioritize components with clear utility cases—DeFi for yield, stablecoins for payments, tokenization for securities—while avoiding speculative categories lacking obvious user demand.

The future trajectory points toward embedded finance redefined

The strategic roadmaps these leaders articulated reveal convergent vision for crypto's role in financial services over the next 3-5 years, with blockchain infrastructure becoming invisible foundation rather than explicit product category.

Johann Kerbrat's long-term vision—"We don't really see this distinction between a crypto company and a non-crypto company. Over time, anyone who is basically moving money or anyone who's in financial services is going to be a crypto company"—articulates the endpoint where crypto infrastructure ubiquity eliminates the crypto category itself. Robinhood's stock tokenization initiative, planning to tokenize "any financial instrument in the future, not just US stocks, but anything" with instant broker transfers replacing multi-day settlement, represents this vision operationalized. The Layer-2 blockchain development built on Arbitrum technology for compliance-ready infrastructure suggests 2026-2027 timeframe for these capabilities reaching production.

PayPal's merchant strategy targeting its 20 million business customers for PYUSD integration and expansion of Pay with Crypto beyond U.S. merchants to global rollout positions the company as crypto payment infrastructure at scale. May Zabaneh's emphasis on "payment financing" or PayFi—providing working capital for SMBs with delayed receivables using stablecoin infrastructure—illustrates how blockchain rails enable financial products impractical with traditional infrastructure. CEO Alex Chriss's characterization of PayPal World as "fundamentally reimagining how money moves around the world" by connecting the world's largest digital wallets suggests interoperability across previously siloed payment networks becomes achievable through crypto standards.

Revolut's planned expansion into crypto derivatives (actively recruiting General Manager for crypto derivatives as of June 2025), stablecoin issuance to compete with PYUSD and USDC, and US market crypto service relaunch following regulatory clarity signals multi-year roadmap toward comprehensive crypto banking. Mazen ElJundi's framing of "modernizing finance" through TradFi-DeFi convergence, with Revolut contributing reliable market data to DeFi protocols via Pyth Network while maintaining regulated banking operations, illustrates the bridging role neobanks will play. The investment of $500 million over 3-5 years for US expansion demonstrates capital commitment matching strategic ambition.

Kalshi's 12-month roadmap articulated by John Wang—integration with "every major crypto app and exchange," tokenization of Kalshi positions, permissionless margin trading, and third-party front-end ecosystem—positions prediction markets as composable financial primitive rather than standalone application. Wang's vision that "any generational fintech company of this decade will be powered by crypto" reflects millennial/Gen-Z leadership's assumption that blockchain infrastructure is default rather than alternative. The platform's developer-focused strategy with grants for sophisticated data dashboards, AI agents, and arbitrage tools suggests Kalshi will function as data oracle and settlement layer for prediction market applications, not merely consumer-facing exchange.

Bobby Ong's Token 2049 presentation titled "Up Next: 1 Billion Tokens, $50 Trillion Market Cap" signals CoinGecko's forecast for explosive token proliferation and market value growth over the coming years. His prediction that "the current market cycle is characterized by intense competition among companies to accumulate crypto assets, while the next cycle could escalate to nation-state involvement" following Trump's establishment of Strategic Bitcoin Reserve suggests institutional and sovereign adoption will drive the next phase. The leadership transition positioning Ong as CEO focused on strategic execution while co-founder TM Lee pursues long-term product vision and R&D suggests CoinGecko preparing infrastructure for exponentially larger market than exists today.

Measuring success: The metrics that matter in crypto-fintech integration

The financial performance and operational metrics these platforms disclosed reveal which strategies successfully monetize crypto integration and which remain primarily strategic investments awaiting future returns.

Robinhood's Q4 2024 crypto revenue of $358 million representing 35% of total net revenue ($1.01 billion total) and 700% year-over-year growth demonstrates crypto as material revenue driver, not experimental feature. However, Q1 2025's significant crypto revenue decline followed by Q2 2025 recovery to $160 million (still 98% year-over-year growth) reveals vulnerability to crypto market volatility. CEO Vlad Tenev's acknowledgment of need to diversify beyond crypto dependency led to Gold subscriber growth (3.5 million record), IRA matching, credit cards, and advisory services. The company's adjusted EBITDA of $1.43 billion in 2024 (up 167% year-over-year) and profitable operations demonstrate crypto integration financially sustainable when paired with diversified revenue streams.

Revolut's crypto-related wealth revenue of $647 million in 2024 (298% year-over-year growth) representing significant portion of $4 billion total revenue demonstrates similar materiality. However, crypto's contribution to the $1.4 billion pre-tax profit (149% year-over-year growth) shows crypto functioning as growth driver for profitable core business rather than sustaining unprofitable operations. The 52.5 million global users (38% year-over-year growth) and customer balances of $38 billion (66% year-over-year growth) reveal crypto integration supporting user acquisition and engagement metrics beyond direct crypto revenue. The obtainment of UK banking license in July 2024 after three-year process signals regulatory acceptance of Revolut's integrated crypto-banking model.

PayPal's PYUSD market cap oscillating between $700-894 million through 2025 after peaking at $1.012 billion in August 2024 represents less than 1% of the $229.2 billion total stablecoin market but provides strategic positioning for payments infrastructure play rather than asset accumulation. The $4.1 billion monthly transfer volume (23.84% month-over-month increase) demonstrates growing utility, while 51,942 holders suggests adoption remains early stage. The 4% annual rewards introduced April 2025 through Anchorage Digital partnership directly competes for deposit accounts, positioning PYUSD as yield-bearing cash alternative. PayPal's 432 million active users and $417 billion total payment volume in Q2 2024 (11% year-over-year growth) contextualize crypto as strategic initiative within massive existing business rather than existential transformation.

Kalshi's dramatic trajectory from $13 million monthly volume early 2025 to $260 million single-day record in September 2025, market share growth from 3.3% to 66% overtaking Polymarket, and $2 billion valuation in June 2025 Series C demonstrates prediction markets achieving product-market fit with explosive growth. The platform's 1,220% revenue growth in 2024 and total volume of $1.97 billion (up from $183 million in 2023) validates the business model. However, sustainability beyond election cycles and peak sports seasons remains unproven—August 2025 volume declined before September's NFL-driven resurgence. The 10% of deposits made with crypto suggests crypto infrastructure important but not dominant for user base, with traditional payment rails still primary.

CoinGecko's 677 billion API requests annually and enterprise customers including Consensys, Chainlink, Coinbase, Ledger, and Etherscan demonstrate successful transition from consumer-facing application to infrastructure provider. The company's funding history, including Series B and continued private ownership, suggests profitability or strong unit economics enabling infrastructure investment without quarterly earnings pressure. Bobby Ong's elevation to CEO with mandate for "strategic foresight and operational excellence" signals maturation into institutionalized enterprise rather than founder-led startup.

The verdict: Crypto becomes infrastructure, not destination

The transformation from apps to assets fundamentally represents crypto's absorption into financial infrastructure rather than crypto's replacement of traditional finance. These five companies, collectively serving over 700 million users and processing hundreds of billions in crypto transactions annually, validated that mainstream crypto adoption occurs through familiar platforms adding crypto functionality, not through users adopting crypto-native platforms.

Johann Kerbrat's observation that "anyone who is basically moving money or anyone who's in financial services is going to be a crypto company" proved prescient—by late 2025, the distinction between fintech and crypto companies became semantic rather than substantive. Robinhood tokenizing stocks, PayPal settling merchant payments through stablecoin conversion, Revolut contributing price data to DeFi protocols, Kalshi pushing event data onchain, and CoinGecko providing oracle services to smart contracts all represent crypto infrastructure enabling traditional financial products rather than crypto products replacing traditional finance.

The stablecoin convergence exemplifies this transformation. As McKinsey forecast $2 trillion stablecoin circulation by 2028 from $250 billion in 2025, the use case clarified: stablecoins as payment rails, not stores of value. The blockchain benefits—instant settlement, 24/7 availability, programmability, lower costs—matter for infrastructure while fiat denomination maintains mainstream acceptability. May Zabaneh's articulation that stablecoins represent crypto's "killer app" by "combining the power of the blockchain with the stability of fiat currency" captured the insight that mainstream adoption requires mainstream denominations.

The regulatory breakthrough in 2024-2025 through MiCA, GENIUS Act, and federal court victories for Kalshi created the clarity all leaders identified as prerequisite for mainstream adoption. May Zabaneh's statement that "there has to be some clarity that comes out, some standards, some ideas of the dos and the don'ts" reflected universal sentiment that regulatory certainty mattered more than regulatory favorability. The companies that invested in compliance-first strategies—PayPal's full BitLicense, Robinhood's meeting with SEC 16 times, Kalshi's CFTC litigation, Revolut's UK banking license—positioned themselves to capitalize when clarity arrived.

Yet significant challenges persist. Robinhood's 35% Q4 revenue dependence on crypto followed by Q1 decline demonstrates volatility risk. Revolut's €3.5 million AML fine highlights ongoing compliance challenges. PayPal's PYUSD capturing less than 1% stablecoin market share shows incumbent advantages in crypto markets. Kalshi's sustainability beyond election cycles remains unproven. CoinGecko's challenge competing against exchange-owned data providers with deeper pockets continues. The path from 700 million accounts to mainstream ubiquity requires continued execution, regulatory navigation, and technological innovation.

The ultimate measure of success will not be crypto revenue percentages or token prices but rather crypto's invisibility—when users obtain yield on savings accounts without knowing stablecoins power them, transfer money internationally without recognizing blockchain rails, trade prediction markets without understanding smart contracts, or tokenize assets without comprehending custody architecture. John Wang's vision of prediction markets as "Trojan Horse for crypto," Mazen ElJundi's "bridge between Web2 and Web3," and Bobby Ong's philosophy that "anything that can be tokenized will be tokenized" all point toward the same endpoint: crypto infrastructure so seamlessly integrated into financial services that discussing "crypto" as separate category becomes obsolete. These five leaders, through parallel execution of convergent strategies, are building that future—one API request, one transaction, one user at a time.

How Stablecoins Can Go Mainstream Like Credit Cards

· 8 min read
Dora Noda
Software Engineer

Stablecoins are most widely known for their role as the "settlement layer" in the crypto market. However, to truly fulfill their potential as the core of the internet of value, stablecoins must cross the chasm from an insider tool to a form of everyday payment, becoming the next generation of digital currency in our pockets.

This path is full of challenges, but not unachievable. Let's start with the conclusion: for stablecoins to transition from a "settlement layer" to "everyday payment" in the U.S., the most viable path is to—

First, establish sustainable "strongholds" in niche scenarios by leveraging incentives and relative convenience.

Then, use an open, neutral, and participant-governed network to standardize and interconnect these fragmented strongholds, aggregating them into a unified whole to reach the mainstream.

1. Learning the "Two-Step" from Credit Cards

Any new payment method faces a common hurdle in its early stages: the bootstrapping problem. This is a classic "chicken-or-egg" dilemma—a network has no value without users, and users won't join a network that lacks value. To understand how stablecoins can break this cycle, we can learn from the successful path of credit cards, particularly the "two-step" strategy pioneered by BankAmericard (the precursor to Visa).

Credit cards' initial breakthrough was not through instant nationwide coverage but by creating positive feedback loops in local areas based on their "innate characteristics." The first was convenience—a single card could be used at multiple stores, greatly reducing the friction of carrying cash and writing checks. The second was incentives—it offered easier access to revolving credit, reaching a population underserved by traditional charge cards and providing tangible benefits to users. For merchants, credit cards brought incremental sales; by "outsourcing" credit and risk management to financial institutions, even small and medium-sized businesses could enjoy the sales boost from offering credit.

Once these fragmented strongholds formed a positive feedback loop, the true leap came in the second step: connecting them. The key was building an organizationally neutral network governed by all participants. This addressed the early distrust that came with being "both the referee and the player," allowing banks and merchants to join with confidence. At the same time, technical interoperability provided uniform rules for authorization, clearing, settlement, and dispute resolution, making the system efficient enough to compete with cash and checks.

The takeaway is: first, use "innate characteristics" to create a positive feedback loop in a niche, then use an "open network" to scale this local advantage into a national network effect.

2. The Three Levers of Stablecoins: Convenience | Incentives | Incremental Sales

Today's stablecoin ecosystem is gradually acquiring the "innate characteristics" that credit cards once had.

1) Convenience (The Gap Is Narrowing)

The pain points of current stablecoin payments are clear: high friction for fiat on-ramps, a poor user experience with private keys and gas tokens, and the complexity of cross-chain compatibility. Fortunately, we have clear technological and regulatory pathways to approximate the bank card experience.

In the future, deep integration with regulated custodians and financial institutions will significantly reduce the friction of exchanging fiat for stablecoins. Concurrently, infrastructure improvements like account abstraction, gas sponsorship, and passkeys will free users from the burden of private key management and gas payments. Furthermore, advances in chain abstraction and smart routing technology will simplify the complexity of users and merchants needing to be on the same chain, enabling seamless payments.

The conclusion is: while stablecoin payments are not convenient enough today, the technological and regulatory pathways are clear and are rapidly catching up.

2) Incentives (For Both Merchants and Consumers)

Stablecoins can offer incentives far beyond static loyalty points. Imagine "white-label stablecoins," where a regulated issuer handles the underlying issuance and operation, while a brand distributes it under its own label. This new type of membership asset is more user-friendly than traditional closed-loop stored value because it's transferable and redeemable. Brands can leverage its programmability to provide targeted subsidies, such as instant discounts, free shipping, priority access, or even VIP services.

On the consumer side, programmable rewards will bring a revolutionary experience. Stablecoins' native programmability allows rewards to be tightly coupled with payments: you can implement instant subsidies at settlement or dynamic rewards triggered by specific behaviors. Airdrops can be used for low-cost, targeted reach and immediate activation. If wallets can seamlessly route a user's floating funds to a compliant yield source, users will be more willing to keep balances within the ecosystem and spend directly with stablecoins.

3) Incremental Sales (Yield-Driven "BNPL-like" Model)

Stablecoins themselves are not credit instruments, but they can be layered with custodial and yield mechanisms to create a new model for stimulating consumption. A merchant could set it up so that when transaction funds enter a custodial account and earn yield, a portion of that yield is used to subsidize the user's bill upon maturity. This is essentially a redistribution of DeFi yield, transformed into a more refined and attractive transaction subsidy, exchanging lower capital costs for higher conversion rates and average order values.

3. How to Bootstrap a Stablecoin Payment Network

Step One: Build Self-Contained "Strongholds"

The secret to success is to start in marginal, niche scenarios rather than directly challenging the mainstream.

  • Niche A: Relative Convenience + New Sales.

    • Scenario: A U.S. merchant sells dollar-denominated digital goods or services to international users, where traditional payment methods are either expensive or restricted.
    • Value: Stablecoins provide an accessible and affordable payment rail, bringing the merchant new sales and a wider reach.
  • Niche B: Incentive-Driven Audiences & High-Frequency Platforms.

    • Scenario 1: Fan Economy/Cultural Icons. Fan communities commit to holding a "her-branded dollar" in exchange for priority access and exclusive rights.
    • Scenario 2: High-Velocity In-Platform Markets. For example, a second-hand marketplace or content creation platform where sellers' revenue is often recirculated within the platform. Using a "platform dollar" reduces the friction of funds entering and exiting, amplifying turnover efficiency.

For these strongholds to succeed, three elements are essential: incentives must be impactful (instant reductions are better than long-term points), the experience must be smooth (quick on-ramps, gas-less experience, chain abstraction), and the funds must be transferable/redeemable (avoiding the psychological burden of "permanent lock-in").

Step Two: Use an Open Network to Connect the "Strongholds"

Once fragmented strongholds achieve scale, a unified network is needed to aggregate them. This network must be:

  • Neutrally Governed: Co-governed by participants to avoid vertical integration with a specific issuer or acquirer, thereby earning everyone's trust.
  • Unified Rules: Under the appropriate regulatory and licensing frameworks, establish uniform rules for KYC/AML, consumer protection, redemption, and dispute resolution, as well as clear procedures for extreme situations like asset freezing or blacklisting.
  • Technically Interoperable: Standardize messaging for authorization, clearing, and reconciliation. Support a consistent API and smart routing for multi-chain stablecoins, and integrate compliant risk gateways for anti-money laundering, suspicious transaction monitoring, and traceability.
  • Shared Economics: Fairly distribute network fees, service fees, and yield returns to ensure that issuers, merchants, wallets, and various service providers all benefit. Support co-branded loyalty programs and yield-sharing, much like co-branded credit cards once "recruited" major merchants.

4. Common Objections and Counterarguments

  • "Credit cards are more convenient, why switch?"

    • This is not about replacement, but "attacking the flanks first." Stablecoins will first build an advantage in underserved segments and among incentive-driven audiences, and then scale their coverage through network aggregation.
  • "Without chargebacks, how are consumers protected?"

    • Functional equivalents can be achieved through escrow, dispute arbitration, and insurance mechanisms. For high-risk categories, a revocable layer and token-gated identity management can be provided.
  • "With regulatory uncertainty, how to scale?"

    • The premise is "compliance-first" issuance and custody. Within clear state or federal frameworks, "do what can be done first." The network layer can be designed for pluggable compliance and geo-fencing, gradually expanding as regulatory clarity improves.
  • "Could card networks retaliate with lower fees?"

    • Stablecoins' core advantage is the new product space created by their programmability and open APIs, not just competing on fees. In cross-border and high-velocity closed-loop scenarios, their structural cost and experience advantages are difficult for card networks to replicate.

5. Verifiable Milestones in 12–24 Months

Over the next 1-2 years, we can expect the following milestones:

  • Experience: The time for a new user to go from zero to making a payment is ≤ 2 minutes; a gas-less experience and automatic cross-chain routing with failure rates and latency comparable to mainstream e-wallets.
  • Ecosystem: ≥ 5 compliant issuers/custody service providers have launched white-label stablecoins; ≥ 50,000 merchants accept them, with ≥ 30% from cross-border or digital goods/services.
  • Economics: The all-in merchant cost of a stablecoin payment (including risk management and redemption) is significantly lower than traditional alternatives in target scenarios; repeat purchases or average order value driven by co-branding/yield-sharing achieve statistical significance.

Conclusion

If stablecoins were to race against bank cards head-on, their chances of winning would be low. But by starting in niche segments, establishing "strongholds" with incentives and relative convenience, and then using an open, neutral, and participant-owned network to standardize, interconnect, and scale these strongholds—this path is not only feasible, but once the network takes shape, it will look like a natural and logical next step in hindsight.

Stablecoins Reshape Cross-Border Payments for Chinese Companies

· 37 min read
Dora Noda
Software Engineer

Stablecoins have emerged as transformative infrastructure for Chinese companies expanding internationally, offering 50-80% cost savings and settlement times reduced from days to minutes. The market reached $300+ billion by October 2025 (up 47% year-to-date), processing $6.3 trillion in cross-border payments over 12 months—equivalent to 15% of global retail cross-border payments. Major Chinese companies including JD.com, Ant Group, and Zoomlion are actively deploying stablecoin strategies through Hong Kong's newly regulated framework, which became effective August 1, 2025. This development comes as China maintains strict crypto restrictions on the mainland while positioning Hong Kong as a compliant gateway, creating a dual-track approach that allows Chinese enterprises to access stablecoin benefits while the government develops the digital yuan (e-CNY) as a strategic alternative.

The shift represents more than technological innovation—it's a fundamental restructuring of cross-border payment infrastructure. Traditional SWIFT transfers cost 6-6.3% of transaction value and take 3-5 business days, leaving approximately $12 billion trapped in-transit globally. Stablecoins eliminate correspondent banking chains, operate 24/7, and settle in seconds for 0.5-3% total cost. For Chinese companies facing capital controls, foreign exchange volatility, and high banking fees, stablecoins offer a pathway to operational efficiency—though one fraught with regulatory complexity, technical risks, and the strategic tension between dollar-backed stablecoins and China's digital currency ambitions.

Understanding stablecoins: types, mechanisms, and market dominance

Stablecoins are cryptocurrencies designed to maintain stable value by pegging to external assets, primarily the US dollar. The sector is dominated by fiat-collateralized models, which hold 99% market share and back each token 1:1 with reserves—typically US Treasury bills, cash, and equivalents. Tether (USDT) leads with $174-177 billion market capitalization (58-68% dominance), followed by Circle's USDC at $74-75 billion (20.5-24.5%). Both experienced explosive 2024 growth: USDT added $45 billion in new issuance (+50% annually), while USDC grew 79% from $24.4 billion to $43.9 billion.

USDT generates significant revenue from yields on its $113+ billion US Treasury holdings, earning $13 billion net profit in 2024 (record-breaking). The company maintains 82,000+ Bitcoin (~$5.5 billion) and 48 metric tons of gold as additional reserves, with a $7+ billion excess buffer. However, transparency remains contentious: Tether has never completed a full independent audit, relying instead on quarterly attestations from BDO. The CFTC fined Tether $42.5 million in 2021 for claims that USDT was fully backed only 27.6% of the time during 2016-2018. Despite controversies, USDT dominates with daily trading volumes consistently exceeding $75 billion—often surpassing Bitcoin and Ethereum combined.

USDC offers stronger transparency through monthly attestations by Deloitte & Touche and detailed CUSIP-level disclosure of Treasury holdings. Circle manages approximately 80% of reserves through BlackRock's government money market fund (USDXX), with 20% in cash at Global Systemically Important Banks (GSIBs). This structure proved both strength and vulnerability: during March 2023's Silicon Valley Bank collapse, Circle's $3.3 billion exposure (8% of reserves) caused USDC to briefly depeg to $0.87 before recovering within four days after federal intervention. The incident demonstrated how traditional banking system risks contaminate stablecoins, triggering cascade effects—DAI depegged to $0.85 due to 40% USDC collateral exposure, causing ~3,400 automatic liquidations worth $24 million on Aave.

Crypto-collateralized stablecoins like DAI (MakerDAO) represent the decentralized alternative, with $5.0-5.4 billion market capitalization. DAI requires over-collateralization—typically 150%+ collateralization ratios—using crypto assets (ETH, WBTC, USDC) locked in smart contracts. When collateral value drops too low, positions automatically liquidate to maintain DAI stability. This model proved resilient during the 2023 banking crisis, maintaining peg while USDC wobbled, but faces capital inefficiency and complexity challenges. MakerDAO is evolving toward "Endgame" plans to scale DAI (rebranding as USDS) to 100 billion supply to compete with Tether.

Algorithmic stablecoins have been largely abandoned following Terra/Luna's catastrophic May 2022 collapse that wiped out $45-60 billion. TerraUST (UST) relied solely on arbitrage with LUNA token without true collateral, offering unsustainable 19.5% APY through Anchor Protocol that required $6 million daily subsidies by April 2022. When large withdrawals triggered runs on May 7, 2022, the death spiral mechanics caused LUNA to mint exponentially while UST fell from $1 to $0.35, then pennies. Research revealed 72% of UST was concentrated in Anchor, wealthier investors exited first with smaller losses, and retail investors who "bought the dip" suffered the most. The Luna Foundation Guard's $480 million Bitcoin reserves proved insufficient to restore the peg, demonstrating fatal flaws in undercollateralized algorithmic models.

Stablecoins maintain their dollar peg through arbitrage mechanisms: when trading above $1, arbitrageurs mint new tokens from issuers at $1 and sell at market price for profit, increasing supply and pushing prices down; when trading below $1, arbitrageurs buy cheap tokens on markets and redeem at issuers for $1, decreasing supply and pushing prices up. This self-stabilizing system works in normal conditions with credible issuer commitment, supplemented by reserve management, redemption guarantees, and collateral liquidation protocols.

Cross-border payment pain points that stablecoins address for Chinese companies

Chinese companies face severe friction in traditional cross-border payments, stemming from high costs, settlement delays, capital controls, and currency volatility. Transaction fees average 6-6.3% of transfer value according to 2024 World Bank data, comprising sending bank fees ($15-$75), multiple intermediary correspondent bank fees ($15-$50 per bank, typically 2-4 banks in payment chain), receiving bank fees ($10-$30), and foreign exchange markups (2-6% above mid-market rate hidden in exchange rates). For a typical $10,000 wire transfer, total costs reach $260-$463 (2.6-4.63%), with international remittances to Sub-Saharan Africa averaging 7.7%.

Settlement times of 3-5 business days create massive working capital inefficiency, with approximately $12 billion trapped in-transit globally at any moment. SWIFT's T+2 to T+3 settlement cycles result from different time zones and banking hours (limited to business hours only), weekend and holiday closures, multiple intermediary banks in payment chains, manual AML/KYC verification processes, batch-based processing systems, and currency conversion requirements. SWIFT data shows approximately 10% of cross-border transactions require correction or fail: 4% cancelled before/on settlement date, 1% cancelled after settlement date, and 5% completed after settlement date.

China's foreign exchange controls create unique challenges under SAFE (State Administration of Foreign Exchange) and PBOC (People's Bank of China) administration. The $5 million threshold requires SAFE approval for all outbound remittances exceeding this amount (reduced from previous $50 million limit). The $50 million ODI threshold means SAFE supervises and can halt ODI projects requiring larger transfers. Pre-payment registration requirements mandate companies register with SAFE within 15 working days of contract signing for advance payments. Companies must report overseas payments with terms exceeding 90 days, and overpayment amounts cannot exceed 10% of prior year's total importation. December 2024 SAFE regulations now require banks to monitor and report crypto-related transactions, specifically targeting illegal cross-border transactions.

Individual restrictions compound challenges: annual foreign currency conversion limits of $50,000 per person, transactions exceeding $10,000 must be reported, and cash transactions exceeding RMB 50,000 (~$7,350) must be reported. Companies report unpredictable approval times from SAFE, with window guidance varying by city and region, creating lack of consistency and uncertain process times that differ by jurisdiction.

Stablecoins dramatically address these pain points through multiple mechanisms. Cost reductions reach 50-80% versus traditional methods: blockchain transaction costs on Ethereum average ~$1 for USDC transfers (down from $12 in 2021), while Layer 2 networks like Base and Arbitrum charge less than $0.01 average, and Solana processes transactions for ~$0.01 with 1-2 second settlement. Total stablecoin fees range 0.5-3.0% of transfer amount compared to 6-6.3% traditional. For a $10,000 transfer, stablecoins cost $111-$235 (1.11-2.35%) versus $260-$463 traditional, yielding net savings of $149-$228 per transaction (49-57% reduction). For companies with $1 million annual cross-border payments, this translates to $30,000-$70,000 annual savings (50-87% reduction).

Speed improvements are even more dramatic: settlement reduced from 3-5 days to seconds or minutes with 24/7/365 availability. Solana achieves 1,133 TPS with 30-second finality; Ethereum processes transactions in 2-5 minutes with 12-confirmation finality (~3 minutes); Layer 2 solutions achieve 1-5 second settlement; and Stellar completes transactions in 3-5 seconds. This eliminates the approximately $1.5 million in capital trapped in-transit at any moment for a company with $10 million monthly cross-border payments. At 5% annual cost of capital, this freed capital provides $75,000 annual benefit, combined with fee savings of $60,000-$80,000 for total annual benefit of $135,000-$155,000 (1.35-1.55% of payment volume).

Stablecoins bypass traditional banking friction through direct wallet-to-wallet transfers requiring no bank intermediaries, eliminating 3-5 intermediary banks in payment chains, circumventing capital controls (blockchain-based transfers harder to restrict than traditional banking flows), reduced AML/KYC friction through smart contract automation and on-chain compliance tools (companies like Chainalysis, Elliptic, TRM Labs provide real-time AML screening), and no pre-funding requirements eliminating need for local currency accounts in multiple jurisdictions. For Chinese companies specifically, stablecoins potentially bypass SAFE approval requirements for smaller transactions, provide faster options than 15-day registration requirements for pre-payments, offer more flexibility than $5 million threshold restrictions, and enable real-time settlement despite capital controls—with Hong Kong serving as gateway through JD.com's Jingdong Coinlink preparing HKD and USD stablecoins.

Volatility mitigation occurs through 1:1 fiat peg with each stablecoin backed by equivalent fiat reserves. USDC's reserve composition includes 85% short-term US Treasuries or repos and 15% cash for immediate liquidity. Instant settlement eliminates multi-day currency risk windows, providing predictability where companies know exact amounts recipients receive. Major stablecoins achieved $250 billion total circulation by 2025 (doubled from $120 billion 18 months prior), with daily velocity of 0.15-0.25 indicating high liquidity and projected growth to $400 billion by end-2025 and $2 trillion by 2028.

Regulatory landscape: China's dual-track approach and global frameworks

China maintains strict crypto restrictions on the mainland while positioning Hong Kong as a regulated gateway, creating a complex dual-track system for Chinese enterprises. In June 2025, full criminalization of cryptocurrency ownership, trading, and mining became effective, expanding the 2021 ban. The August 2024 Supreme People's Court ruling classified using cryptocurrencies to convert criminal proceeds as criminal law violation. December 2024 SAFE regulations require banks to monitor and report crypto-related transactions, specifically targeting illegal cross-border financial activities. Using yuan to buy crypto assets before converting to foreign currencies is now classified as illegal cross-border financial activity, with banks identifying high-risk transactions based on individual identity, fund sources, and trade frequency.

Despite these restrictions, an estimated 59 million Chinese users continue crypto activity through VPNs and offshore platforms, and the Chinese government owns 194,000 BTC (~$18 billion) seized from illicit activities. Stablecoins are viewed as threats to capital controls—prior estimates showed $50 billion left China via crypto/stablecoins in 2020 before the comprehensive ban.

Hong Kong's stablecoin framework provides the compliant pathway. In May 2025, Hong Kong's Legislative Council passed the landmark Stablecoins Bill, allowing licensed entities to issue fiat-backed stablecoins (HKD-pegged and CNH-pegged), effective August 1, 2025. The Hong Kong Monetary Authority (HKMA) oversees licensing and audits, with minimum capital requirements of HK$25 million ($3.2 million), full reserve requirements, monthly attestations, and AML compliance. Over 40 companies applied for licenses, with single digits expected for initial approvals. The first batch of sandbox participants (July 2024) included Jingdong Coinlink Technology (JD.com), Circle Coin Technology, and Standard Chartered Bank.

Chinese firms are actively pursuing Hong Kong licenses: Ant International (Singapore-based unit of Alibaba's Ant Group) is applying for stablecoin licenses in Hong Kong, Singapore, and Luxembourg, focusing on cross-border payment services and supply-chain finance through the Alipay+ global payment network. JD.com is participating in HKMA's stablecoin sandbox, planning to secure "stablecoin licences across key currency markets globally" with initial HKD and USD stablecoins, and potential offshore yuan stablecoin pending PBOC approval.

PBOC Governor Pan Gongsheng's June 2025 remarks at Lujiazui Forum marked a significant policy shift—the first official acknowledgment of stablecoins' positive role, noting they are "reshaping the global payment system" and recognizing shorter cross-border payment cycles. This signals China's evolution from complete ban to controlled experimentation using a "two-zone" approach: experimentation offshore (Hong Kong), control onshore (mainland).

United States regulatory clarity arrived with the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins) signed by President Trump in July 2025. This first comprehensive federal stablecoin legislation defines collateral, disclosure, and marketing rules; creates pathway for bank-issued stablecoins; establishes reserve requirements; and gives the Federal Reserve oversight of large stablecoin issuers with master account access requirements for large-scale operations. The GENIUS Act aims to maintain USD dominance amid China's digital currency challenge and is expected to accelerate institutional entry. State-level regulation continues with multiple states maintaining money transmission licenses for stablecoin issuers, with New York (via NYDFS) particularly active. The June 2024 court ruling (SEC v. Binance) confirmed fiat-backed stablecoins like USDC and BUSD are NOT securities, with the SEC closing investigations (Paxos/BUSD case dropped) and shifting focus away from stablecoins to other crypto assets.

European Union's MiCA (Markets in Crypto-Assets) regulation became effective January 2025, requiring detailed reserve disclosure, licenses for issuers operating in EU, with 18-month transition period (until July 2026) for existing operators. MiCA prohibits interest on stablecoins to discourage use as stores of value and imposes transaction limits: if ARTs exceed 1 million transactions daily or €200 million daily value, issuers must stop new issuances. Circle became the first MiCA-licensed issuer in July 2024, with Tether claiming full compliance.

Asia-Pacific jurisdictions are creating supportive frameworks: Singapore's MAS finalized its framework in August 2023 and actively experiments with tokenized deposits through Project Guardian. Japan regulates stablecoins under the Payment Services Act since June 2022, with JPYC launching as first JPY-pegged stablecoin in August 2025, distinguishing between fiat-backed (regulated) and algorithmic (less regulated). Bahrain's Stablecoin Issuance and Offering Module (July 2025) allows single currency fiat-backed stablecoins while prohibiting algorithmic stablecoins. El Salvador granted Tether stablecoin issuer and DASP licenses in 2024, with Tether establishing headquarters there. Dubai and Hong Kong granted Tether VASP licenses in 2024, with both jurisdictions welcoming stablecoin issuers.

Compliance pathways for Chinese companies require offshore legal structures (Hong Kong subsidiaries being most common), payment service provider partnerships with licensed entities, extensive KYC/AML requirements through automated compliance tools (Chainalysis, Elliptic provide real-time AML screening for blockchain identity solutions), and appropriate licensing based on target markets. Hong Kong's framework allows Chinese companies to operate compliantly while maintaining separation from mainland restrictions, positioning Hong Kong as the primary gateway for China's stablecoin experimentation.

Real-world applications: how Chinese companies use stablecoins

Chinese companies are deploying stablecoins across four major categories: cross-border e-commerce, supply chain finance, international trade settlement, and overseas payroll—with concrete implementations emerging in 2024-2025.

Cross-border e-commerce payment and settlement

JD.com represents the flagship case study. China's second-largest e-commerce company (often called "China's Amazon") established Jingdong Coinlink Technology in Hong Kong, participating in HKMA's stablecoin sandbox since July 2024. Chairman Richard Liu announced in June 2025 that JD.com intends to "secure stablecoin licences across key currency markets globally" with initial HKD-pegged and USD-pegged stablecoins, plus future offshore yuan (CNH) stablecoin pending PBOC approval.

Richard Liu stated JD.com "can reduce the global cross border payment cost by 90% and then improve the efficiency to within ten seconds," hoping "JD stablecoin will become a universal payment method worldwide." CEO Teddy Liu of Jingdong Coinlink declared in June 2025: "I believe stablecoins will become the next-generation payment system – that is beyond doubt." JD.com's initial focus targets B2B payments before consumer adoption, with direct transactions planned with Southeast Asian suppliers using JD stablecoins for minute-level transfers, targeting Asia-Pacific, Middle East, and African markets.

The Chinese seller ecosystem on Amazon and eBay is massive: over 63% of Amazon third-party sellers are from mainland China or Hong Kong, with Shenzhen alone accounting for approximately 25% of all Amazon third-party sellers. China's cross-border e-commerce exports grew 19.6% in 2023, reaching RMB 2.38 trillion ($331 billion). These sellers face 7-15 day payment cycles from Amazon, but stablecoins enable minute-level transfers versus 1-5 days traditional. Stablecoin transaction fees are approximately 1/10th of traditional foreign trade transaction fees.

Jiang Bo, a cross-border payment expert interviewed by 36Kr in 2025, analyzed: "From the customers we have contacted, cross-border e-commerce merchants and enterprises engaged in digital service exports are more willing to try stablecoins, mainly because they see the advantages of stablecoins in terms of efficiency and cost." He noted "The repayment cycle for Amazon merchants is generally 7-15 days. Higher payment efficiency helps ensure stable cash flow and improve the efficiency of capital utilization."

Payment platforms enabling this include Shopify integration with Coinbase Commerce for crypto/stablecoin payments where merchants can accept USDC and USDT globally. TransFi processes over $10 billion in annualized payment volume (300% YoY growth in 2025), supporting local collection and payout across 70+ markets, backed by Circle Ventures and Ripple. Grab in Southeast Asia partnered with Alipay and StraitsX in March 2024, allowing Chinese tourists to pay using Alipay converted to XSGD stablecoin, with merchants receiving Singapore dollars.

Supply chain finance and Belt and Road settlements

Zoomlion Heavy Industry provides the flagship manufacturing case. This construction and agricultural machinery manufacturer with $3.3 billion in offshore revenue (2024) partnered with AnchorX (Hong Kong fintech) to use AxCNH, the first licensed offshore yuan-pegged stablecoin. AxCNH received regulatory license from Astana Financial Services Authority (AFSA) in Kazakhstan and operates on Conflux Network blockchain. Launched at the 10th Belt and Road Summit in Hong Kong in February 2025, Zoomlion completed pilot transactions on Conflux blockchain for cross-border settlements with Belt and Road Initiative (BRI) partners.

The strategic significance is substantial: in 2024, China's trade with BRI countries reached RMB 22.1 trillion ($3.2 trillion), targeting 150+ countries across Asia, Africa, South America, and Oceania. AxCNH provides reduced exchange rate volatility, lower transaction costs, and improved settlement efficiency (minute-level versus days). Lenovo also signed an MOU with AnchorX for AxCNH usage, focusing on supply chain and international settlements. ATAIX Eurasia (Kazakhstan exchange) listed AxCNH with trading pairs AxCNH:KZT and AxCNH:USDT, positioning Kazakhstan as gateway to Central Asia and Europe for BRI trade settlements.

Ant Group/Ant International focuses on cross-border finance and supply chain finance, applying for stablecoin licenses in Hong Kong, Singapore, and Luxembourg. The company completed significant tokenized asset projects: August 2024 partnership with Longshine Technology for renewable energy asset tokenization, and December 2024 GCL Energy Technology solar asset project (RMB 200 million / $28 million). Ant's tokenization model uses stablecoins as settlement layer for tokenized assets, bypassing SWIFT system for asset transactions while providing cash-like, low-volatility investment options.

Standard Chartered Bank formed a joint venture with Animoca Brands for HKD stablecoin, participating in Hong Kong's stablecoin sandbox. As one of three banks authorized to issue physical HKD, Standard Chartered's focus on cross-border B2B payments represents traditional banking's embrace of stablecoin infrastructure.

International trade settlement and B2B transactions

Monthly stablecoin transaction volumes between businesses reached $3 billion+ in early 2025, up from under $100 million at start of 2023. 2024 saw 29.6% increase in crypto payment transaction volume (CoinGate data), with stablecoins accounting for 35.5% of all crypto transactions in 2024 (up from 25.4% in 2023 and 16% in 2022, representing 171% YoY growth 2022-2023 and 26.2% YoY growth 2023-2024).

JD.com's B2B focus prioritizes direct transactions with Southeast Asian suppliers using JD stablecoins for minute-level transfers and supply chain payments before expanding to consumer adoption. Use case categories include: commodity trading using AxCNH for Belt and Road commodity imports; manufacturing settlements with direct supplier payments; treasury management enabling real-time liquidity management across borders; and trade finance through pilot corridors in Hong Kong and Shanghai free trade zones.

Ant Digital Technologies' tokenized renewable energy asset projects use stablecoins as settlement layer, with investors receiving stablecoin-denominated returns while bypassing traditional banking for asset-backed financing. This represents the evolution of trade finance where stablecoins serve as universal settlement layer for tokenized real-world assets.

Overseas employee payroll and contractor payments

General market adoption shows 75% of Gen Z workers prefer receiving at least part of their salary in stablecoins, with Web3 professionals earning average $103,000 annually. USDC holds 63% market share for payroll, USDT 28.6%. Benefits include stablecoin transaction fees of 0.1-1% versus 3.5% credit card fees; speed of minutes versus 3-5 days for international transfers; blockchain-recorded transparency for all transactions; and USD-pegged stablecoins protecting against local currency devaluation.

Rise processed over $800 million in payroll volume, operating across 20+ blockchains with Circle partnership for USDC payments. The platform includes compliance tools through Chainalysis and SumSub integration, issues 1099s, and gathers W9/W8-Ben forms. Deel uses BVNK for stablecoin settlements, paying contractors in 100+ countries with focus on international hiring. Bitwage offers over 10 years experience in crypto payroll, supporting Bitcoin and stablecoin payments as add-on to existing payroll systems.

While specific named Chinese companies using these for payroll remain limited in public reporting, the infrastructure is being built for tech startups in Web3 space, gaming companies with international developers, and e-commerce platforms with global remote teams. Chinese companies with distributed international workforces are increasingly exploring these platforms to reduce remittance costs and improve payment speed for overseas contractors.

Southeast Asian payment corridors

Singapore-China corridor demonstrates practical implementation. StraitsX issues XSGD (Singapore dollar stablecoin) as an MAS-regulated licensed issuer, processing over $8 billion in volume. The real-world application shows Chinese tourists using Alipay to scan GrabPay QR codes, with behind-the-scenes operations where Alipay purchases XSGD and transfers to Grab merchants who receive SGD settlement. Volume data shows 75% of XSGD transfers under $1 million and 25% of transfers under $10,000 (retail activity), with steady $200+ million quarterly transfer value since Q3 2022.

Thailand-Singapore's PromptPay-PayNow connection (since 2021) provides a blueprint: real-time, low-cost mobile payments with daily limit of SGD 1,000 / THB 25,000 ($735/$695) at THB 150 ($4) cost in Thailand and free in Singapore. This represents potential infrastructure for China-ASEAN payment integration with stablecoin layers on top of fast payment systems, supporting Chinese businesses operating in Southeast Asia.

Risks and challenges: regulatory, technical, and operational hazards

Regulatory risks dominate the landscape

China's June 2025 full criminalization of cryptocurrency ownership, trading, and mining creates existential legal risk for mainland entities. Using stablecoins to circumvent capital controls can result in criminal prosecution, with banks required to monitor and report crypto-related transactions. The August 2024 Supreme People's Court ruling classified using cryptocurrencies to convert criminal proceeds as criminal law violation, expanding enforcement beyond trading to include any financial manipulation using crypto.

Chinese entities face extreme difficulty accessing compliant on/off ramps within mainland China due to forex controls. All centralized exchanges were banned since 2017, with OTC trading persisting but carrying legal risks. VPN usage required to access foreign platforms is itself restricted. Yuan-to-crypto conversions are classified as illegal forex activity as of December 2024. Hong Kong provides the legal gateway, but requires extensive KYC/AML compliance, with licensed exchanges operational while maintaining separation from mainland capital controls.

Banking de-risking concerns create operational challenges. US banks increasingly wary of processing crypto-related transactions force issuers to offshore banks. Tether lacks full regulatory oversight with no authoritative body monitoring reserve investments. Circle's $3.3 billion exposure to Silicon Valley Bank demonstrated interconnected risks. Chinese entities face extreme difficulty accessing compliant on/off ramps, with Western banks hesitant to service China-linked crypto entities due to compliance costs for AML/KYC requirements and concerns about facilitating capital control circumvention.

Enforcement actions demonstrate real consequences. Chainalysis estimates $25-32 billion in stablecoins received by illicit actors in 2024 (12-16% of market cap). The UN Office of Drugs and Crime (January 2024) identified stablecoins as preferred currency for cybercriminals in Southeast Asia. $20 billion in Tether transactions through sanctioned Russian exchange Garantex are under investigation, though Tether has frozen $12 million linked to scams through its T3 Financial Crime Unit (2024) and recovered $108.8 million USDT linked to illicit activities.

Technical risks: smart contracts, congestion, and custody

Smart contract vulnerabilities caused massive losses in 2024. According to DeFiHacksLabs data, over 150 contract attack incidents resulted in losses exceeding $328 million in 2024 alone, with $9.11 billion accumulated DeFi losses according to DeFiLlama. Q1 2024 alone saw $45 million in losses across 16 incidents ($2.8 million average per exploit).

The OWASP Smart Contract Top 10 (2025) analyzed $1.42 billion in losses, identifying: Access Control Vulnerabilities ($953.2 million), Logic Errors ($63.8 million), Reentrancy Attacks ($35.7 million), Flash Loan Attacks ($33.8 million), and Price Oracle Manipulation ($8.8 million). High-profile 2024 attacks included Sonne Finance (May 2024) with $20 million exploited via Compound V2 fork vulnerability using flash loans.

Stablecoin-specific vulnerabilities show centralized stablecoins face custodial and regulatory risks, while decentralized stablecoins remain vulnerable to smart contract and oracle issues. DAI experienced depegging when USDC (40% of collateral) depegged in March 2023, demonstrating cascade contagion effects. Algorithmic stablecoins remain fundamentally flawed, as UST collapse demonstrated.

Blockchain congestion creates operational challenges. Ethereum mainnet limited to approximately 15 TPS causes high gas fees during congestion, though Layer 2 solutions (Arbitrum, Optimism) reduce fees but add complexity. Cross-chain bridges create single points of failure—the Ronin hack cost $625 million, Wormhole $325 million. Emerging solutions include Layer 2 adoption accelerating with Base costing under $0.01 versus $44 traditional wire transfer; Solana processing stablecoin transactions in 1-2 seconds at less than $0.01 fees; Circle's CCTP V2 reducing settlement from 15 minutes to seconds; and LayerZero OFT standard enabling seamless multi-chain stablecoin deployment.

Exchange and custody risks remain significant. Concentration of liquidity creates systemic vulnerability—Coinbase temporarily paused USDC redemptions during SVB crisis (March 2023). Private key management is critical with social engineering remaining the top threat. However, multi-party computation (MPC) and hardware security modules (HSM) are improving security, with institutional-grade custody now available through qualified custodians with regulatory oversight. Critically, stablecoin holders have no legal entitlement to instant redemption, being treated as unsecured creditors in bankruptcy with no legal claim to underlying assets.

De-pegging events: catastrophic precedents

TerraUST's May 2022 collapse remains the defining catastrophe. On May 7, 2022, large withdrawals (375 million UST) triggered runs, with an $85 million trade on Curve Finance overwhelming stabilization mechanisms. By May 9, UST fell to $0.35 while LUNA fell from $80 to pennies. Total losses reached $45-60 billion in ecosystem value with $400 billion broader market impact.

Root causes included unsustainable yields with Anchor paying 19.5% APY requiring $6 million daily subsidies by April 2022; algorithmic instability where UST relied solely on LUNA arbitrage without true collateral; death spiral mechanics as panicking UST holders caused LUNA to mint exponentially, diluting value; and liquidity attacks exploiting Curve 3pool vulnerability during planned liquidity migration to 4pool. The concentration risk showed 72% of UST deposited in Anchor, with wealthier investors exiting first with smaller losses while retail investors who "bought the dip" suffered most. Luna Foundation Guard's $480 million Bitcoin reserves proved insufficient to restore peg.

USDC's March 2023 de-pegging from Silicon Valley Bank collapse revealed how traditional banking risks contaminate stablecoins. On March 10, 2023, SVB failure revealed Circle held $3.3 billion (~8% of reserves) with the failed bank. USDC fell to $0.87 (13% depeg) on Saturday March 11, with Coinbase suspending USDC-USD conversions over the weekend when banks were closed. Cascade effects included DAI depegging to $0.85 (40% collateral was USDC), FRAX also affected due to USDC exposure, and approximately 3,400 automatic liquidations on Aave worth $24 million collateral (86% USDC).

Recovery occurred by Monday after FDIC waived $250,000 insurance limit, but S&P Research findings (June 2023) showed USDC was below $0.90 for 23 minutes (longest depeg), DAI below $0.90 for 20 minutes, USDT only dipped below $0.95 for 1 minute, and BUSD never dropped below $0.975. Frequency analysis revealed USDC and DAI depegged far more often than USDT over the 24-month period. Post-crisis, Circle expanded banking partnerships (BNY Mellon, Cross River), increased reserve diversification, and enhanced transparency through monthly attestations.

Tether transparency concerns persist despite its relative stability. Historical problems include 2018 claims of $2.55 billion reserves backing $2.54 billion USDT supported only by law firm report (not audit); 2019 New York Attorney General investigation revealing only 74% backing by cash/equivalents; 2021 CFTC fine of $41 million for false statements about dollar backing; and reserves held for only 27.6% of time during 2016-2018 sample period per CFTC findings.

Current reserve composition (Q2 2024) shows $100 billion+ in U.S. Treasury bonds, 82,000+ Bitcoin (~$5.5 billion value), 48 metric tons of gold, and over $120 billion total reserves with $5.6 billion surplus (Q1 2025). However, discrepancy exists between $120 billion reserves and 150 billion+ USDT circulation. Tether maintains no comprehensive audit from Big Four accounting firm (only quarterly attestations from BDO), with $6.57 billion in "secured loans" (up from $4.7 billion in Q1 2024) having unclear composition. Reliance on offshore banks without authoritative reserve monitoring earned S&P risk rating of 4 out of 5 (December 2023).

Operational challenges: on-ramps, banking, and taxation

Mainland China restrictions make on/off ramps extremely difficult. All centralized exchanges banned since 2017, with OTC trading persisting but carrying legal risks. VPN usage required to access foreign platforms is itself restricted. Yuan-to-crypto conversions classified as illegal forex activity (December 2024). Hong Kong provides gateway through licensed exchanges operational with KYC/AML compliance requirements. AxCNH listed on ATAIX Eurasia (Kazakhstan) targets Chinese firms, with Zoomlion ($3.3 billion offshore revenue) signed to use AxCNH for settlements. PBOC Shanghai center developing cross-border digital payment platform.

Global access challenges include off-ramp liquidity fragmented across 100+ blockchains, cross-chain bridge security concerns following major hacks, weekend/holiday conversion limited by traditional banking hours (SVB crisis example), though Real-Time Payments (RTP) and FedNow may eventually enable 24/7 fiat settlement.

Banking relationships pose correspondent banking issues where Western banks hesitate to service China-linked crypto entities. Compliance costs high due to AML/KYC requirements, with SWIFT dominance at $5 trillion daily versus China's CIPS at $200+ billion processed but growing. Banking relationships essential for institutional-scale stablecoin operations. Institutional solutions emerging include Stripe's $1.1 billion acquisition of Bridge (stablecoin infrastructure) signaling fintech integration, PayPal and SAP offering native stablecoin support, Coinbase and Circle pursuing banking licenses under favorable US regulatory environment, and regional API providers differentiating on compliance and service.

Tax implications and reporting create complexity. Post-June 2025 ban makes crypto tax largely irrelevant for mainland individuals, though previous unreported crypto gains subject to capital gains treatment. Cross-border transactions monitored for capital flight, while Hong Kong provides clearer framework with stablecoin regulatory clarity. International compliance requires FATF Travel Rule adoption by China for international transactions, wallet registration for traceability, Chinese entities using offshore structures facing complex multi-jurisdictional reporting, and capital losses from depegging events requiring classification based on business versus capital treatment.

Central Bank Digital Currency: e-CNY's international push

China's digital yuan (e-CNY) represents the government's strategic alternative to private stablecoins, with massive domestic deployment and expanding international ambitions. As of 2025, the e-CNY achieved 261 million individual wallets opened, $7.3 trillion cumulative transaction value (up from $1 trillion mid-2024), 180 million individual users (July 2024), and operations in 29 cities across 17 provinces, used for metro fares, government wages, and merchant payments.

September 2025 marked a critical inflection point when PBOC inaugurated the International Operations Center in Shanghai with three platforms: a cross-border digital payment platform exploring e-CNY for international transactions; a blockchain service platform providing standardized cross-chain transaction transfers; and a digital asset platform integrating with existing financial infrastructure.

Project mBridge represents wholesale CBDC infrastructure through collaboration with Bank for International Settlements (BIS), with 11+ central banks in trials as of 2024 expanding to 15 new countries in 2025. The 2025 projection targets $500 billion annually through mBridge, with 2030 scenarios suggesting 20-30% of China's foreign trade could use e-CNY rails.

Belt and Road Integration shows ASEAN trade volume in RMB reaching 5.8 trillion yuan, with e-CNY used for oil transactions. The China-Laos Railway and Jakarta-Bandung High-Speed Rail accept e-CNY. UnionPay expanded e-CNY network to 30+ countries with Cambodia and Vietnam focus, targeting the Belt and Road corridor.

China's strategic objectives include countering USD stablecoin dominance (99% of stablecoin activity is dollar-denominated), circumventing SWIFT sanctions potential, enabling offline payments for rural areas and in-flight use, and programmable sovereignty through code-based capital controls and transaction limits.

Challenges remain substantial: yuan represents only 2.88% of global payments (June 2024), down from 4.7% peak (July 2024), with capital controls limiting convertibility. Competition from established WeChat Pay/Alipay (90%+ market share) domestically limits e-CNY adoption enthusiasm. USD still commands 47%+ of global payments with euro at 23%, making yuan internationalization a long-term strategic challenge.

Institutional adoption: projections through 2030

Market growth projections vary widely but all point upward. Conservative estimates from Bernstein project $3 trillion by 2028, Standard Chartered forecasts $2 trillion by 2028, from current $240-250 billion (Q1 2025). Aggressive forecasts include futurist predictions of $10+ trillion by 2030 based on GENIUS Act regulatory clarity, Citi GPS $2 trillion by 2028 potentially higher with corporate adoption, and McKinsey suggesting daily transactions could reach $250 billion in next 3 years.

Transfer volume data shows 2024 reached $27.6 trillion total (exceeding Visa + Mastercard combined), with daily real payment transactions at $20-30 billion (remittances + settlements). Currently representing less than 1% of global money transfer volume but doubling every 18 months, Q1 2025 remittances reached 3% of $200 trillion global cross-border payments.

Banking sector developments include JPMorgan's JPM Coin processing over $1 billion daily in tokenized deposit settlements. Citibank, Goldman Sachs, and UBS experiment via Canton Network. US banks discuss joint stablecoin issuance, with 50%+ of financial institutions reporting stablecoin infrastructure readiness (2025 survey).

Corporate adoption shows Stripe's Bridge acquisition for $1.1 billion signaling fintech integration, PayPal launching PYUSD ($38 million issued January 2025, though slowing), retailers exploring branded stablecoins (Amazon, Walmart predicted 2025-2027), and Standard Chartered launching Hong Kong dollar-pegged stablecoin.

Academic and institutional research shows 60% of institutional investors prefer stablecoins (Harvard Business Review 2024), MIT Digital Currency Initiative conducting active research, 200+ new academic papers on stablecoins published in 2025, and Stanford launching Stablecoin and Digital Assets Lab.

Regulatory evolution and compliance frameworks

United States GENIUS Act impact creates dual role for Federal Reserve as gatekeeper and infrastructure provider. Bank-issued stablecoins anticipated to dominate with compliance infrastructure, tier-2 banks forming consortiums for scale, and regional banks relying on tech stack providers (Fiserv, FIS, Velera). The framework expected to generate $1.75 trillion in new dollar stablecoins by 2028, viewed by China as strategic threat to yuan internationalization, spurring China's accelerated Hong Kong stablecoin framework and support for CNH-pegged stablecoins offshore.

European Union MiCA fully applicable since late 2024, prohibits interest payments limiting adoption (largest EU stablecoin only €200 million versus USDC $60 billion), imposes stringent reserve requirements and liquidity management, with 18-month grace period ending July 2026.

Asia-Pacific frameworks show Singapore and Hong Kong creating supportive frameworks attracting issuers. Hong Kong stablecoin licenses creating compliant CNH-pegged options, Japan regulatory clarity enabling expansion, with 88% of North American firms viewing regulations favorably (2025 survey).

Cross-jurisdictional challenges include the same stablecoin being treated as payment instrument, security, or deposit in different countries. Extraterritorial regulations create compliance complexity, regulatory fragmentation forces issuers to choose markets or adopt complex structures, and enforcement risks persist even without clear guidelines.

Technology improvements: Layer 2 scaling and cross-chain interoperability

Layer 2 scaling solutions dramatically reduce costs and increase speed. Major networks in 2025 include: Arbitrum using high-speed Ethereum scaling via optimistic rollups; Optimism with reduced fees while maintaining Ethereum security; Polygon achieving 65,000 TPS with 28,000+ contract creators, 220 million unique addresses, and $204.83 million TVL; Base (Coinbase L2) with under $0.01 transaction costs; zkSync using zero-knowledge rollups for trustless scaling; and Loopring achieving 9,000 TPS for DEX operations.

Cost reductions are dramatic: Base charges less than $0.01 versus $44 traditional wire; Solana stablecoins achieve 1-2 seconds settlement at less than $0.01 fees; Ethereum gas fees significantly reduced via L2 bundling.

Cross-chain interoperability advances through leading protocols. LayerZero OFT Standard enables Ethena's USDe deployment across 10+ chains with $50 million USD weekly cross-chain volume. Circle CCTP V2 reduces settlement from 15 minutes to seconds. Wormhole and Cosmos IBC move beyond lock-and-mint to message-passing validation. USDe averaged $230 million+ monthly cross-chain volume since inception, while CCTP transferred $3+ billion volume last month.

Bridge evolution moves away from vulnerable "lock-and-mint" models toward light-client validation and message-passing, with native interoperability becoming standard rather than optional. Stablecoin issuers leverage protocols to reduce operational costs. Market impact shows stablecoin transactions across Layer 2s growing rapidly, with USDC on Arbitrum facilitating major Uniswap markets. Binance Smart Chain and Avalanche run major fiat-backed tokens. The multi-chain reality means stablecoins must be natively interoperable for success.

Expert predictions and industry outlook

McKinsey insights suggest "2025 may witness material shift across payments industry," with stablecoins transcending banking hours and global borders. True scaling requires paradigm shift from currency settlement to stablecoin retention, with financial institutions needing to integrate or risk irrelevance.

Citi GPS predicts "2025 will be blockchain's ChatGPT moment" with stablecoins igniting transformation. Issuance jumped from $200 billion (early 2025) to $280 billion (mid-2025), with institutional adoption accelerating through company listings and record fundraising.

Fireblocks 2025 survey found 90% of firms taking action on stablecoins today, with 48% citing speed as top benefit (cost cited last), 86% reporting infrastructure readiness, and 9 in 10 saying regulations drive adoption.

Regional insights show Latin America at 71% using stablecoins for cross-border payments (highest globally), Asia with 49% citing market expansion as primary driver, North America with 88% viewing regulations as green light rather than barrier, and Europe with 42% citing legacy risks and 37% demanding safer rails.

Security focus reveals 36% say better protection will drive scale, 41% demand speed, 34% require compliance as non-negotiable, with real-time threat detection becoming essential and enterprise-grade security fundamental to scaling.

Expert warnings from Atlantic Council's Ashley Lannquist highlight network transaction fees often overlooked, fragmentation of money across multiple stablecoins, wallet compatibility issues, bank deposit/liquidity challenges, and lack of legal entitlement to reserves (unsecured creditors).

Academic perspectives include Stanford's Darrell Duffie noting e-CNY enables Chinese surveillance of foreign businesses, Harvard research revealing TerraUST collapse information asymmetries where wealthy exited first, and Federal Reserve analysis showing algorithmic stablecoins as fundamentally flawed designs.

Timeline predictions for 2025-2027 include GENIUS Act framework solidifying corporate adoption, major retailers launching branded stablecoins, traditional payment companies pivoting or declining, and banking deposits beginning to flee to yield-bearing stablecoins. For 2027-2030: emerging markets achieving mass stablecoin adoption, energy and commodity tokenization scaling globally, universal interoperability creating unified global payment system, and AI-driven commerce emerging at massive scale. For 2030-2035: programmable money enabling impossible business models, complete payment system transformation, and stablecoins potentially reaching $10+ trillion in aggressive scenarios.

Strategic implications for Chinese cross-border business

Chinese companies face a complex calculus in adopting stablecoins for international expansion. The technology delivers undeniable benefits: 50-80% cost savings, settlement times reduced from days to minutes, 24/7 liquidity, and elimination of correspondent banking friction. Major Chinese enterprises including JD.com ($74-75 billion target for its stablecoins), Ant Group (applying across three jurisdictions), and Zoomlion ($3.3 billion offshore revenue using AxCNH) demonstrate real-world viability through Hong Kong's regulatory framework.

However, risks remain substantial. China's June 2025 full criminalization of crypto creates existential legal exposure for mainland operations. The March 2023 USDC depeg to $0.87 and May 2022 TerraUST collapse ($45-60 billion lost) demonstrate catastrophic potential. Tether's opacity—never completing a full independent audit, only backed 27.6% of time during 2016-2018 per CFTC, though now holding $120+ billion reserves—poses systemic concerns. Smart contract vulnerabilities caused $328+ million in 2024 losses alone, with over 150 attack incidents.

The dual-track approach China has adopted—strict mainland prohibition with Hong Kong experimentation—creates a viable pathway. PBOC Governor Pan Gongsheng's June 2025 acknowledgment that stablecoins are "reshaping the global payment system" signals policy evolution from complete rejection to strategic engagement. Hong Kong's August 1, 2025 effective stablecoin framework provides legal infrastructure for CNH-pegged stablecoins targeting Belt and Road trade ($3.2 trillion annually).

Yet the geopolitical dimension cannot be ignored. The US GENIUS Act aims to "maintain USD dominance amid China's digital currency challenge," generating an expected $1.75 trillion in new dollar stablecoins by 2028. Ninety-nine percent of current stablecoin activity is dollar-denominated, extending American monetary hegemony into digital finance. China's response—accelerating e-CNY international expansion through Project mBridge ($500 billion target for 2025, 20-30% of Chinese trade by 2030)—represents strategic competition where stablecoins serve as proxies for currency influence.

For Chinese enterprises, the strategic recommendations are:

First, utilize Hong Kong-licensed operations exclusively for legal compliance, avoiding mainland exposure to criminal liability. JD.com, Ant Group, and Standard Chartered's participation in HKMA's sandbox demonstrates this pathway's viability.

Second, diversify across multiple stablecoins (USDC, USDT, potentially AxCNH) to avoid concentration risk, maintaining 10-15% reserves in fiat as contingency for depegging events. The SVB crisis demonstrated cascade effects where 40% USDC collateral exposure caused DAI to depeg to $0.85.

Third, implement robust custody solutions with qualified custodians using multi-party computation (MPC) and hardware security modules (HSM), recognizing that stablecoin holders are unsecured creditors with no legal claim to reserves in bankruptcy.

Fourth, monitor e-CNY international expansion as the primary long-term strategic option. The September 2025 PBOC International Operations Center in Shanghai with cross-border digital payment platform, blockchain service platform, and digital asset platform represents state-backed infrastructure that will ultimately receive government preference over private stablecoins for Chinese companies.

Fifth, maintain contingency plans recognizing regulatory uncertainty. The same technology treated as payment instrument in Singapore may be deemed security in one US state and deposit in another, creating enforcement risks even without clear guidelines.

The 2025-2027 period represents a critical window as the GENIUS Act framework solidifies, MiCA's 18-month transition period ends (July 2026), and Hong Kong's licensing regime matures. Chinese companies that establish compliant stablecoin capabilities now—through proper legal structures, qualified custody, diversified banking relationships, and real-time compliance monitoring—will capture first-mover advantages in efficiency gains while the 90% of firms globally "taking action" on stablecoins reshape cross-border payment infrastructure.

The fundamental tension between dollar-backed stablecoins extending US monetary hegemony and China's digital yuan ambitions will define the next decade of international finance. Chinese companies navigating this landscape must balance immediate operational benefits against long-term strategic alignment, recognizing that today's efficiency gains through USDC and USDT may tomorrow face policy reversal if geopolitical tensions escalate. The Hong Kong gateway—with CNH-pegged stablecoins for Belt and Road trade and eventual e-CNY integration—offers the most sustainable path for Chinese enterprises seeking to modernize cross-border payments while remaining aligned with national strategy.

Stablecoins are not merely a technological upgrade to SWIFT—they represent a fundamental restructuring of global payment architecture where programmable money, 24/7 settlement, and blockchain transparency create entirely new business models. Chinese companies that master this infrastructure through compliant pathways will thrive in the next era of international commerce, while those that ignore these developments risk competitive obsolescence as the rest of the world settles transactions in seconds for fractions of traditional costs.

Solana's Vision to Revolutionize Global Securities Markets

· 36 min read
Dora Noda
Software Engineer

Solana is pursuing an ambitious strategy to capture a significant share of the $270 trillion global securities market through breakthrough technical infrastructure that enables instant settlement, sub-cent transaction costs, and 24/7 trading. Max Resnick, the Lead Economist at Anza who joined from Ethereum's ConsenSys in December 2024, has emerged as the chief architect of this vision, declaring that "trillions of dollars in securities are coming to Solana whether we like it or not." His economic frameworks—including Multiple Concurrent Leaders (MCL), the Alpenglow consensus protocol achieving 100-130 millisecond finality, and Application-Controlled Execution (ACE)—provide the theoretical foundation for what he calls a "decentralized NASDAQ" that can outcompete traditional exchanges on price quality and execution speed. Early implementations are already live: 55+ tokenized U.S. equities trade continuously on Solana through Backed Finance's xStocks platform, Franklin Templeton's $594 million money market fund operates natively on the network, and Apollo Global Management's $109.74 million credit fund demonstrates institutional confidence in the platform's compliance capabilities.

The market opportunity is substantial yet often mischaracterized. While advocates cite a $500 trillion securities market, verified data shows the global market for publicly traded equities and bonds totals approximately $270 trillion—still representing one of the largest addressable markets in financial history. McKinsey projects tokenized securities will grow from roughly $31 billion today to $2 trillion by 2030, with more aggressive estimates reaching $18-19 trillion by 2033. Solana's technical advantages position it to capture 20-40% of this emerging market through a unique combination of performance (65,000+ transactions per second), economic efficiency ($0.00025 per transaction versus $10-100+ on Ethereum), and the composability benefits of public blockchain infrastructure that private enterprise solutions cannot match.

Resnick's economic architecture for market microstructure dominance

Max Resnick joined Anza on December 9, 2024, bringing credentials from MIT (Master's in Economics) and experience as Head of Research at ConsenSys subsidiary Special Mechanisms Group. His move from Ethereum to Solana sent shockwaves through the crypto industry, with many viewing it as validation of Solana's superior technical approach. Resnick had been ranked among the top 40 most influential voices in crypto on Twitter/X, making his decision particularly notable. In announcing his transition, he stated simply: "There's just so much more possibility and potential energy in Solana."

At Solana's Accelerate conference in New York City on May 19-23, 2025, Resnick delivered a keynote presentation outlining Solana's path to becoming a decentralized NASDAQ. He emphasized that "from day one, [Solana] was designed to compete with the New York Stock Exchange, with NASDAQ, with the CME, with all these centralized venues that are getting tons and tons of volume." Resnick argued that Solana was never meant to compete with Ethereum, stating: "Solana has always had its sights much higher." He provided specific performance benchmarks to illustrate the challenge: Visa processes approximately 7,400 transactions per second, NASDAQ handles roughly 70,000 TPS, while Solana was achieving about 4,500 TPS as of May 2025 with ambitions to exceed centralized exchange capabilities.

The core of Resnick's economic analysis centers on market spread—the difference between the highest buy order and lowest sell order. In traditional and current crypto markets, this spread is determined by market makers balancing their expected revenue from trading with uninformed traders against losses from informed traders. The critical bottleneck Resnick identified is that market makers on centralized exchanges win the race to cancel stale orders only 13% of the time, and even less frequently on Solana with Jito auctions. This forces market makers to widen spreads to protect themselves from adverse selection, ultimately delivering worse prices to traders.

Resnick's solution involves implementing Multiple Concurrent Leaders, which would prevent single leader censorship and enable "cancels before takes" ordering policies. He articulated the logical chain in his co-authored blog post "The Path to Decentralized Nasdaq" published May 8, 2025: "To outcompete with Nasdaq we need to offer better prices than Nasdaq. To offer better prices than Nasdaq we need to give applications more flexibility to sequence cancellations before takes. To give applications that flexibility we need to ensure that leaders don't have the power to unilaterally censor orders. And to ensure that leaders do not have that power we need to ship multiple concurrent leaders." This framework introduces a novel fee structure where inclusion fees are paid to validators who include transactions, while ordering fees are paid to the protocol (and burned) to merge blocks from concurrent leaders.

Technical infrastructure designed for institutional-scale securities trading

Solana's architecture delivers performance metrics that fundamentally distinguish it from competitors. The network currently processes 400-1,000+ sustained user transactions per second, with peaks reaching 2,000-4,700 TPS during high demand periods. Block time runs at 400 milliseconds, enabling near-instantaneous user confirmation. The network achieved full finality in 12.8 seconds as of 2024-2025, but the Alpenglow consensus protocol—which Resnick helped develop—targets finality of 100-150 milliseconds by 2026. This represents a roughly 100-fold improvement and would make Solana 748,800 times faster than the traditional T+1 settlement standard recently adopted in U.S. securities markets.

The cost structure proves equally transformative. Base transaction fees on Solana amount to 5,000 lamports per signature, translating to approximately $0.0005 when SOL trades at $100, or $0.001 at $200. Average user transactions including priority fees cost around $0.00025. This contrasts starkly with traditional securities settlement infrastructure, where post-trade processing costs the industry an estimated $17-24 billion annually according to Broadridge, with per-transaction costs ranging from $5 to $50 depending on complexity. Solana's fee structure represents a 99.5-99.995% cost reduction compared to traditional systems, enabling previously impossible use cases like fractional share trading, micro-dividend distributions, and high-frequency portfolio rebalancing for retail investors.

Settlement speed advantages extend beyond simple transaction confirmation. Traditional securities markets operate on a T+1 (trade date plus one business day) settlement cycle in the United States, recently shortened from T+2. This creates a 24-hour counterparty risk exposure window, requires significant collateral for margin, and restricts trading to market hours approximately 6.5 hours per weekday. Solana enables T+0 or instant settlement with atomic delivery-versus-payment transactions that eliminate counterparty risk entirely. Markets can operate 24/7/365 without the artificial constraints of traditional market infrastructure, and capital efficiency improves dramatically when participants don't need to maintain two-day float periods requiring extensive collateral arrangements.

Anza, the Solana Labs spinout responsible for the Agave validator client, has been instrumental in building this technical foundation. The Agave client, written in Rust and available at github.com/anza-xyz/agave, represents the most widely deployed Solana validator implementation. Anza released Solana Web3.js 2.0 in September 2024, delivering 10x faster cryptographic operations using native Ed25519 APIs and modernized architecture for institutional-grade applications. The firm's development of Token Extensions (Token-2022 Program) provides protocol-level compliance features specifically designed for regulated securities, including transfer hooks that execute custom compliance checks, permanent delegate authority for lawful court orders and asset seizure, confidential transfers using zero-knowledge proofs, and pausable configurations for regulatory requirements or security incidents.

Network reliability has improved substantially from early challenges. Solana maintained 100% uptime for 16-18 consecutive months from February 6, 2024, through mid-2025, with the last major outage lasting 4 hours 46 minutes due to a bug in the LoadedPrograms function. This represents dramatic improvement from 2021-2022 when the network experienced multiple outages during its rapid scaling phase. The network now operates with 966 active validators, a Nakamoto Coefficient of 20 (an industry-leading decentralization metric), and approximately $96.71 billion in total stake as of 2024. Transaction success rates improved from 42% in early 2024 to 62% by the first half of 2025, with block production skip rates below 0.3% indicating near-flawless validator performance.

Alpenglow consensus and the Internet Capital Markets roadmap

Resnick played a central role in developing Alpenglow, described by The Block as "not only a new consensus protocol, but the biggest change to Solana's core protocol since, well, ever." The protocol achieves actual finality in approximately 150 milliseconds median, with some transactions finalizing as fast as 100 milliseconds—what Resnick called "an unbelievably low number for a world-wide L1 blockchain protocol." The innovation involves running consensus on many different blocks simultaneously, with the goal of producing a new block or set of blocks from multiple concurrent leaders every 20 milliseconds. This means Solana can compete with Web2 infrastructure in terms of responsiveness, making blockchain technology viable for entirely new categories of applications demanding real-time performance.

The broader strategic vision crystallized in the "Internet Capital Markets Roadmap" published July 24, 2025, which Resnick co-authored with Anatoly Yakovenko (Solana Labs), Lucas Bruder (Jito Labs), Austin Federa (DoubleZero), Chris Heaney (Drift), and Kyle Samani (Multicoin Capital). This document articulated the concept of Application-Controlled Execution (ACE), defined as "giving smart contracts millisecond-level control over their own transaction ordering." The roadmap emphasized that "Solana should host the world's most liquid markets, not the markets with the highest volume"—a subtle but important distinction focusing on price quality and execution efficiency rather than raw transaction counts.

The implementation timeline divides into short, medium, and long-term initiatives. Short-term solutions implemented within 1-3 months included Jito's Block Assembly Marketplace (BAM) launched in July 2025, transaction landing improvements, and achievement of p95 0-slot transaction latency. Medium-term solutions spanning 3-9 months involve DoubleZero, a dedicated fiber network reducing latency by up to 100 milliseconds; the Alpenglow consensus protocol achieving approximately 150ms finality; and Async Program Execution (APE), which removes execution replay from the critical path. Long-term solutions targeted for 2027 include full MCL implementation, protocol-enforced ACE, and leveraging geographic decentralization advantages.

Resnick argued that geographic decentralization provides unique informational advantages impossible in colocated systems. Traditional exchanges cluster all their servers in single locations like data centers in New Jersey for proximity to market makers. When the Japanese government announces loosening of trade restrictions on American cars, the geographic distance between Tokyo and New Jersey delays information about the market's reaction by over 100 milliseconds before reaching American validators. With geographic decentralization and multiple concurrent leaders, Resnick theorized that "information from around the world could theoretically be fed into the system during the same 20ms execution tick," enabling simultaneous incorporation of global market-moving information rather than sequential processing based on physical proximity to exchange infrastructure.

Regulatory engagement through Project Open and SEC dialogue

The Solana Policy Institute, a Washington D.C.-based non-partisan nonprofit founded in 2024 and led by CEO Miller Whitehouse-Levine, submitted a comprehensive regulatory framework to the SEC's Crypto Task Force on April 30, 2025, with follow-up letters on June 17, 2025. This "Project Open" initiative proposed an 18-month pilot program for tokenized securities trading on public blockchains, specifically featuring "Token Shares"—SEC-registered equity securities issued as digital tokens on Solana that would enable 24/7 trading with instant T+0 settlement.

Key participants in Project Open include Superstate Inc. (SEC-registered transfer agent and registered investment advisor), Orca (decentralized exchange), and Phantom (wallet provider with 15 million+ monthly active users and $25 billion in custody). The framework argues that SEC-registered transfer agents should be permitted to maintain ownership records on blockchain infrastructure, includes KYC/AML requirements at the wallet level, and contends that decentralized automated market makers should not be classified as exchanges, brokers, or dealers under existing securities laws. The core argument positions decentralized protocols as fundamentally different from traditional intermediaries: they eliminate the brokers, clearinghouses, and custodians that existing securities laws were designed to regulate, therefore requiring new regulatory classification approaches rather than forced compliance with frameworks designed for intermediated systems.

Solana has faced its own regulatory challenges. In June 2023, the SEC labeled SOL as a security in lawsuits against Binance and Coinbase. The Solana Foundation publicly disagreed with this characterization on June 10, 2023, emphasizing that SOL functions as a utility token for network validation rather than a security. The regulatory landscape shifted substantially in 2025 with more favorable approaches to crypto regulation under revised SEC leadership, though multiple Solana ETF applications remain pending with approval odds estimated at approximately 3% as of early 2025. However, the SEC raised compliance concerns over staking-based ETFs, creating ongoing uncertainty around certain product structures.

On June 17, 2025, four separate legal frameworks were submitted to the SEC as part of the Project Open coalition. The Solana Policy Institute argued that validators on the Solana network do not trigger securities registration requirements. Phantom Technologies contended that non-custodial wallet software does not require broker-dealer registration since wallets are user-controlled tools rather than intermediaries. Orca Creative maintained that AMM protocols should not be classified as exchanges, brokers, dealers, or clearing agencies because they are autonomous, non-custodial systems that are user-directed rather than intermediated. Superstate outlined a path for SEC-registered transfer agents to use blockchain for ownership records, demonstrating how existing regulatory frameworks can accommodate blockchain innovation without requiring entirely new legislation.

Miller Whitehouse-Levine characterized the initiative's significance: "Project Open has the potential to unlock transformative change for capital markets, enabling billions in traditional assets including stocks, bonds, and funds to trade 24/7 with instant settlement, dramatically lower costs, and unprecedented transparency." The coalition remains open to additional industry participants joining the pilot framework, inviting market makers, protocols, infrastructure providers, and issuers to collaborate on the regulatory framework design with ongoing SEC feedback.

Token Extensions provide native compliance infrastructure for securities

Launched in January 2024 and developed in collaboration with large financial institutions, Token Extensions (Token-2022 Program) provides protocol-level compliance features that distinguish Solana from competitors. These extensions underwent security audits by five leading firms—Halborn, Zellic, NCC, Trail of Bits, and OtterSec—ensuring institutional-grade security for regulated securities applications.

Transfer Hooks execute custom compliance checks on every transfer and can revoke non-permissible transfers in real-time. This enables automated KYC/AML verification, investor accreditation checks, geographic restrictions for Regulation S compliance, and lock-up period enforcement without requiring off-chain intervention. Permanent Delegate authority allows designated addresses to transfer or burn tokens from any account without user permission, a critical requirement for lawful court orders, regulatory asset seizure, or forced corporate action execution. Pausable Config provides emergency pause functionality for regulatory requirements or security incidents, ensuring issuers maintain control over their securities in crisis situations.

Confidential Transfers represent a particularly sophisticated feature, using zero-knowledge proofs to mask token balances and transfer amounts with ElGamal encryption while maintaining auditability for regulators and issuers. An April 2025 upgrade introduced Confidential Balances, an enhanced privacy framework with ZK-powered encrypted token standards specifically designed for institutional compliance requirements. This preserves commercial privacy—preventing competitors from analyzing trading patterns or portfolio positions—while ensuring regulatory authorities retain necessary oversight capabilities through auditor keys and designated disclosure mechanisms.

Additional extensions support securities-specific requirements: Metadata Pointer links tokens to issuer-hosted metadata for transparency; Scaled UI Amount Config handles corporate actions like stock splits and dividends programmatically; Default Account State enables efficient blocklist management through sRFC-37; and Token Metadata stores on-chain name, symbol, and issuer details. Institutional adoption has already begun, with Paxos implementing USDP stablecoin using Token Extensions, GMO Trust planning a regulated stablecoin launch, and Backed Finance leveraging the framework for xStocks implementation of 55+ tokenized U.S. equities.

The compliance architecture supports wallet-level KYC through transfer hooks that verify identity before permitting token transfers, allowlisted wallets through Default Account State extension, and private RPC endpoints for institutional privacy requirements. Some implementations like Deutsche Bank's DAMA (Digital Asset Management Access) project utilize Soulbound Tokens—non-transferable identity tokens tied to wallets that enable KYC verification without repeated personal information submission, allowing access to DeFi services with verified identity credentials. On-chain investor registries maintained by SEC-registered transfer agents create automated compliance checks on all transactions with detailed audit trails for regulatory reporting, satisfying both blockchain's transparency benefits and traditional finance's regulatory requirements.

Real-world implementations demonstrate institutional confidence

Franklin Templeton, managing $1.5-1.6 trillion in assets, added Solana support for its Franklin OnChain U.S. Government Money Fund (FOBXX) on February 12, 2025. With a $594 million market capitalization making it the third-largest tokenized money market fund, FOBXX invests 99.5% in U.S. government securities, cash, and fully collateralized repurchase agreements, delivering an annual yield of 4.55% APY as of February 2025. The fund maintains a stable $1 share price similar to stablecoins and was the first tokenized money fund natively issued on blockchain infrastructure. Franklin Templeton had previously launched the fund on Stellar in 2021, then expanded to Ethereum, Base, Aptos, Avalanche, Arbitrum, and Polygon before adding Solana, demonstrating multi-chain strategy while Solana's inclusion validates its institutional readiness.

The firm's commitment to Solana deepened with the February 10, 2025, registration of Franklin Solana Trust in Delaware, indicating plans for a Solana ETF. Franklin Templeton had successfully launched Bitcoin ETF in January 2024 and Ethereum ETF in July 2024, establishing expertise in crypto asset management products. The company is also seeking SEC approval for a Crypto Index ETF. Senior executives publicly expressed interest in Solana ecosystem development as early as Q4 2023, making the subsequent FOBXX integration a logical progression of their blockchain strategy.

Apollo Global Management, with $730+ billion in assets under management, announced partnership with Securitize on January 30, 2025, to launch the Apollo Diversified Credit Securitize Fund (ACRED). This tokenized feeder fund invests in the Apollo Diversified Credit Fund, implementing a multi-asset strategy across corporate direct lending, asset-backed lending, performing credit, dislocated credit, and structured credit. Available on Solana, Ethereum, Aptos, Avalanche, Polygon, and Ink (Kraken's Layer-2), the fund requires a $50,000 minimum investment limited to accredited investors, with access exclusively via Securitize Markets, an SEC-regulated broker-dealer.

ACRED represents Securitize's first integration with Solana blockchain and the first tokenized fund available for DeFi integration on the platform. Integration with Kamino Finance enables leveraged yield strategies through "looping"—borrowing against fund positions to amplify exposure and returns. The fund's market capitalization reached approximately $109.74 million as of August 2025, with daily NAV pricing and native on-chain redemptions providing liquidity mechanisms. Management fees run at 2% with 0% performance fees, competitive with traditional private credit fund structures. Christine Moy, Apollo Partner and former JPMorgan blockchain lead who pioneered Intraday Repo, stated: "This tokenization not only provides an on-chain solution for Apollo Diversified Credit Fund, but also could pave the way for broader access to private markets through next generation product innovation." Early investors including Coinbase Asset Management and Kraken demonstrated crypto-native institutional confidence in the structure.

xStocks platform enables 24/7 trading of U.S. equities

Backed Finance launched xStocks on June 30, 2025, creating the most visible implementation of Resnick's vision for tokenized equities. The platform offers over 60 U.S. stocks and ETFs on Solana, each backed 1:1 by real shares held with regulated custodians. Available to non-U.S. persons only, securities carry tickers ending in "x"—AAPLx for Apple, NVDAx for Nvidia, TSLAx for Tesla. Major stocks available include Apple, Microsoft, Nvidia, Tesla, Meta, Amazon, and the S&P 500 ETF (SPYx). The product launched with 55 initial offerings and has since expanded.

The compliance framework leverages Solana Token Extensions for programmable regulatory controls. Corporate actions are handled via Scaled UI Amount Config, pause and transfer controls operate through Pausable Config and Permanent Delegate, regulatory freeze-and-seize functionality provides law enforcement capabilities, blocklist management executes via Transfer Hook, Confidential Balances framework stands initialized but disabled, and on-chain metadata ensures transparency. This architecture satisfies regulatory requirements while maintaining the efficiency and composability benefits of public blockchain infrastructure.

Distribution partners on launch day demonstrated ecosystem coordination. Centralized exchanges Kraken and Bybit offered xStocks to users in 185+ countries, while DeFi protocols including Raydium (primary automated market maker), Jupiter (aggregator), and Kamino (collateral pools) provided decentralized trading and lending infrastructure. Wallets Phantom and Solflare incorporated native display support. The "xStocks Alliance" comprising Backed, Kraken, Bybit, Solana, AlchemyPay, Chainlink, Kamino, Raydium, and Jupiter coordinated the ecosystem-wide launch.

Market traction exceeded expectations. In the first six weeks, xStocks generated $2.1 billion in cumulative volume across all venues, with approximately $500 million on-chain DEX volume. By August 11, 2025, xStocks captured roughly 58% of global tokenized stock trading, with Solana holding majority market share at $46 million of the total $86 million tokenized stock market. On-chain DEX activity surpassed $110 million in the first month, demonstrating substantial organic demand for 24/7 securities trading.

Features include continuous trading versus traditional market hours, instant T+0 settlement versus T+2 in traditional markets, fractional ownership with no minimum investment requirements, self-custody in standard Solana wallets, zero management fees, and composability with DeFi protocols for collateral, lending, and automated market maker liquidity pools. Dividends automatically reinvest into token balances, streamlining corporate action handling. Chainlink provides dedicated data feeds for prices and corporate actions, ensuring accurate valuation and automated event processing. The platform demonstrates that tokenized equities can achieve meaningful adoption and liquidity when technical infrastructure, regulatory compliance, and ecosystem coordination align effectively.

Opening Bell platform targets native blockchain securities issuance

Superstate, an SEC-registered transfer agent and registered investment advisor known for USTB ($650 million tokenized Treasury fund) and USCC (crypto basis fund), launched the Opening Bell platform on May 8, 2025—the same day Resnick and Yakovenko published "The Path to Decentralized Nasdaq." The platform enables SEC-registered public equities to be issued and traded directly on blockchain infrastructure, initially on Solana with planned expansion to Ethereum.

SOL Strategies Inc. (formerly Cypherpunk Holdings), a Canadian public company trading on CSE under ticker HODL and OTCQB as CYFRF, signed a memorandum of understanding on April 25, 2025, to become the first issuer. The company focuses on Solana ecosystem infrastructure and held 267,151 SOL tokens as of March 31, 2025. SOL Strategies is exploring Nasdaq uplisting with dual-market presence and seeking to become the first public issuer via blockchain-based equity, positioning itself as a pioneer in the convergence of traditional public markets and crypto-native infrastructure.

Forward Industries Inc. (NASDAQ: FORD), the largest Solana-focused treasury company, announced partnership on September 21, 2025. Forward holds over 2 million SOL tokens valued above $400 million when SOL exceeds $200, accumulated through a $1.65 billion PIPE financing—the largest Solana treasury financing to date. Strategic backers including Galaxy Digital, Jump Crypto, and Multicoin Capital subscribed over $350 million to the offering. Forward is taking an equity stake in Superstate, aligning incentives for joint product development and platform success. Kyle Samani, Forward Industries Chairman, stated: "This partnership reflects the continued execution of our vision to make Forward Industries an on-chain-first company, including tokenizing our equity directly on the Solana mainnet."

The platform architecture enables SEC-registered shares to trade as native blockchain tokens through direct issuance without synthetic or wrapped versions. This creates programmable securities with smart contract functionality, eliminates reliance on centralized exchanges, provides real-time settlement via blockchain infrastructure, enables continuous 24/7 trading, and ensures interoperability with DeFi protocols and crypto wallets. Superstate's registration as a digital transfer agent with the SEC in 2025 establishes the legal framework for full compliance with SEC registration and disclosure requirements while operating under existing securities laws rather than requiring new legislation. Robert Leshner, Superstate CEO and Compound Finance founder, characterized the vision: "Through Opening Bell, stock will become fully transferrable, programmable, and integrated into DeFi."

The target market includes public companies seeking crypto-native capital markets, late-stage startups wanting to tokenize equity instead of launching separate utility tokens, and institutional and retail investors preferring blockchain wallets over traditional brokerages. This addresses a fundamental inefficiency in current markets where companies must choose between traditional IPOs with extensive intermediaries or crypto token launches with unclear regulatory status. Opening Bell offers a path to SEC-compliant public securities that operate with blockchain's efficiency, programmability, and composability advantages while maintaining regulatory legitimacy and investor protections.

Competitive positioning against Ethereum and private blockchains

Solana's 65,000+ transactions per second capacity compares to Ethereum's 15-30 TPS on the base layer, even when including all 140+ Layer-2 solutions and sidechains bringing combined Ethereum ecosystem throughput to approximately 300 TPS. Transaction costs reveal even starker differences: Solana's $0.00025 average versus Ethereum's $10-100+ during congestion periods represents a 40,000-400,000x cost advantage. Finality times of 12.8 seconds currently and 100-150 milliseconds with Alpenglow contrast with Ethereum's 12+ minutes for economic finality. This performance gap matters critically for securities use cases involving frequent trading, portfolio rebalancing, dividend distributions, or high-frequency market making.

The economic implications extend beyond simple cost savings. Solana's sub-cent transaction fees enable fractional share trading (trading 0.001 shares becomes economically viable), micro-dividend distributions that automatically reinvest small amounts, high-frequency rebalancing that continuously optimizes portfolios, and retail access to institutional products without prohibitive per-transaction costs eating into returns. These capabilities simply cannot exist on higher-cost infrastructure—a $10 transaction fee makes a $5 investment nonsensical, effectively excluding retail participants from many financial products and strategies.

Ethereum maintains significant strengths including first-mover advantage in smart contracts, the most mature DeFi ecosystem with over $100 billion in total value locked, a proven security track record with the strongest decentralization metrics, widely adopted ERC token standards, and the Enterprise Ethereum Alliance fostering institutional adoption. Layer-2 scaling solutions like Optimism, Arbitrum, and zkSync improve performance substantially. Ethereum currently dominates tokenized treasuries, holding essentially $5 billion of the $5+ billion tokenized treasury market as of early 2025. However, Layer-2 solutions add complexity, still face higher costs than Solana, and fragment liquidity across multiple networks.

Private blockchains including Hyperledger Fabric, Quorum, and Corda offer faster performance than public chains when using limited validator sets, provide privacy control through permissioned access, simplify regulatory compliance in closed networks, and offer institutional comfort with centralized control. However, they suffer critical weaknesses for securities markets: lack of interoperability prevents connection with the public DeFi ecosystem, limited liquidity results from isolation from broader crypto markets, centralization risk creates single points of failure, composability limitations prevent integration with stablecoins, decentralized exchanges, and lending protocols, and trust requirements force participants to rely on central authorities rather than cryptographic verification.

Franklin Templeton's public statements reveal institutional perspective shifting away from private solutions. The firm stated: "Private blockchains will fade next to fast-innovating public utility chains." Grayscale Research concluded in their tokenization analysis that "public blockchains are the more promising path for tokenization." BlackRock CEO Larry Fink projected: "Every stock, every bond will be on one general ledger," implying public infrastructure rather than fragmented private networks. The reasoning centers on network effects: every significant digital asset including Bitcoin, Ethereum, stablecoins, and NFTs exists on public chains; liquidity and network effects only become achievable on public infrastructure; true DeFi innovation proves impossible on private chains; and interoperability with the global financial ecosystem requires open standards and permissionless access.

Market size projections and adoption pathways to 2030

The global securities market comprises approximately $270-275 trillion in publicly traded equities and bonds, not the frequently cited $500 trillion figure. Specifically, global equity markets total $126.7 trillion according to SIFMA 2024 data, global bond markets reach $145.1 trillion, producing a combined $271 trillion in traditional securities. The $500 trillion figure appears to include derivatives markets, private equity and debt, and other less liquid assets, or relies on outdated projections. MSCI calculates the investable global market portfolio at $213 trillion end of 2023, with the full global market portfolio including less liquid assets reaching $271 trillion. The World Economic Forum identifies $255 trillion in marketable securities suitable for collateral, though only $28.6 trillion currently gets actively used, suggesting massive efficiency gains possible through better infrastructure.

Current tokenized securities total approximately $31 billion excluding stablecoins, with tokenized treasuries around $5 billion, total tokenized real-world assets including stablecoins reaching approximately $600 billion, and money market funds surpassing $1 billion in Q1 2024. Tokenized repos—repurchase agreements—process trillions of dollars monthly through platforms operated by Broadridge, Goldman Sachs, and J.P. Morgan, demonstrating institutional proof-of-concept at massive scale.

McKinsey's conservative projection estimates $2 trillion in tokenized securities by 2030, with a bullish scenario reaching $4 trillion, assuming approximately 75% compound annual growth rate across asset classes through the decade. BCG and 21Shares project $18-19 trillion in tokenized real-world assets by 2033. Binance Research calculates that just 1% of global equities moving on-chain would create $1.3 trillion in tokenized stocks, suggesting the potential for multi-trillion dollar markets if adoption accelerates beyond current projections.

Wave 1 assets reaching over $100 billion tokenized by 2027-2028 include cash and deposits (CBDCs, stablecoins, tokenized deposits), money market funds led by BlackRock, Franklin Templeton, and WisdomTree, bonds and exchange-traded notes encompassing government and corporate issuance, and loans and securitization covering private credit, home equity lines of credit, and warehouse lending. Wave 2 assets gaining traction 2028-2030 include alternative funds (private equity, hedge funds), public equities (listed stocks on major exchanges), and real estate (tokenized properties and REITs).

Critical milestones for 2025 include Nasdaq's tokenized securities proposal under SEC review, Robinhood's tokenized stocks gaining regulatory clarity, SEC Commissioner Hester Peirce (known as "Crypto Mom") actively advocating for on-chain securities, and Europe's planned move to T+1 settlement by 2027 creating competitive pressure as tokenization offers instant settlement advantages. Required signposts for acceleration include infrastructure supporting trillions in transaction volume (Solana and other platforms already capable), seamless interoperability between blockchains (in active development), widespread tokenized cash for settlement via CBDCs and stablecoins (growing rapidly with over $11.2 billion in stablecoins circulating on Solana alone), buy-side appetite for on-chain capital products (increasing institutionally), and regulatory clarity with supportive frameworks (major progress throughout 2025).

Cost comparisons reveal transformative economic advantages

Traditional securities settlement infrastructure costs the industry $17-24 billion annually in post-trade processing according to Broadridge estimates. Individual transaction costs range from $5-50 depending on institutional complexity and transaction type, with syndicated loans requiring up to three weeks for settlement due to legal complications and multiple intermediary coordination. The Depository Trust & Clearing Corporation (DTCC) processed $2.5 quadrillion in transactions during 2022, holds custody of 3.5 million securities issues valued at $87.1 trillion, and handles over 350 million transactions annually valued above $142 trillion—demonstrating the massive scale of infrastructure requiring disruption.

Academic and industry research quantifies potential savings. Securities clearing and settlement cost reductions of $11-12 billion annually appear achievable through blockchain implementation according to multiple peer-reviewed studies. The Global Financial Markets Association projects $15-20 billion in global infrastructure operational costs could be eliminated through smart contracts and automation as cited by World Economic Forum analysis. Capital efficiency improvements exceeding $100 billion become possible from enhanced collateral management, with cross-border settlement savings of $27 billion by 2030 projected by Jupiter Research.

McKinsey analysis of tokenized bond lifecycles shows 40%+ operational efficiency improvement from end-to-end digitization. Automated compliance through smart contracts eliminates manual checking and reconciliation processes that currently occupy 60-70% of asset management employees who don't generate alpha but instead handle operations. Multiple intermediaries including custodians, broker-dealers, and clearinghouses each add cost layers and complexity that blockchain's disintermediation eliminates. Markets currently close nights and weekends despite global demand for continuous trading, creating artificial constraints that blockchain's 24/7 operation removes. Cross-border transactions face complex custody chains and multiple jurisdictional requirements that unified blockchain infrastructure simplifies dramatically.

Settlement speed improvements reduce counterparty risk exposure by over 99% when moving from T+1 (24-hour settlement window) to T+0 or instant settlement. This near-elimination of settlement risk allows reduced liquidity buffers, smaller margin requirements, and more efficient capital deployment. Intraday liquidity enabled by continuous settlement supports short-term borrowing and lending that wasn't previously economically feasible. Real-time collateral mobility across jurisdictions optimizes capital usage globally rather than forcing regional silos. The 24/7 settlement capability enables continuous collateral optimization and automated yield strategies that maximize returns on every asset continuously rather than only during market hours.

Resnick's broader vision and cultural observations on development

In December 2024, shortly after joining Anza, Resnick outlined his first 100 days focus: "In my first 100 days, I plan on writing a spec for as much of the Solana protocol as I can get to, prioritizing fee markets and consensus implementations where I believe I can have the highest impact." He graded Solana's fee market as "B or B minus" as of late 2024, noting significant improvements from earlier in the year but identifying substantial room for optimization. His MEV (maximal extractable value) strategy distinguished between short-term improvements like better slippage settings and reconsidering public mempool design, versus long-term solutions involving multiple leaders creating competition that reduces sandwiching attacks. He quantified progress on sandwiching rates: "The sandwiching rate [is] way down... a 10% stake that's sandwiching is able to see only 10% of the transactions, which is what it should be," demonstrating that stake-weighted transaction visibility reduces attack profitability.

Resnick provided a striking revenue projection: achieving 1 million transactions per second could potentially generate $60 billion in annual revenue for Solana through transaction fees, illustrating the economic scalability of the model if adoption reaches Web2 scale. This projection assumes fees remain economically significant while volume scales massively—a delicate balance between network sustainability and user accessibility that proper fee market design must optimize.

His cultural observations on Solana versus Ethereum development reveal deeper philosophical differences. Resnick appreciated that "all of the discussions are happening in a place of how can we understand the way that a computer works and build a system based on that rather than building a system based on a mathematical model of a computer that is very lossy and doesn't actually represent what a computer does." This reflects Solana's engineering-first culture focused on practical performance optimization versus Ethereum's more theoretical computer science approach. He criticized Ethereum's development culture as constraining: "The ETH culture is really downstream of core development, and people who actually want to get things done are changing their personality, changing what they're suggesting in order to make sure that they preserve political capital with the core dev community."

Resnick emphasized after attending Solana Breakpoint conference: "I liked what I saw at Breakpoint. Anza developers are extremely cracked and I'm excited to get the opportunity to work with them." He characterized the philosophical difference succinctly: "There are no zealots in Solana, only pragmatic engineers who want to build a platform that can support the world's most liquid financial markets." This pragmatism over ideology distinction suggests Solana's development process prioritizes measurable performance outcomes and real-world use cases over theoretical purity or maintaining backward compatibility with legacy design decisions.

His positioning of Solana's original mission reinforces that securities markets were always the target: "Solana was originally founded to build a blockchain that is so fast and so cheap that you can put a working central limit order book on top of it." This wasn't a pivot or new strategy but rather the founding vision finally reaching maturity with the technical infrastructure, regulatory environment, and institutional adoption converging simultaneously.

Timeline for securities market disruption and key milestones

Completed developments through 2024-2025 established the foundation. Resnick joined Anza in December 2024, bringing economic expertise and strategic vision. Agave 2.3 released in April 2025 with improved TPU (Transaction Processing Unit) client enhancing transaction handling. The Alpenglow whitepaper published in May 2025 outlined the revolutionary consensus protocol, coinciding with Opening Bell's launch on May 8. Jito's Block Assembly Marketplace launched in July 2025, implementing short-term solutions from the Internet Capital Markets roadmap. DoubleZero testnet achieved operation with over 100 validators by September 2025, demonstrating dedicated fiber network reducing latency.

Near-term developments for late 2025 through early 2026 include Alpenglow activation on mainnet, bringing finality times down from 12.8 seconds to 100-150 milliseconds—a transformative improvement for high-frequency trading and real-time settlement applications. DoubleZero mainnet adoption across the validator network will reduce geographic latency penalties and improve global information incorporation. APE (Asynchronous Program Execution) implementation removes execution replay from the critical path, further reducing transaction confirmation times and improving throughput efficiency.

Medium-term developments spanning 2026-2027 focus on scaling and ecosystem maturation. Additional real-world asset issuers will deploy Securitize sTokens on Solana, expanding the variety and total value of tokenized securities available. Retail access expansion will lower minimum investment thresholds and broaden availability beyond accredited investors, democratizing access to institutional-grade products. Secondary market growth will increase liquidity on tokenized securities as more participants enter and market makers optimize strategies. Regulatory clarity should finalize post-pilot programs, with Project Open potentially establishing precedents for blockchain-based securities. Cross-chain standards will improve interoperability with Ethereum Layer-2s and other networks, reducing fragmentation.

Long-term vision for 2027 and beyond encompasses full MCL (Multiple Concurrent Leaders) implementation at the protocol level, enabling the economic models Resnick designed for optimal market microstructure. Protocol-enforced ACE (Application-Controlled Execution) at scale will give applications millisecond-level control over transaction ordering, enabling sophisticated trading strategies and execution quality improvements impossible on current infrastructure. The concept of "Internet Capital Markets" envisions fully on-chain capital markets with instant global access, where anyone with an internet connection can participate in global securities markets 24/7 without geographic or temporal restrictions.

Broader ecosystem developments include automated compliance through AI-driven KYC/AML and risk management systems that reduce friction while maintaining regulatory requirements, programmable portfolios enabling automated rebalancing and treasury management through smart contracts, fractional everything democratizing access to all asset classes regardless of unit price, and DeFi integration creating seamless interaction between tokenized securities and decentralized finance protocols for lending, derivatives, and liquidity provision.

Anthony Scaramucci of SkyBridge Capital forecast in 2025: "In 5 years, we'll be looking back and saying Solana has the largest market share of all these L1s," reflecting growing institutional conviction that Solana's technical advantages will translate to market dominance. Industry consensus suggests 10-20% of the securities market could tokenize by 2035, representing $27-54 trillion in on-chain securities if the total market grows modestly to $270-300 trillion over the next decade.

Conclusion: engineering superiority meets market opportunity

Solana's approach to disrupting securities markets distinguishes itself through fundamental engineering advantages rather than incremental improvements. The platform's ability to process 65,000 transactions per second at $0.00025 per transaction with 100-150 millisecond finality (post-Alpenglow) creates qualitative differences from competitors, not just quantitative improvements. These specifications enable entirely new categories of financial products: fractional ownership of high-value assets becomes economically viable when transaction costs don't exceed investment amounts; continuous portfolio rebalancing optimizes returns without being cost-prohibited; micro-dividend distributions can automatically reinvest small amounts efficiently; and retail investors can access institutional strategies previously limited by minimum investment thresholds and transaction cost structures.

Max Resnick's intellectual framework provides the economic theory undergirding technical implementation. His Multiple Concurrent Leaders concept addresses the fundamental problem of adverse selection in market microstructure—market makers widening spreads because they lose races to cancel stale orders. His Application-Controlled Execution vision gives smart contracts millisecond-level control over transaction ordering, enabling applications to implement optimal execution strategies. His geographic decentralization thesis argues that distributed validators can incorporate global information simultaneously rather than sequentially, providing informational advantages impossible in colocated systems. These aren't abstract academic theories but concrete technical specifications already under development, with Alpenglow representing the first major implementation of his economic frameworks.

Real-world adoption validates theoretical promise. $594 million from Franklin Templeton, $109.74 million from Apollo Global Management, and $2.1 billion in trading volume for xStocks in just six weeks demonstrate institutional and retail demand for blockchain-based securities when technical infrastructure, regulatory compliance, and user experience align properly. The fact that xStocks captured 58% of global tokenized stock trading within weeks of launch suggests winner-take-most dynamics may emerge—the platform offering the best combination of liquidity, cost, speed, and compliance tools will attract disproportionate volume through network effects.

The competitive moat deepens as adoption grows. Each new security tokenized on Solana adds liquidity and use cases, attracting more traders and market makers, which improves execution quality, which attracts more issuers in a reinforcing cycle. DeFi composability creates unique value: tokenized stocks becoming collateral in lending protocols, automated market makers providing 24/7 liquidity, derivatives markets building on tokenized underlying assets. These integrations prove impossible on private blockchains and economically impractical on high-cost public chains, giving Solana structural advantages that compound over time.

The distinction between hosting "the world's most liquid markets" versus "markets with the highest volume" reveals sophisticated strategic thinking. Liquidity quality—measured by tight bid-ask spreads, minimal price impact, and reliable execution—matters more than transaction count. A market can process billions of transactions but still deliver poor execution if spreads are wide and slippage high. Resnick's frameworks prioritize price quality and execution efficiency, targeting the metric that actually determines whether institutional traders choose a venue. This focus on market quality over vanity metrics like transaction count demonstrates the economic sophistication behind Solana's securities strategy.

Regulatory engagement through Project Open represents pragmatic navigation of compliance requirements rather than revolutionary dismissal of existing frameworks. The coalition's argument that decentralized protocols eliminate intermediaries therefore requiring new classification approaches—rather than forcing outdated intermediary regulations onto non-intermediated systems—reflects sophisticated legal reasoning that may prove more persuasive to regulators than confrontational approaches. The 18-month pilot structure with real-time monitoring provides regulators low-risk opportunity to evaluate blockchain securities in controlled conditions, potentially establishing precedents for permanent frameworks.

The $270 trillion securities market represents one of the largest addressable opportunities in financial history, even excluding the inflated $500 trillion figures sometimes cited. Capturing just 20-40% of a $27-54 trillion tokenized securities market by 2035 would establish Solana as critical infrastructure for global capital markets. The combination of superior technical performance, thoughtful economic design, growing institutional adoption, sophisticated regulatory engagement, and composability advantages from public blockchain infrastructure positions Solana uniquely to achieve this outcome. Resnick's vision of Solana becoming the operating system for Internet Capital Markets—enabling anyone with an internet connection to participate in global securities markets 24/7 with instant settlement and minimal costs—transforms from aspirational rhetoric to engineering roadmap when examined through the lens of implemented technical specifications, live institutional deployments, and concrete regulatory frameworks already under SEC consideration.

Momentary Custody, Long-Term Compliance: A Playbook for Crypto-Payment Founders

· 6 min read
Dora Noda
Software Engineer

If you’re building a crypto payments platform, you might have told yourself, “My platform only touches customer funds for a few seconds. That doesn’t really count as custody, right?”

This is a dangerous assumption. To financial regulators worldwide, even momentary control over customer funds makes you a financial intermediary. That brief touch—even for a few seconds—triggers a long-term compliance burden. For founders, understanding the substance of regulation, not just the technical implementation of your code, is critical for survival.

This playbook offers a clear guide to help you make smart, strategic decisions in a complex regulatory landscape.

1. Why “Just a Few Seconds” Still Triggers Money-Transmission Rules

The core of the issue is how regulators define control. The U.S. Financial Crimes Enforcement Network (FinCEN) is unequivocal: anyone who “accepts and transmits convertible virtual currency” is classified as a money transmitter, regardless of how long the funds are held.

This standard was reaffirmed in FinCEN’s 2019 CVC guidance and again in the 2023 DeFi risk assessment.

Once your platform meets this definition, you face a host of demanding requirements, including:

  • Federal MSB registration: Registering as a Money Services Business with the U.S. Department of the Treasury.
  • A written AML program: Establishing and maintaining a comprehensive Anti-Money Laundering program.
  • CTR/SAR filing: Filing Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs).
  • Travel-Rule data exchange: Exchanging originator and beneficiary information for certain transfers.
  • Ongoing OFAC screening: Continuously screening users against sanctions lists.

2. Smart Contracts ≠ Immunity

Many founders believe that automating processes with smart contracts provides a safe harbor from custodial obligations. However, regulators apply a functional test: they judge based on who has effective control, not how the code is written.

The Financial Action Task Force (FATF) made this clear in its 2023 targeted update, stating that “marketing terms or self-identification as DeFi is not determinative” of regulatory status.

If you (or a multisig you control) can perform any of the following actions, you are the custodian:

  • Upgrade a contract via an admin key.
  • Pause or freeze funds.
  • Sweep funds through a batch-settlement contract.

Only contracts with no admin key and direct user-signed settlement may avoid the Virtual Asset Service Provider (VASP) label—and even then, you still need to integrate sanctions screening at the UI layer.

3. The Licensing Map at a Glance

The path to compliance varies dramatically across jurisdictions. Here is a simplified overview of the global licensing landscape.

RegionCurrent GatekeeperPractical Hurdle
U.S.FinCEN + State MTMA licencesDual layer, costly surety bonds, and audits. 31 states have adopted the Money Transmission Modernization Act (MTMA) so far.
EU (today)National VASP registersMinimal capital requirements, but passporting rights are limited until MiCA is fully implemented.
EU (2026)MiCA CASP licence€125k–€150k capital requirement, but offers a single-passport regime for all 27 EU markets.
UKFCA crypto-asset registerRequires a full AML program and a Travel Rule-compliant interface.
SG / HKPSA (MAS) / VASP OrdinanceMandates custody segregation and a 90% cold-wallet rule for customer assets.

4. Case Study: BoomFi’s Poland VASP Route

BoomFi’s strategy provides an excellent model for startups targeting the EU. The company registered with the Polish Ministry of Finance in November 2023, securing a VASP registration.

Why it works:

  • Fast and low-cost: The approval process took less than 60 days and had no hard capital floor.
  • Builds credibility: The registration signals compliance and is a key requirement for EU merchants who need to work with a VASP-of-record.
  • Smooth path to MiCA: This VASP registration can be upgraded to a full MiCA CASP license in-place, preserving the existing customer base.

This lightweight approach allowed BoomFi to gain early market access and validate its product while preparing for the more rigorous MiCA framework and a future U.S. rollout.

5. De-risking Patterns for Builders

Compliance shouldn’t be an afterthought. It must be woven into your product design from day one. Here are several patterns that can minimize your licensing exposure.

Wallet Architecture

  • User-signed, contract-forwarding flows: Use patterns like ERC-4337 Paymasters or Permit2 to ensure all fund movements are explicitly signed and initiated by the user.
  • Time-lock self-destruct of admin keys: After the contract is audited and deployed, use a time-lock to permanently renounce admin privileges, proving you no longer have control.
  • Shard custody with licensed partners: For batch settlements, partner with a licensed custodian to handle the aggregation and disbursement of funds.

Operational Stack

  • Pre-transaction screening: Use an API gateway that injects OFAC and chain-analysis scores to vet addresses before a transaction is ever processed.
  • Travel Rule messenger: For cross-VASP transfers of $1,000 or more, integrate a solution like TRP or Notabene to handle required data exchange.
  • KYB first, then KYC: Vet the merchant (Know Your Business) before you onboard their users (Know Your Customer).

Expansion Sequencing

  1. Europe via VASP: Start in Europe with a national VASP registration (e.g., Poland) or a UK FCA registration to prove product-market fit.
  2. U.S. via partners: While state licenses are pending, enter the U.S. market by partnering with a licensed sponsor bank or custodial institution.
  3. MiCA CASP: Upgrade to a MiCA CASP license to lock in the EU passport for 27 markets.
  4. Asia-Pac: Pursue a license in Singapore (MAS) or Hong Kong (VASP Ordinance) if volume and strategic goals justify the additional capital outlay.

Key Takeaways

For every founder in the crypto-payments space, remember these core principles:

  1. Control trumps code: Regulators look at who can move money, not how the code is structured.
  2. Licensing is strategy: A lightweight EU VASP can open doors while you prepare for more capital-intensive jurisdictions.
  3. Design for compliance early: Admin-free contracts and sanction-aware APIs buy you runway and investor confidence.

Build like you will one day be inspected—because if you move customer funds, you will.