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Plasma Blockchain: Tether's $2 Billion Vertical Integration Gambit

· 11 min read
Dora Noda
Software Engineer

Plasma represents Tether's most aggressive strategic move since the stablecoin's inception—a purpose-built Layer 1 blockchain designed to recapture billions in transaction value currently flowing to competitor networks like Tron. After raising $373 million and attracting $5.6 billion in deposits within one week of its September 2025 mainnet launch, Plasma has since experienced a brutal reality check: TVL has declined to approximately $1.8 billion in stablecoins, and its XPL token has plummeted 85% from its $1.54 all-time high to ~$0.20. The core question facing this ambitious project isn't technical—it's existential: Can Plasma convert mercenary yield farmers into genuine payment users before its subsidy-fueled growth model exhausts itself?


The economics of "free": How Plasma subsidizes zero-fee transfers

Plasma's zero-fee USDT transfer promise is technically sophisticated but economically straightforward—it's a venture-funded subsidy designed for market capture, not a sustainable fee-free architecture.

The mechanism operates through a protocol-level paymaster contract built on EIP-4337 account abstraction. When users initiate USDT transfers, the Plasma Foundation's pre-funded XPL reserves cover gas costs automatically. Users never need to hold or acquire XPL for basic transfers. The system includes anti-spam protections: lightweight identity verification (options include zkEmail attestations and Cloudflare Turnstile) and rate limits of approximately 5 free transfers per 24 hours per wallet.

Critically, only simple transfer() and transferFrom() calls for official USDT are subsidized. All DeFi interactions, smart contract deployments, and complex transactions still require XPL for gas, preserving validator economics and creating the network's actual revenue model. This creates a two-tier system: free for retail remittances, paid for DeFi activity.

The competitive fee landscape reveals Plasma's value proposition:

BlockchainAvg USDT Transfer FeeNotes
Plasma$0.00Rate-limited, verified users
Tron$0.59–$1.60Post-60% fee cut (Aug 2025)
Ethereum L1$0.50–$7.00+Volatile, can spike to $30+
Solana$0.0001–$0.0005Near-zero without rate limits
Arbitrum/Base$0.01–$0.15L2 rollup benefits

Tron's response to Plasma's launch was immediate and defensive. On August 29, 2025, Tron cut energy unit prices by 60% (from 210 sun to 100 sun), reducing USDT transfer costs from $4+ to under $2. Daily network fee revenue dropped from $13.9 million to approximately $5 million—a direct acknowledgment of the competitive threat Plasma poses.

The sustainability question looms large. Plasma's model requires continuous Foundation spending without direct fee revenue from its primary use case. The $373 million raised provides runway, but at $2.8 million daily in estimated incentive distribution, burn rates are significant. Long-term viability depends on either: transitioning to fee-based transfers once user habits form, cross-subsidizing from DeFi ecosystem fees, or permanent backing from Tether's $13+ billion annual profits.


Strategic positioning within Tether's empire

The relationship between Plasma and Tether runs far deeper than typical blockchain investments—this is functional vertical integration through arms-length corporate structure.

Founder Paul Faecks (former Goldman Sachs, co-founder of institutional digital assets firm Alloy) has publicly pushed back against characterizing Plasma as "Tether's designated blockchain." But the connections are undeniable: Paolo Ardoino (Tether/Bitfinex CEO) is an angel investor and vocal champion; Christian Angermeyer (Plasma co-founder) manages Tether's profit reinvestment through Apeiron Investment Group; Bitfinex led Plasma's Series A; and the entire go-to-market strategy centers on USDT with zero-fee transfers.

The strategic logic is compelling. Currently, Tether profits from reserve yield—approximately $13 billion in 2024 from Treasury holdings backing USDT's $164 billion circulation. But the transactional value of billions of daily USDT movements accrues to host blockchains. Tron alone generated $2.15 billion in fee revenue in 2024, primarily from USDT transactions. From Tether's perspective, this represents massive value leakage—fees paid by Tether's own users flowing to third-party networks.

Plasma enables Tether to own both the product (USDT) and the distribution channel (the blockchain). According to DL News analysis, if Plasma captures 30% of USDT transfers:

  • Tron loses $1.6–$2.1 million daily in missed TRX burning
  • Ethereum loses $230,000–$370,000 daily in gas fees

This isn't merely about fee capture. Owning infrastructure provides compliance flexibility that third-party chains cannot offer. Tether has frozen $2.9+ billion across 5,188 addresses in collaboration with 255+ law enforcement agencies, but faces a critical limitation: a 44-minute average delay between freeze initiation and execution on Tron/Ethereum, during which $78 million in illicit funds have escaped. Plasma's architecture enables faster protocol-level enforcement without multi-sig delays.

The broader industry trend validates this strategy. Circle announced Arc (August 2025)—its own stablecoin-optimized L1 with USDC-native gas. Stripe is building Tempo with Paradigm. Ripple launched RLUSD. The stablecoin infrastructure war has shifted from issuing dollars to owning the rails.


The cold start problem: From record launch to 72% TVL decline

Plasma's launch metrics were extraordinary—and so has been the subsequent decline, exposing the fundamental challenge of converting incentivized deposits into organic usage.

The initial success was remarkable. Within 24 hours of mainnet launch (September 25, 2025), Plasma attracted $2.32 billion in TVL. Within one week, that figure reached $5.6 billion, briefly approaching Tron's DeFi TVL. The token sale was 7.4x oversubscribed at $0.05/XPL; one participant spent $100,000 in ETH gas fees simply to secure allocation. XPL launched at $1.25 and peaked at $1.54.

Plasma's novel "egalitarian airdrop" model—distributing equal XPL amounts regardless of deposit size—generated massive social media engagement and temporarily avoided the whale concentration plaguing typical token launches.

Then reality intervened. Current metrics tell a sobering story:

MetricPeakCurrentDecline
Stablecoin TVL$6.3B~$1.82B72%
XPL Price$1.54~$0.2085%
Weekly Outflow (Oct)$996MNet negative

The exodus follows a predictable yield-farming pattern. Most deposits concentrated in Aave lending vaults offering 20%+ APY—not in actual payments or transfers. When yields compressed and XPL's price collapsed (destroying reward value), capital migrated to higher-yielding alternatives. October 2025 saw $996 million in stablecoin outflows from Plasma versus $1.1 billion inflows to Tron—the exact inverse of Plasma's intended competitive dynamic.

Network usage data reveals the depth of the problem. Actual TPS has averaged approximately 14.9 transactions per second against claimed capacity of 1,000+. Most stablecoins remain "parked in lending pools rather than being used for payments or transfers," according to on-chain analysis.

The DeFi ecosystem demonstrates breadth without depth. Over 100 protocols launched at mainnet—Aave, Curve, Ethena, Euler, Fluid—but Aave alone commands 68.8% of lending activity. Key regional partnerships (Yellow Card for Africa remittances, BiLira for Turkish lira on/off-ramps) remain early-stage. The Plasma One neobank—promising 10%+ yields, 4% cashback, and physical cards in 150 countries—is still in waitlist phase.

Three conditions appear necessary for cold start success:

  • Native USDT issuance (currently using USDT0 via LayerZero bridge, not Tether-issued native tokens)
  • Exchange default status (Tron's years of integration create significant switching costs)
  • Real-world payment adoption beyond yield farming

Regulatory landscape: MiCA threatens, GENIUS Act opens doors

The global stablecoin regulatory environment has fundamentally shifted in 2025, creating both existential challenges and unprecedented opportunities for Plasma's USDT-centric architecture.

The EU presents the biggest obstacle. MiCA (Markets in Crypto-Assets Regulation) requires stablecoin issuers to obtain authorization as credit institutions or electronic money institutions, maintain 60% of reserves in EU bank accounts for significant stablecoins, and prohibit interest payments to holders. Tether CEO Paolo Ardoino publicly criticized these requirements as creating "systemic banking risks" and has not pursued MiCA authorization.

The consequences have been severe:

  • Coinbase Europe delisted USDT (December 2024)
  • Binance, Kraken removed USDT from EEA trading (March 2025)
  • Tether discontinued its euro-pegged EURT stablecoin entirely

ESMA clarified that custody and transfer of USDT remain legal—only new offerings/trading are prohibited. But for Plasma, whose entire value proposition centers on USDT, the EU market is effectively inaccessible without supporting MiCA-compliant alternatives like Circle's USDC.

The US regulatory picture is dramatically more favorable. The GENIUS Act—signed into law July 18, 2025—represents the first federal digital asset legislation in US history. Key provisions:

  • Stablecoins explicitly not securities or commodities (no SEC/CFTC oversight)
  • 100% reserve backing in qualified assets (Treasuries, Fed notes, insured deposits)
  • Monthly disclosure and annual audits for large issuers
  • Technical capability to freeze, seize, or burn stablecoins on lawful order required

For Tether, GENIUS Act creates a clear pathway to US market legitimacy. For Plasma, the compliance requirements align with architectural capabilities—the network's modular attestation framework supports blacklisting, rate limits, and jurisdictional approvals at the protocol level.

Emerging markets represent the highest-opportunity segment. Turkey processes $63 billion annually in stablecoin volume, driven by 34% inflation and lira devaluation. Nigeria has 54 million crypto users with 12% stablecoin penetration despite government hostility. Argentina, facing 140%+ inflation, sees 60%+ of crypto activity in stablecoins. Sub-Saharan Africa uses stablecoins for 43% of crypto volume, primarily remittances.

Plasma's zero-fee model directly targets these use cases. The $700 billion annual remittance market to low/middle-income countries loses approximately 4% (over $600 million yearly in the US-India corridor alone) to intermediaries. Plasma One's planned features—10%+ yields, zero-fee transfers, card access in 150 countries—address precisely these demographics.


Three scenarios for Plasma's evolution

Based on current trajectory and structural factors, three distinct development paths emerge:

Bull scenario: Stablecoin infrastructure winner. Plasma One achieves 1+ million active users in emerging markets. The network captures 5–10% of Tron's $80 billion+ USDT flow. Confidential transactions with selective disclosure drive institutional adoption. Bitcoin bridge activation unlocks meaningful BTC DeFi. Result: $15–20 billion TVL, XPL recovering to $1.00–$2.50 (5–12x current levels), 5+ million monthly active users.

Base scenario: Niche stablecoin L1. Plasma maintains $3–5 billion TVL with lending/yield focus. Plasma One achieves modest traction (100,000–500,000 users). Network competes for 2–3% of stablecoin market share. XPL stabilizes at $0.20–$0.40 after 2026 unlock dilution. Network functions but doesn't meaningfully threaten Tron's dominance—similar to how Base/Arbitrum coexist with Ethereum rather than replacing it.

Bear scenario: Failed launch syndrome. TVL continues declining below $1 billion as yields normalize. XPL breaks below $0.10 as team/investor unlocks accelerate (2.5 billion tokens begin vesting September 2026). Network effect failure prevents organic user acquisition. Competitive displacement intensifies as Tron cuts fees further and L2s capture growth. Worst case: Plasma joins the graveyard of overhyped L1s that attracted capital through high yields but were abandoned when rewards depleted.

Key observation indicators for tracking trajectory:

  • User quality: Non-lending TVL percentage (currently <10%), actual USDT transfer volume versus DeFi interactions
  • Ecosystem depth: Protocol diversification beyond Aave dominance
  • Commercialization: Plasma One user acquisition, card issuance numbers, regional payment volumes
  • Token health: XPL price trajectory through 2026 unlock events (US investors July, team September)
  • Competitive dynamics: USDT market share shifts between Plasma, Tron, Ethereum L2s

Conclusion: Value proposition meets structural constraints

Plasma's core value proposition is strategically sound. Zero-fee USDT transfers address genuine friction in the $15.6 trillion annual stablecoin settlement market. Tether's vertical integration logic follows classic business strategy—owning both product and distribution. The regulatory environment (particularly post-GENIUS Act) increasingly favors compliant stablecoin infrastructure. Emerging market demand for dollar access outside traditional banking is real and growing.

But structural constraints are substantial. The network must overcome Tron's seven-year integration advantage with a two-month track record. The cold start strategy successfully attracted capital but failed to convert yield farmers into payment users—a classic incentive misalignment. The 85% token decline and 72% TVL drop signal that markets are skeptical of sustainability. Major unlock events in 2026 create overhang risk.

The most likely path forward is neither triumphant disruption nor complete failure but gradual niche establishment. Plasma may capture meaningful share in specific corridors (Turkey, Latin America, Africa remittances) where its regional partnerships and zero-fee model provide genuine utility. Institutional adoption could follow if confidential transactions with selective disclosure prove regulatory-compatible. But displacing Tron's entrenched position in the broader USDT ecosystem will require years of execution, sustained Tether support, and successful conversion of incentive-driven growth into organic network effects.

For industry observers, Plasma represents a critical experiment in stablecoin infrastructure verticalization—a trend that includes Circle's Arc, Stripe's Tempo, and Tether's parallel "Stable" chain. Whether the winner-take-most dynamics of stablecoin issuance extend to infrastructure ownership will shape the next decade of crypto-finance architecture. Plasma's outcome will provide the definitive case study.

Anatomy of a $285M DeFi Contagion: The Stream Finance xUSD Collapse

· 39 min read
Dora Noda
Software Engineer

On November 4, 2025, Stream Finance disclosed a $93 million loss from an external fund manager, triggering one of the year's most significant stablecoin failures. Within 24 hours, its yield-bearing token xUSD plummeted 77% from $1.00 to $0.26, freezing $160 million in user deposits and exposing over $285 million in interconnected debt across the DeFi ecosystem. This wasn't a smart contract hack or oracle manipulation—it was an operational failure that revealed fundamental flaws in the emerging "looping yield" economy and the hybrid CeDeFi model.

The collapse matters because it exposes a dangerous illusion: protocols promising DeFi's transparency and composability while depending on opaque off-chain fund managers. When the external manager failed, Stream had no on-chain emergency tools to recover funds, no circuit breakers to limit contagion, and no redemption mechanism to stabilize the peg. The result was a reflexive bank run that cascaded through Elixir's deUSD stablecoin (which lost 98% of value) and major lending protocols like Euler, Morpho, and Silo.

Understanding this event is critical for anyone building or investing in DeFi. Stream Finance operated for months with 4x+ leverage through recursive looping, turning $160 million in user deposits into a claimed $520 million in assets—a accounting mirage that collapsed under scrutiny. The incident occurred just one day after the $128 million Balancer exploit, creating a perfect storm of fear that accelerated the depeg. Now, three weeks later, xUSD still trades at $0.07-0.14 with no path to recovery, and hundreds of millions remain frozen in legal limbo.

Background: Stream Finance's high-leverage yield machine

Stream Finance launched in early 2024 as a multi-chain yield aggregator operating across Ethereum, Arbitrum, Avalanche, and other networks. Its core proposition was deceptively simple: deposit USDC and receive xUSD, a yield-bearing wrapped token that would generate passive returns through "institutional-grade" DeFi strategies.

The protocol deployed user funds across 50+ liquidity pools using recursive looping strategies that promised yields up to 12% on stablecoins—roughly triple what users could earn on platforms like Aave (4.8%) or Compound (3%). Stream's activities spanned lending arbitrage, market making, liquidity provision, and incentive farming. By late October 2025, the protocol reported approximately $520 million in total assets under management, though actual user deposits totaled only around $160 million.

This discrepancy wasn't an accounting error—it was the feature. Stream employed a leverage amplification technique that worked like this: User deposits $1 million USDC → receives xUSD → Stream uses $1M as collateral on Platform A → borrows $800K → uses that as collateral on Platform B → borrows $640K → repeats. Through this recursive process, Stream transformed $1 million into roughly $3-4 million in deployed capital, quadrupling its effective leverage.

xUSD itself was not a traditional stablecoin but rather a tokenized claim on a leveraged yield portfolio. Unlike purely algorithmic stablecoins (Terra's UST) or fully-reserved fiat-backed stablecoins (USDC, USDT), xUSD operated as a hybrid model: it had real collateral backing, but that collateral was actively deployed in high-risk DeFi strategies, with portions managed by external fund managers operating off-chain.

The peg mechanism depended on two critical elements: adequate backing assets and operational redemption access. When Stream Finance disabled redemptions following the fund manager loss, the arbitrage mechanism that maintains stablecoin pegs—buy cheap tokens, redeem for $1 of backing—simply stopped working. With only shallow DEX liquidity as an exit route, panic selling overwhelmed available buyers.

This design exposed Stream to multiple attack surfaces simultaneously: smart contract risk from 50+ integrated protocols, market risk from leveraged positions, liquidity risk from layered unwinding requirements, and crucially, counterparty risk from external fund managers who operated beyond the protocol's control.

November 3-4: Timeline of the collapse

October 28-November 2: Warning signs emerged days before the official announcement. On-chain analyst CBB0FE flagged suspicious metrics on October 28, noting that xUSD showed backing assets of only $170 million supporting $530 million in borrowing—a 4.1x leverage ratio. Yearn Finance contributor Schlag published detailed analysis exposing "circular minting" between Stream and Elixir, warning of a "ponzi the likes of which we haven't seen for awhile in crypto." The protocol's flat 15% yields suggested manually set returns rather than organic market performance, another red flag for sophisticated observers.

November 3 (Morning): The Balancer Protocol suffered a $100-128 million exploit across multiple chains due to faulty access controls in its manageUserBalance function. This created broader DeFi panic and triggered defensive positioning across the ecosystem, setting the stage for Stream's announcement to have maximum impact.

November 3 (Late afternoon): Roughly 10 hours before Stream's official disclosure, users began reporting withdrawal delays and deposit issues. Omer Goldberg, founder of Chaos Labs, observed xUSD beginning to slip from its $1.00 peg and warned his followers. Secondary DEX markets showed xUSD starting to trade below target range as informed participants began exiting positions.

November 4 (Early hours UTC): Stream Finance published its official announcement on X/Twitter: "Yesterday, an external fund manager overseeing Stream funds disclosed the loss of approximately $93 million in Stream fund assets." The protocol immediately suspended all deposits and withdrawals, engaged law firm Perkins Coie LLP to investigate, and began the process of withdrawing all liquid assets. This decision to freeze operations while announcing a major loss proved catastrophic—it removed the exact mechanism needed to stabilize the peg.

November 4 (Hours 0-12): xUSD experienced its first major decline. Blockchain security firm PeckShield reported an initial 23-25% depeg, with prices rapidly falling from $1.00 to approximately $0.50. With redemptions suspended, users could only exit via secondary DEX markets. The combination of mass selling pressure and shallow liquidity pools created a death spiral—each sale pushed prices lower, triggering more panic and more selling.

November 4 (Hours 12-24): The acceleration phase. xUSD crashed through $0.50 and continued falling to the $0.26-0.30 range, representing a 70-77% loss of value. Trading volumes surged as holders rushed to salvage whatever value remained. CoinGecko and CoinMarketCap both recorded lows around $0.26. The interconnected nature of DeFi meant the damage didn't stop at xUSD—it cascaded into every protocol that accepted xUSD as collateral or was exposed to Stream's positions.

Systemic contagion (November 4-6): Elixir Network's deUSD, a synthetic stablecoin with 65% of its backing exposed to Stream ($68 million lent via private Morpho vaults), collapsed 98% from $1.00 to $0.015. Major lending protocols faced liquidity crises as borrowers using xUSD collateral couldn't be liquidated due to oracle hardcoding (protocols had set xUSD's price at $1.00 to prevent cascading liquidations, creating an illusion of stability while exposing lenders to massive bad debt). Compound Finance paused certain Ethereum lending markets. Stream Finance's TVL collapsed from $204 million to $98 million in 24 hours.

Current status (November 8, 2025): xUSD remains severely depegged, now trading at $0.07-0.14 (87-93% below peg) with virtually no liquidity. The 24-hour trading volume has fallen to approximately $30,000, indicating an illiquid, potentially dead market. Deposits and withdrawals remain frozen with no resumption timeline. The Perkins Coie investigation continues with no public findings. Most critically, no recovery plan or compensation mechanism has been announced, leaving hundreds of millions in frozen assets and unclear creditor priorities.

Root causes: Recursive leverage meets fund manager failure

The Stream Finance collapse was fundamentally an operational failure amplified by structural vulnerabilities, not a technical exploit. Understanding what broke is essential for evaluating similar protocols going forward.

The trigger: $93 million external manager loss—On November 3, Stream disclosed that an unnamed external fund manager overseeing Stream funds had lost approximately $93 million. No evidence of a smart contract hack or exploit has been found. The loss appears to stem from fund mismanagement, unauthorized trading, poor risk controls, or adverse market movements. Critically, the identity of this fund manager has not been publicly disclosed, and the specific strategies that resulted in losses remain opaque.

This reveals the first critical failure: off-chain counterparty risk. Stream promised DeFi's benefits—transparency, composability, no trusted intermediaries—while simultaneously relying on traditional fund managers operating off-chain with different risk frameworks and oversight standards. When that manager failed, Stream had no on-chain emergency tools available: no multisigs with clawback functions, no contract-level recovery mechanisms, no DAO governance that could execute within block cycles. The toolbox that enabled protocols like StakeWise to recover $19.3 million from the Balancer exploit simply didn't work for Stream's off-chain losses.

Recursive looping created phantom collateral—The single most dangerous structural element was Stream's leverage amplification through recursive looping. This created what analysts called "inflated TVL metrics" and "phantom collateral." The protocol repeatedly deployed the same capital across multiple platforms to amplify returns, but this meant that $1 million in user deposits might appear as $3-4 million in "assets under management."

This model had severe liquidity mismatches: unwinding positions required repaying loans layer-by-layer across multiple platforms, a time-consuming process impossible to execute quickly during a crisis. When users wanted to exit, Stream couldn't simply hand back their proportional share of assets—it needed to first unwind complex, leveraged positions spanning dozens of protocols.

DeFiLlama, a major TVL tracking platform, disputed Stream's methodology and excluded recursive loops from its calculations, showing $200 million rather than Stream's claimed $520 million. This transparency gap meant users and curators couldn't accurately assess the protocol's true risk profile.

Circular minting with Elixir created a house of cards—Perhaps the most damning technical detail emerged from Yearn Finance lead developer Schlag's analysis: Stream and Elixir engaged in recursive cross-minting of each other's tokens. The process worked like this: Stream's xUSD wallet received USDC → swapped to USDT → minted Elixir's deUSD → used borrowed assets to mint more xUSD → repeat. Using just $1.9 million in USDC, they created approximately $14.5 million in xUSD through circular loops.

Elixir had lent $68 million (65% of deUSD's collateral) to Stream via private, hidden lending markets on Morpho where Stream was the only borrower, using its own xUSD as collateral. This meant deUSD was ultimately backed by xUSD, which was partially backed by borrowed deUSD—a recursive dependency that guaranteed both would collapse together. On-chain analysis estimated actual collateral backing at "sub $0.10 per $1."

Severe undercollateralization masked by complexity—Days before the collapse, analyst CBB0FE calculated that Stream had actual backing assets of approximately $170 million supporting $530 million in total borrowing—a leverage ratio exceeding 4x. This represented over 300% effective leverage. The protocol operated with undisclosed insurance funds (users later accused the team of retaining approximately 60% of profits without disclosure), but whatever insurance existed proved wholly inadequate for a $93 million loss.

Oracle hardcoding prevented proper liquidations—Multiple lending protocols including Morpho, Euler, and Elixir had hardcoded xUSD's oracle price to $1.00 to prevent mass liquidations and cascading failures across the DeFi ecosystem. While well-intentioned, this created massive problems: as xUSD traded at $0.30 on secondary markets, lending protocols still valued it at $1.00, preventing risk controls from triggering. Lenders were left holding worthless collateral with no automatic liquidation protecting them. This amplified bad debt across the ecosystem but didn't cause the initial depeg—it merely prevented proper risk management once the depeg occurred.

What didn't happen: It's important to clarify what this incident was NOT. There was no smart contract vulnerability in xUSD's core code. There was no oracle manipulation attack causing the initial depeg. There was no flash loan exploit or complex DeFi arbitrage draining funds. This was a traditional fund management failure occurring off-chain, exposing the fundamental incompatibility between DeFi's promise of transparency and the reality of depending on opaque external managers.

Financial impact and ecosystem contagion

The Stream Finance collapse demonstrates how concentrated leverage and interconnected protocols can transform a $93 million loss into over a quarter-billion in exposed positions across the DeFi ecosystem.

Direct losses: The disclosed $93 million fund manager loss represents the primary, confirmed destruction of capital. Additionally, $160 million in user deposits remains frozen with uncertain recovery prospects. xUSD's market capitalization collapsed from approximately $70 million to roughly $20 million (at current $0.30 prices), though the actual realized losses depend on when holders sold or whether they're still frozen in the protocol.

Debt exposure across lending protocols—DeFi research group Yields and More (YAM) published comprehensive analysis identifying $285 million in direct debt exposure across multiple lending platforms. The largest creditors included: TelosC with $123.64 million in loans secured by Stream assets (the single largest curator exposure); Elixir Network with $68 million (65% of deUSD backing) lent via private Morpho vaults; MEV Capital with $25.42 million; Varlamore and Re7 Labs with additional tens of millions each.

These weren't abstract on-chain positions—they represented real lenders who had deposited USDC, USDT, and other assets into protocols that then lent to Stream. When xUSD collapsed, these lenders faced either total losses (if borrowers defaulted and collateral was worthless) or severe haircuts (if any recovery occurs).

TVL destruction: Stream Finance's total value locked collapsed from a peak of $204 million in late October to $98 million by November 5—losing over 50% in a single day. But the damage extended far beyond Stream itself. DeFi-wide TVL dropped approximately 4% within 24 hours as fear spread, users withdrew from yield protocols, and lending markets tightened.

Cascade effects through interconnected stablecoins—Elixir's deUSD experienced the most dramatic secondary failure, collapsing 98% from $1.00 to $0.015 when its massive Stream exposure became apparent. Elixir had positioned itself as having "full redemption rights at $1 with Stream," but those rights proved meaningless when Stream couldn't process payouts. Elixir eventually processed redemptions for 80% of deUSD holders before suspending operations, took a snapshot of remaining balances, and announced the stablecoin's sunset. Stream reportedly holds 90% of the remaining deUSD supply (approximately $75 million) with no ability to repay.

Multiple other synthetic stablecoins faced pressure: Stable Labs' USDX depegged due to xUSD exposure; various derivative tokens like sdeUSD and scUSD (staked versions of deUSD) became effectively worthless. Stream's own xBTC and xETH tokens, which used similar recursive strategies, also collapsed though specific pricing data is limited.

Lending protocol dysfunction—Markets on Euler, Morpho, Silo, and Gearbox that accepted xUSD as collateral faced immediate crises. Some reached 100% utilization rates with borrow rates spiking to 88%, meaning lenders literally could not withdraw their funds—every dollar was lent out, and borrowers weren't repaying because their collateral had cratered. Compound Finance, acting on recommendations from risk manager Gauntlet, paused USDC, USDS, and USDT markets to contain contagion.

The oracle hardcoding meant positions weren't liquidated automatically despite being catastrophically undercollateralized. This left protocols with massive bad debt that they're still working to resolve. The standard DeFi liquidation mechanism—automatically selling collateral when values fall below thresholds—simply didn't trigger because the oracle price and market price had diverged so dramatically.

Broader DeFi confidence damage—The Stream collapse occurred during a particularly sensitive period. Bitcoin had just experienced its largest liquidation event on October 10 (approximately $20 billion wiped out across the crypto market), yet Stream was suspiciously unaffected—a red flag that suggested hidden leverage or accounting manipulation. Then, one day before Stream's disclosure, Balancer suffered its $128 million exploit. The combination created what one analyst called a "perfect storm of DeFi uncertainty."

The Crypto Fear & Greed Index plummeted to 21/100 (extreme fear territory). Twitter polls showed 60% of respondents unwilling to trust Stream again even if operations resumed. More broadly, the incident reinforced skepticism about yield-bearing stablecoins and protocols promising unsustainable returns. The collapse drew immediate comparisons to Terra's UST (2022) and reignited debates about whether algorithmic or hybrid stablecoin models are fundamentally viable.

Response, recovery, and the road ahead

Stream Finance's response to the crisis has been characterized by immediate operational decisions, ongoing legal investigation, and notably absent: any concrete recovery plan or user compensation mechanism.

Immediate actions (November 4)—Within hours of the disclosure, Stream suspended all deposits and withdrawals, effectively freezing $160 million in user funds. The protocol engaged Keith Miller and Joseph Cutler of law firm Perkins Coie LLP—a major blockchain and cryptocurrency practice—to lead a comprehensive investigation into the loss. Stream announced it was "actively withdrawing all liquid assets" and expected to complete this "in the near term," though no specific timeline was provided.

These decisions, while perhaps legally necessary, had devastating market consequences. Pausing redemptions during a confidence crisis is exactly what exacerbates a bank run. Users who noticed withdrawal delays before the official announcement were vindicated in their suspicion—Omer Goldberg warned of the depeg 10-17 hours before Stream's statement, highlighting a significant communication lag that created information asymmetry favoring insiders and sophisticated observers.

Transparency failures—One of the most damaging aspects was the contrast between Stream's stated values and actual practice. The protocol's website featured a "Transparency" section that displayed "Coming soon!" at the time of collapse. Stream later acknowledged: "We have not been as transparent as we should have been on how the insurance fund works." User chud.eth accused the team of retaining an undisclosed 60% fee structure and hiding insurance fund details.

The identity of the external fund manager who lost $93 million has never been disclosed. The specific strategies employed, the timeline of losses, whether this represented sudden market movements or gradual bleeding—all remain unknown. This opacity makes it impossible for affected users or the broader ecosystem to assess what actually happened and whether malfeasance occurred.

Legal investigation and creditor conflicts—As of November 8, 2025 (three weeks post-collapse), Perkins Coie's investigation continues with no public findings. The investigation aims to determine causes, identify responsible parties, assess recovery possibilities, and critically, establish creditor priorities for any eventual distribution. This last point has created immediate conflicts.

Elixir claims to have "full redemption rights at $1 with Stream" and states it's "the only creditor with these 1-1 rights," suggesting preferential treatment in any recovery. Stream reportedly told Elixir it "cannot process payouts until attorneys determine creditor priority." Other major creditors like TelosC ($123M exposure), MEV Capital ($25M), and Varlamore face uncertain standing. Meanwhile, retail xUSD/xBTC holders occupy yet another potential class of creditors.

This creates a complex bankruptcy-like situation without clear DeFi-native resolution mechanisms. Who gets paid first: direct xUSD holders, lending protocol depositors who lent to curators, curators themselves, or synthetic stablecoin issuers like Elixir? Traditional bankruptcy law has established priority frameworks, but it's unclear if those apply here or if novel DeFi-specific resolutions will emerge.

No compensation plan announced—The most striking aspect of Stream's response is what hasn't happened: no formal compensation plan, no timeline for assessment completion, no estimated recovery percentages, no distribution mechanism. Community discussions mention predictions of 10-30% haircuts (meaning users might recover 70-90 cents per dollar, or suffer 10-30% losses), but these are speculation based on perceived available assets versus claims, not official guidance.

Elixir has taken the most proactive approach for its specific users, processing redemptions for 80% of deUSD holders before suspending operations, taking snapshots of remaining balances, and creating a claims portal for 1:1 USDC redemption. However, Elixir itself faces the problem that Stream holds 90% of remaining deUSD supply and hasn't repaid—so Elixir's ability to make good on redemptions depends on Stream's recovery.

Current status and prospects—xUSD continues trading at $0.07-0.14, representing 87-93% loss from peg. The fact that market pricing sits well below even conservative recovery estimates (10-30% haircut would imply $0.70-0.90 value) suggests the market expects either: massive losses from the investigation findings, years-long legal battles before any distribution, or complete loss. The 24-hour trading volume of approximately $30,000 indicates an essentially dead market with no liquidity.

Stream Finance operations remain frozen indefinitely. There's been minimal communication beyond the initial November 4 announcement—the promised "periodic updates" have not materialized regularly. The protocol shows no signs of resuming operations even in a limited capacity. For comparison, when Balancer was exploited for $128 million on the same day, the protocol used emergency multisigs and recovered $19.3 million relatively quickly. Stream's off-chain loss offers no such recovery mechanisms.

Community sentiment and trust destruction—Social media reactions reveal deep anger and a sense of betrayal. Early warnings from analysts like CBB0FE and Schlag give some users vindication ("I told you so") but don't help those who lost funds. The criticism centers on several themes: the curator model failed catastrophically (curators supposedly do due diligence but clearly didn't identify Stream's risks); unsustainable yields should have been a red flag (18% on stablecoins when Aave offered 4-5%); and the hybrid CeDeFi model was fundamentally dishonest (promising decentralization while depending on centralized fund managers).

Expert analysts have been harsh. Yearn Finance's Schlag noted that "none of what happened came out of nowhere" and warned that "Stream Finance is far from the only ones out there with bodies to hide," suggesting similar protocols may face similar fates. The broader industry has used Stream as a cautionary tale about transparency, proof-of-reserves, and the importance of understanding exactly how protocols generate yield.

Technical post-mortem: What actually broke

For developers and protocol designers, understanding the specific technical failures is crucial for avoiding similar mistakes.

Smart contracts functioned as designed—This is both important and damning. There was no bug in xUSD's core code, no exploitable reentrancy vulnerability, no integer overflow, no access control flaw. The smart contracts executed perfectly. This means security audits of the contract code—which focus on finding technical vulnerabilities—would have been useless here. Stream's failure occurred in the operational layer, not the code layer.

This challenges a common assumption in DeFi: that comprehensive audits from firms like CertiK, Trail of Bits, or OpenZeppelin can identify risks. Stream Finance appears to have had no formal security audits from major firms, but even if it had, those audits would have examined smart contract code, not fund management practices, leverage ratios, or external manager oversight.

Recursive looping mechanics—The technical implementation of Stream's leverage strategy worked like this:

  1. User deposits 1,000 USDC → receives 1,000 xUSD
  2. Stream's smart contracts deposit USDC into Platform A as collateral
  3. Smart contracts borrow 750 USDC from Platform A (75% LTV)
  4. Deposit borrowed USDC into Platform B as collateral
  5. Borrow 562.5 USDC from Platform B
  6. Repeat across Platform C, D, E...

After 4-5 iterations, 1,000 USDC in user deposits becomes approximately 3,000-4,000 USDC in deployed positions. This amplifies returns (if positions profit, those profits are calculated on the larger amount) but also amplifies losses and creates severe unwinding problems. To return the user's 1,000 USDC requires:

  • Withdrawing from final platform
  • Repaying loan to previous platform
  • Withdrawing collateral
  • Repaying loan to previous platform
  • Etc., working backward through the entire chain

If any platform in this chain has a liquidity crisis, the entire unwinding process stops. This is exactly what happened—xUSD's collapse meant many platforms had 100% utilization (no liquidity available), preventing Stream from unwinding positions even if it wanted to.

Hidden markets and circular dependencies—Schlag's analysis revealed that Stream and Elixir used private, unlisted markets on Morpho where normal users couldn't see activity. These "hidden markets" meant that even on-chain transparency was incomplete—you had to know which specific contract addresses to examine. The circular minting process created a graph structure like:

Stream xUSD ← backed by (deUSD + USDC + positions) Elixir deUSD ← backed by (xUSD + USDT + positions)

Both tokens depended on each other for backing, creating a reinforcing death spiral when one failed. This is structurally similar to how Terra's UST and LUNA created a reflexive dependency that amplified the collapse.

Oracle methodology and liquidation prevention—Multiple protocols made the explicit decision to hardcode xUSD's value at $1.00 in their oracle systems. This was likely an attempt to prevent cascading liquidations: if xUSD's price fell to $0.50 in oracles, any borrower using xUSD as collateral would be instantly undercollateralized, triggering automatic liquidations. Those liquidations would dump more xUSD on the market, pushing prices lower, triggering more liquidations—a classic liquidation cascade.

By hardcoding the price at $1.00, protocols prevented this cascade but created a worse problem: borrowers were massively undercollateralized (holding $0.30 of real value per $1.00 of oracle value) but couldn't be liquidated. This left lenders with bad debt. The proper solution would have been to accept the liquidations and have adequate insurance funds to cover losses, rather than masking the problem with false oracle prices.

Liquidity fragmentation—With redemptions paused, xUSD only traded on decentralized exchanges. The primary markets were Balancer V3 (Plasma chain) and Uniswap V4 (Ethereum). Total liquidity across these venues was likely only a few million dollars at most. When hundreds of millions in xUSD needed to exit, even a few million in selling pressure moved prices dramatically.

This reveals a critical design flaw: stablecoins cannot rely solely on DEX liquidity to maintain their peg. DEX liquidity is inherently limited—liquidity providers won't commit unlimited capital to pools. The only way to handle large redemption pressure is through a direct redemption mechanism with the issuer, which Stream removed by pausing operations.

Warning signs and detection failures—On-chain data clearly showed Stream's problems days before collapse. CBB0FE calculated leverage ratios from publicly available data. Schlag identified circular minting by examining contract interactions. DeFiLlama disputed TVL figures publicly. Yet most users, and critically most risk curators who were supposed to do due diligence, missed or ignored these warnings.

This suggests the DeFi ecosystem needs better tooling for risk assessment. Raw on-chain data exists, but analyzing it requires expertise and time. Most users don't have capacity to audit every protocol they use. The curator model—where sophisticated parties allegedly do this analysis—failed because curators were incentivized to maximize yield (and thus fees) rather than minimize risk. They had asymmetric incentives: earn fees during good times, externalize losses during bad times.

No technical recovery mechanisms—When the Balancer exploit occurred on November 3, StakeWise protocol recovered $19.3 million using emergency multisigs with clawback functions. These on-chain governance tools can execute within block cycles to freeze funds, reverse transactions, or implement emergency measures. Stream had none of these tools for its off-chain losses. The external fund manager operated in traditional financial systems beyond the reach of smart contracts.

This is the fundamental technical limitation of hybrid CeDeFi models: you can't use on-chain tools to fix off-chain problems. If the failure point exists outside the blockchain, all of DeFi's supposed benefits—transparency, automation, trustlessness—become irrelevant.

Lessons for stablecoin design and DeFi risk management

The Stream Finance collapse offers critical insights for anyone building, investing in, or regulating stablecoin protocols.

The redemption mechanism is non-negotiable—The single most important lesson: stablecoins cannot maintain their peg if redemption is suspended when confidence declines. Stream's $93 million loss was manageable—it represented roughly 14% of user deposits ($93M / $160M in deposits if no leverage, or even less if you believe the $520M figure). A 14% haircut, while painful, shouldn't cause a 77% depeg. What caused the catastrophic failure was removing the ability to redeem.

Redemption mechanisms work through arbitrage: when xUSD trades at $0.90, rational actors buy it and redeem for $1.00 worth of backing assets, earning a $0.10 profit. This buying pressure pushes the price back toward $1.00. When redemptions pause, this mechanism breaks entirely. Price becomes solely dependent on available DEX liquidity and sentiment, not on underlying value.

For protocol designers: build redemption circuits that remain functional during stress, even if you need to rate-limit them. A queue system where users can redeem 10% per day during emergencies is vastly better than completely pausing redemptions. The latter guarantees panic; the former at least provides a path to stability.

Transparency cannot be optional—Stream operated with fundamental opacity: undisclosed insurance fund size, hidden fee structures (the alleged 60% retention), unnamed external fund manager, private Morpho markets not visible to normal users, and vague strategy descriptions like "dynamically hedged HFT and market making" that meant nothing concrete.

Every successful stablecoin recovery in history (USDC after Silicon Valley Bank, DAI's various minor depegs) involved transparent reserves and clear communication. Every catastrophic failure (Terra UST, Iron Finance, now Stream) involved opacity. The pattern is undeniable. Users and curators cannot properly assess risk without complete information about:

  • Collateral composition and location: exactly what assets back the stablecoin and where they're held
  • Custody arrangements: who controls private keys, what are the multisig thresholds, what external parties have access
  • Strategy descriptions: specific, not vague—"We lend 40% to Aave, 30% to Compound, 20% to Morpho, 10% reserves" not "lending arbitrage"
  • Leverage ratios: real-time dashboards showing actual backing versus outstanding tokens
  • Fee structures: all fees disclosed, no hidden charges or profit retention
  • External dependencies: if using external managers, their identity, track record, and specific mandate

Protocols should implement real-time Proof of Reserve dashboards (like Chainlink PoR) that anyone can verify on-chain. The technology exists; failing to use it is a choice that should be interpreted as a red flag.

Hybrid CeDeFi models require extraordinary safeguards—Stream promised DeFi benefits while depending on centralized fund managers. This "worst of both worlds" approach combined on-chain composability risks with off-chain counterparty risks. When the fund manager failed, Stream couldn't use on-chain emergency tools to recover, and they didn't have traditional finance safeguards like insurance, regulatory oversight, or custodial controls.

If protocols choose hybrid models, they need: real-time position monitoring and reporting from external managers (not monthly updates—real-time API access); multiple redundant managers with diversified mandates to avoid concentration risk; on-chain proof that external positions actually exist; clear custody arrangements with reputable institutional custodians; regular third-party audits of off-chain operations, not just smart contracts; and disclosed, adequate insurance covering external manager failures.

Alternatively, protocols should embrace full decentralization. DAI shows that pure on-chain, over-collateralized models can achieve stability (though with capital inefficiency costs). USDC shows that full centralization with transparency and regulatory compliance works. The hybrid middle ground is demonstrably the most dangerous approach.

Leverage limits and recursive strategies need constraints—Stream's 4x+ leverage through recursive looping turned a manageable loss into a systemic crisis. Protocols should implement: hard leverage caps (e.g., maximum 2x, absolutely not 4x+); automatic deleveraging when ratios are exceeded, not just warnings; restrictions on recursive looping—it inflates TVL metrics without creating real value; and diversification requirements across venues to avoid concentration in any single protocol.

The DeFi ecosystem should also standardize TVL calculation methodologies. DeFiLlama's decision to exclude recursive loops was correct—counting the same dollar multiple times misrepresents actual capital at risk. But the dispute highlighted that no industry standard exists. Regulators or industry groups should establish clear definitions.

Oracle design matters enormously—The decision by multiple protocols to hardcode xUSD's oracle price at $1.00 to prevent liquidation cascades backfired spectacularly. When oracles diverge from reality, risk management becomes impossible. Protocols should: use multiple independent price sources, include spot prices from DEXes alongside TWAP (time-weighted average prices), implement circuit breakers that pause operations rather than mask problems with false prices, and maintain adequate insurance funds to handle liquidation cascades rather than preventing liquidations through fake pricing.

The counterargument—that allowing liquidations would have caused a cascade—is valid but misses the point. The real solution is building systems robust enough to handle liquidations, not hiding from them.

Unsustainable yields signal danger—Stream offered 18% APY on stablecoin deposits when Aave offered 4-5%. That differential should have been a massive red flag. In finance, return correlates with risk (risk-return tradeoff is fundamental). When a protocol offers yields 3-4x higher than established competitors, the additional yield comes from additional risk. That risk might be leverage, counterparty exposure, smart contract complexity, or as in Stream's case, opaque external management.

Users, curators, and integrating protocols need to demand explanations for yield differentials. "We're just better at optimization" isn't sufficient—show specifically where the additional yield comes from, what risks enable it, and provide comparable examples.

The curator model needs reformation—Risk curators like TelosC, MEV Capital, and others were supposed to do due diligence before deploying capital to protocols like Stream. They had $123 million+ in exposure, suggesting they believed Stream was safe. They were catastrophically wrong. The curator business model creates problematic incentives: curators earn management fees on deployed capital, incentivizing them to maximize AUM (assets under management) rather than minimize risk. They retain profits during good times but externalize losses to their lenders during failures.

Better curator models should include: mandatory skin-in-the-game requirements (curators must maintain significant capital in their own vaults); regular public reporting on due diligence processes; clear risk ratings using standardized methodologies; insurance funds backed by curator profits to cover losses; and reputational accountability—curators who fail at due diligence should lose business, not just issue apologies.

DeFi's composability is both strength and fatal weakness—Stream's $93 million loss cascaded into $285 million in exposure because lending protocols, synthetic stablecoins, and curators all interconnected through xUSD. DeFi's composability—the ability to use one protocol's output as another's input—creates incredible capital efficiency but also contagion risk.

Protocols must understand their downstream dependencies: who accepts our tokens as collateral, what protocols depend on our price feeds, what second-order effects could our failure cause. They should implement concentration limits on how much exposure any single counterparty can have, maintain larger buffers between protocols (reduce rehypothecation chains), and conduct regular stress tests asking "What if the protocols we depend on fail?"

This is similar to lessons from 2008's financial crisis: complex interconnections through credit default swaps and mortgage-backed securities turned subprime mortgage losses into a global financial crisis. DeFi is recreating similar dynamics through composability.

How Stream compares to historical stablecoin failures

Understanding Stream within the context of previous major depeg events illuminates patterns and helps predict what might happen next.

Terra UST (May 2022): The death spiral prototype—Terra's collapse remains the archetypal stablecoin failure. UST was purely algorithmic, backed by LUNA governance tokens. When UST depegged, the protocol minted LUNA to restore parity, but this hyperinflated LUNA (supply increased from 400 million to 32 billion tokens), creating a death spiral where each intervention worsened the problem. The scale was enormous: $18 billion in UST + $40 billion in LUNA at peak, with $60 billion in direct losses and $200 billion in broader market impact. The collapse occurred over 3-4 days in May 2022 and triggered bankruptcies (Three Arrows Capital, Celsius, Voyager) and lasting regulatory scrutiny.

Similarities to Stream: Both experienced concentration risk (Terra had 75% of UST in Anchor Protocol offering 20% yields; Stream had opaque fund manager exposure). Both offered unsustainable yields signaling hidden risk. Both suffered loss of confidence triggering redemption spirals. Once redemption mechanisms became accelerants rather than stabilizers, collapse was rapid.

Differences: Terra was 200x larger in scale. Terra's failure was mathematical/algorithmic (the burn-and-mint mechanism created a predictable death spiral). Stream's was operational (fund manager failure, not algorithmic design flaw). Terra's impact was systemic to entire crypto markets; Stream's was more contained within DeFi. Terra's founders (Do Kwon) face criminal charges; Stream's investigation is civil/commercial.

The critical lesson: algorithmic stablecoins without adequate real collateral have uniformly failed. Stream had real collateral but not enough, and redemption access disappeared exactly when needed.

USDC (March 2023): Successful recovery through transparency—When Silicon Valley Bank collapsed in March 2023, Circle disclosed that $3.3 billion (8% of reserves) were at risk. USDC depegged to $0.87-0.88 (13% loss). The depeg lasted 48-72 hours over a weekend but fully recovered once FDIC guaranteed all SVB deposits. This represented a clean counterparty risk event with rapid resolution.

Similarities to Stream: Both involved counterparty risk (banking partner vs. external fund manager). Both had a percentage of reserves at risk. Both saw temporary redemption pathway constraints and flight to alternatives.

Differences: USDC maintained transparent reserve backing and regular attestations throughout, enabling users to calculate exposure. Government intervention provided backstop (FDIC guarantee)—no such safety net exists in DeFi. USDC maintained majority of backing; users knew they'd recover 92%+ even in worst case. Recovery was rapid due to this clarity. Depeg severity was 13% vs. Stream's 77%.

The lesson: transparency and external backing matter enormously. If Stream had disclosed exactly what assets backed xUSD and governmental or institutional guarantees covered portions, recovery might have been possible. Opacity removed this option.

Iron Finance (June 2021): Oracle lag and reflexive failure—Iron Finance operated a fractional algorithmic model (75% USDC, 25% TITAN governance token) with a critical design flaw: 10-minute TWAP oracle created a gap between oracle prices and real-time spot prices. When TITAN fell rapidly, arbitrageurs couldn't profit because oracle prices lagged, breaking the stabilization mechanism. TITAN collapsed from $65 to near-zero in hours, and IRON depegged from $1 to $0.74. Mark Cuban and other high-profile investors were affected, bringing mainstream attention.

Similarities to Stream: Both had partial collateralization models. Both relied on secondary tokens for stability. Both suffered from oracle/timing issues in price discovery. Both experienced "bank run" dynamics. Both collapsed in under 24 hours.

Differences: Iron Finance was partially algorithmic; Stream was yield-backed. TITAN had no external value; xUSD claimed real asset backing. Iron's mechanism flaw was mathematical (TWAP lag); Stream's was operational (fund manager loss). Iron Finance was smaller in absolute terms though larger in percentage terms (TITAN went to zero).

The technical lesson from Iron: oracles using time-weighted averages can't respond to rapid price movements, creating arbitrage disconnects. Real-time price feeds are essential even if they introduce short-term volatility.

DAI and others: The importance of over-collateralization—DAI has experienced multiple minor depegs throughout its history, typically ranging from $0.85 to $1.02, lasting minutes to days, and generally self-correcting through arbitrage. DAI is crypto-collateralized with over-collateralization requirements (typically 150%+ backing). During the USDC/SVB crisis, DAI depegged alongside USDC (correlation 0.98) because DAI held significant USDC in reserves, but recovered when USDC did.

The pattern: over-collateralized models with transparent on-chain backing can weather storms. They're capital-inefficient (you need $150 to mint $100 of stablecoin) but remarkably resilient. Under-collateralized and algorithmic models consistently fail under stress.

Systemic impact hierarchy—Comparing systemic effects:

  • Tier 1 (Catastrophic): Terra UST caused $200B market impact, multiple bankruptcies, regulatory responses worldwide
  • Tier 2 (Significant): Stream caused $285M debt exposure, secondary stablecoin failures (deUSD), exposed lending protocol vulnerabilities
  • Tier 3 (Contained): Iron Finance, various smaller algorithmic failures affected direct holders but limited contagion

Stream sits in the middle tier—significantly damaging to DeFi ecosystem but not threatening the broader crypto market or causing major company bankruptcies (yet—some outcomes remain uncertain).

Recovery patterns are predictable—Successful recoveries (USDC, DAI) involved: transparent communication from issuers, clear path to solvency, external support (government or arbitrageurs), majority of backing maintained, and strong existing reputation. Failed recoveries (Terra, Iron, Stream) involved: operational opacity, fundamental mechanism breakdown, no external backstop, confidence loss becoming irreversible, and long legal battles.

Stream shows zero signs of the successful pattern. The ongoing investigation with no updates, lack of disclosed recovery plan, continued depeg to $0.07-0.14, and frozen operations all indicate Stream is following the failure pattern, not the recovery pattern.

The broader lesson: stablecoin design fundamentally determines whether recovery from shocks is possible. Transparent, over-collateralized, or fully-reserved models can survive. Opaque, under-collateralized, algorithmic models cannot.

Regulatory and broader implications for web3

The Stream Finance collapse arrives at a critical juncture for crypto regulation and raises uncomfortable questions about DeFi's sustainability.

Strengthens the case for stablecoin regulation—Stream occurred in November 2025, following several years of regulatory debate about stablecoins. The US GENIUS Act was signed in July 2025, creating frameworks for stablecoin issuers, but enforcement details remained under discussion. Circle had called for equal treatment of different issuer types. Stream's failure provides regulators with a perfect case study: an under-regulated protocol promising stablecoin functionality while taking risks far exceeding traditional banking.

Expect regulators to use Stream as justification for: mandatory reserve disclosure and regular attestations from independent auditors; restrictions on what assets can back stablecoins (likely limiting exotic DeFi positions); capital requirements similar to traditional banking; licensing regimes that exclude protocols unable to meet transparency standards; and potentially restrictions on yield-bearing stablecoins altogether.

The EU's MiCAR (Markets in Crypto-Assets Regulation) already banned algorithmic stablecoins in 2023. Stream wasn't purely algorithmic but operated in a gray area. Regulators may extend restrictions to hybrid models or any stablecoin whose backing isn't transparent, static, and adequate.

The DeFi regulatory dilemma—Stream exposes a paradox: DeFi protocols often claim to be "just code" without central operators subject to regulation. Yet when failures occur, users demand accountability, investigations, and compensation—inherently centralized responses. Stream engaged lawyers, conducted investigations, and must decide creditor priorities. These are all functions of centralized entities.

Regulators are likely to conclude that DAOs with emergency powers effectively have fiduciary duties and should be regulated accordingly. If a protocol can pause operations, freeze funds, or make distributions, it has control sufficient to justify regulatory oversight. This threatens DeFi's fundamental premise of operating without traditional intermediaries.

Insurance and consumer protection gaps—Traditional finance has deposit insurance (FDIC in US, similar schemes globally), clearing house protections, and regulatory requirements for bank capital buffers. DeFi has none of these systemic protections. Stream's undisclosed "insurance fund" proved worthless. Individual protocols may maintain insurance, but there's no industry-wide safety net.

This suggests several possible futures: mandatory insurance requirements for DeFi protocols offering stablecoin or lending services (similar to bank insurance); industry-wide insurance pools funded by protocol fees; government-backed insurance extended to certain types of crypto assets meeting strict criteria; or continued lack of protection, effectively caveat emptor (buyer beware).

Impact on DeFi adoption and institutional participation—Stream's collapse reinforces barriers to institutional DeFi adoption. Traditional financial institutions face strict risk management, compliance, and fiduciary duty requirements. Events like Stream demonstrate that DeFi protocols often lack basic risk controls that traditional finance considers mandatory. This creates compliance risk for institutions—how can a pension fund justify exposure to protocols with 4x leverage, undisclosed external managers, and opaque strategies?

Institutional DeFi adoption likely requires a bifurcated market: regulated DeFi protocols meeting institutional standards (likely sacrificing some decentralization and innovation for compliance) versus experimental/retail DeFi operating with higher risk and caveat emptor principles. Stream's failure will push more institutional capital toward regulated options.

Concentration risk and systemic importance—One troubling aspect of Stream's failure was how interconnected it became before collapsing. Over $285 million in exposure across major lending protocols, 65% of Elixir's backing, positions in 50+ liquidity pools—Stream achieved systemic importance without any of the oversight that traditionally comes with it.

In traditional finance, institutions can be designated "systemically important financial institutions" (SIFIs) subject to enhanced regulation. DeFi has no equivalent. Should protocols reaching certain TVL thresholds or integration levels face additional requirements? This challenges DeFi's permissionless innovation model but may be necessary to prevent contagion.

The transparency paradox—DeFi's supposed advantage is transparency: all transactions on-chain, verifiable by anyone. Stream demonstrates this is insufficient. Raw on-chain data existed showing problems (CBB0FE found it, Schlag found it), but most users and curators didn't analyze it or didn't act on it. Additionally, Stream used "hidden markets" on Morpho and off-chain fund managers, creating opacity within supposedly transparent systems.

This suggests on-chain transparency alone is insufficient. We need: standardized disclosure formats that users can actually understand; third-party rating agencies or services that analyze protocols and publish risk assessments; regulatory requirements that certain information be presented in plain language, not just available in raw blockchain data; and tools that aggregate and interpret on-chain data for non-experts.

Long-term viability of yield-bearing stablecoins—Stream's failure raises fundamental questions about whether yield-bearing stablecoins are viable. Traditional stablecoins (USDC, USDT) are simple: fiat reserves backing tokens 1:1. They're stable precisely because they don't try to generate yield for holders—the issuer might earn interest on reserves, but token holders receive stability, not yield.

Yield-bearing stablecoins attempt to have both: maintain $1 peg AND generate returns. But returns require risk, and risk threatens the peg. Terra tried this with 20% yields from Anchor. Stream tried with 12-18% yields from leveraged DeFi strategies. Both failed catastrophically. This suggests a fundamental incompatibility: you cannot simultaneously offer yield and absolute peg stability without taking risks that eventually break the peg.

The implication: the stablecoin market may consolidate around fully-reserved, non-yield-bearing models (USDC, USDT with proper attestations) and over-collateralized decentralized models (DAI). Yield-bearing experiments will continue but should be recognized as higher-risk instruments, not true stablecoins.

Lessons for Web3 builders—Beyond stablecoins specifically, Stream offers lessons for all Web3 protocol design:

Transparency cannot be retrofitted: Build it from day one. If your protocol depends on off-chain components, implement extraordinary monitoring and disclosure.

Composability creates responsibility: If other protocols depend on yours, you have systemic responsibility even if you're "just code." Plan accordingly.

Yield optimization has limits: Users should be skeptical of yields significantly exceeding market rates. Builders should be honest about where yields come from and what risks enable them.

User protection requires mechanisms: Emergency pause functions, insurance funds, recovery procedures—these need to be built before disasters, not during.

Decentralization is a spectrum: Decide where on that spectrum your protocol sits and be honest about tradeoffs. Partial decentralization (hybrid models) may combine worst aspects of both worlds.

The Stream Finance xUSD collapse will be studied for years as a case study in what not to do: opacity masquerading as transparency, unsustainable yields indicating hidden risk, recursive leverage creating phantom value, hybrid models combining multiple attack surfaces, and operational failures in systems claiming to be trustless. For Web3 to mature into a genuine alternative to traditional finance, it must learn these lessons and build systems that don't repeat Stream's mistakes.

Crypto's Coming of Age: A16Z's 2025 Roadmap

· 24 min read
Dora Noda
Software Engineer

The A16Z State of Crypto 2025 report declares this "the year the world came onchain," marking crypto's transition from adolescent speculation to institutional utility. Released October 21, 2025, the report reveals that the crypto market has crossed $4 trillion for the first time, with traditional finance giants like BlackRock, JPMorgan, and Visa now actively offering crypto products. Most critically for builders, the infrastructure is finally ready—transaction throughput has grown 100x in five years to 3,400 TPS while costs plummeted from $24 to less than one cent on Layer 2s. The convergence of regulatory clarity (the GENIUS Act passed in July 2025), institutional adoption, and infrastructure maturation creates what A16Z calls "the enterprise adoption era."

The report identifies a massive conversion opportunity: 716 million people own crypto but only 40-70 million actively use it onchain. This 90-95% gap between passive holders and active users represents the primary target for web3 builders. Stablecoins have achieved clear product-market fit with $46 trillion in annual transaction volume—five times PayPal's throughput—and are projected to grow tenfold to $3 trillion by 2030. Meanwhile, emerging sectors like decentralized physical infrastructure networks (DePIN) are forecasted to reach $3.5 trillion by 2028, while the AI agent economy could hit $30 trillion by 2030. For builders, the message is unambiguous: the speculation era is over, and the utility era has begun.

Infrastructure reaches prime time after years of false starts

The technical foundation that frustrated developers for years has fundamentally transformed. Blockchains now process 3,400 transactions per second collectively—on par with Nasdaq's completed trades and Stripe's Black Friday throughput—compared to fewer than 25 TPS five years ago. Transaction costs on Ethereum Layer 2 networks dropped from approximately $24 in 2021 to under a penny today, making consumer applications economically viable for the first time. This isn't incremental progress; it represents the crossing of a critical threshold where infrastructure performance no longer constrains mainstream product development.

The ecosystem dynamics have shifted dramatically as well. Solana experienced 78% growth in builder interest over two years, becoming the fastest-growing ecosystem with native applications generating $3 billion in revenue during the past year. Ethereum combined with its Layer 2s remains the top destination for new developers, though most economic activity has migrated to L2s like Arbitrum, Base, and Optimism. Notably, Hyperliquid and Solana now account for 53% of revenue-generating economic activity—a stark departure from historical Bitcoin and Ethereum dominance. This represents a genuine shift from infrastructure speculation to application-layer value creation.

Privacy and security infrastructure has matured substantially. Google searches for crypto privacy surged in 2025, while Zcash's shielded pool grew to nearly 4 million ZEC and Railgun's transaction flows surpassed $200 million monthly. The Office of Foreign Assets Control lifted sanctions on Tornado Cash, signaling regulatory acceptance of privacy tools. Zero-knowledge proof systems are now integrated across rollups, compliance tools, and even mainstream web services—Google launched a new ZK identity system this year. However, urgency is building around post-quantum cryptography, as roughly $750 billion in Bitcoin sits in addresses vulnerable to future quantum attacks, with the U.S. government planning to transition federal systems to post-quantum algorithms by 2035.

Stablecoins emerge as crypto's first undeniable product-market fit

The numbers tell a story of genuine mainstream adoption. Stablecoins processed $46 trillion in total transaction volume over the past year, up 106% year-over-year, with $9 trillion in adjusted volume after filtering out bot activity—an 87% increase that represents five times PayPal's throughput. Monthly adjusted volume approached $1.25 trillion in September 2025 alone, a new all-time high. The stablecoin supply reached a record $300+ billion, with Tether and USDC accounting for 87% of the total. Over 99% of stablecoins are USD-denominated, and more than 1% of all U.S. dollars now exist as tokenized stablecoins on public blockchains.

The macroeconomic implications extend beyond transaction volume. Stablecoins collectively hold over $150 billion in U.S. Treasuries, making them the 17th largest holder—up from 20th last year—surpassing many sovereign nations. Tether alone holds roughly $127 billion in Treasury bills. This positioning strengthens dollar dominance globally at a time when many foreign central banks are reducing their Treasury holdings. The infrastructure enables transferring dollars in less than one second for less than one cent, functioning almost anywhere in the world without gatekeepers, minimum balances, or proprietary SDKs.

The use case has fundamentally evolved. In years past, stablecoins primarily settled speculative crypto trades. Now they function as the fastest, cheapest, most global way to send dollars, with activity largely uncorrelated with broader crypto trading volume—indicating genuine non-speculative use. Stripe's acquisition of Bridge (a stablecoin infrastructure platform) just five days after A16Z's previous report declared stablecoins had found product-market fit signaled that major fintech companies recognized this shift. Circle's billion-dollar IPO in 2025, which saw shares increase 300%, marked the arrival of stablecoin issuers as legitimate mainstream financial institutions.

For builders, A16Z partner Sam Broner identifies specific near-term opportunities: small and medium businesses with painful payment costs will adopt first. Restaurants and coffee shops where 30 cents per transaction represents significant margin loss on captive audiences are prime targets. Enterprises can add the 2-3% credit card fee directly to their bottom line by switching to stablecoins. However, this creates new infrastructure needs—builders must develop solutions for fraud protection, identity verification, and other services credit card companies currently provide. The regulatory framework is now in place following the GENIUS Act's passage in July 2025, which established clear stablecoin oversight and reserve requirements.

Converting crypto's 617 million inactive users becomes the central challenge

Perhaps the report's most striking finding is the massive gap between ownership and usage. While 716 million people globally own crypto (up 16% from last year), only 40-70 million actively use crypto onchain—meaning 90-95% are passive holders. Mobile wallet users reached an all-time high of 35 million, up 20% year-over-year, but this still represents only a fraction of owners. Monthly active addresses onchain actually decreased 18% to 181 million, suggesting some cooling despite overall ownership growth.

Geographic patterns reveal distinct opportunities. Mobile wallet usage grew fastest in emerging markets: Argentina saw a 16-fold increase over three years amid its currency crisis, while Colombia, India, and Nigeria showed similarly strong growth driven by currency hedging and remittance use cases. Developed markets like Australia and South Korea lead in token-related web traffic but skew heavily toward trading and speculation rather than utility applications. This bifurcation suggests builders should pursue fundamentally different strategies based on regional needs—payment and value storage solutions for emerging markets versus sophisticated trading infrastructure for developed economies.

The passive-to-active conversion represents a fundamentally easier problem than acquiring entirely new users. As A16Z partner Daren Matsuoka emphasizes, these 617 million people already overcame the initial hurdles of acquiring crypto, understanding wallets, and navigating exchanges. They represent a pre-qualified audience waiting for applications worth their attention. The infrastructure improvements—particularly the cost reductions making microtransactions viable—now enable the consumer experiences that can drive this conversion.

Critically, the user experience remains crypto's Achilles heel despite technical progress. Self-custodying secret keys, connecting wallets, navigating multiple network endpoints, and parsing industry jargon like "NFTs" and "zkRollups" still create massive barriers. As the report acknowledges, "it's still too complicated"—the fundamentals of crypto UX remain largely unchanged since 2016. Distribution channels also constrain growth, as Apple's App Store and Google Play block or limit crypto applications. Emerging alternatives like World App's marketplace and Solana's fee-free dApp Store have shown traction, with World App onboarding hundreds of thousands of users within days of launch, but porting web2's distribution advantages onchain remains difficult outside of Telegram's TON ecosystem.

Institutional adoption transforms competitive dynamics for builders

The list of traditional finance and tech giants now offering crypto products reads like a who's who of global finance: BlackRock, Fidelity, JPMorgan Chase, Citigroup, Morgan Stanley, Mastercard, Visa, PayPal, Stripe, Robinhood, Shopify, and Circle. This isn't experimental dabbling—these are core product offerings generating substantial revenue. Robinhood's crypto revenue reached 2.5 times its equities trading business in Q2 2025. Bitcoin ETFs collectively manage $150.2 billion as of September 2025, with BlackRock's iShares Bitcoin Trust (IBIT) cited as the most traded Bitcoin ETP launch of all time. Exchange-traded products hold over $175 billion in onchain crypto holdings, up 169% from $65 billion a year ago.

Circle's IPO performance captures the shift in sentiment. As one of 2025's top-performing IPOs with a 300% share price increase, it demonstrated that public markets now embrace crypto-native companies building legitimate financial infrastructure. The 64% increase in stablecoin mentions in SEC filings since regulatory clarity arrived shows major corporations are actively integrating this technology into their operations. Digital Asset Treasury companies and ETPs combined now hold approximately 10% of both Bitcoin and Ethereum token supplies—a concentration of institutional ownership that fundamentally changes market dynamics.

This institutional wave creates both opportunities and challenges for crypto-native builders. The total addressable market has expanded by orders of magnitude—the Global 2000 represents vast enterprise software spend, cloud infrastructure spend, and assets under management now accessible to crypto startups. However, builders face a harsh reality: these institutional customers have fundamentally different buying criteria than crypto-native users. A16Z explicitly warns that "'the best products sell themselves' is a long-lived fallacy" when selling to enterprises. What worked with crypto-native customers—breakthrough technology and community alignment—gets you only 30% of the way with institutional buyers focused on ROI, risk mitigation, compliance, and integration with legacy systems.

The report dedicates substantial attention to enterprise sales as a critical competency crypto builders must develop. Enterprises make ROI-driven decisions, not technology-driven ones. They demand structured procurement processes, legal negotiations, solutions architecture for integration, and ongoing customer success support to prevent implementation failures. Career risk considerations matter for internal champions—they need cover to justify blockchain adoption to skeptical executives. Successful builders must translate technical features into measurable business outcomes, master pricing strategies and contract negotiations, and build sales development teams sooner rather than later. As A16Z emphasizes, best GTM strategies are built through iteration over time, making early investment in sales capabilities essential.

Building opportunities concentrate in proven use cases and emerging convergence

The report identifies specific sectors already generating substantial revenue and showing clear product-market fit. Perpetual futures volumes increased nearly eight-fold in the past year, with Hyperliquid alone generating over $1 billion in annualized revenue—rivaling some centralized exchanges. Nearly one-fifth of all spot trading volume now happens on decentralized exchanges, demonstrating that DeFi has moved beyond a niche. Real-world assets reached a $30 billion market, growing nearly fourfold in two years as U.S. Treasuries, money-market funds, private credit, and real estate get tokenized. These aren't speculative bets; they're operational businesses generating measurable revenue today.

DePIN represents one of the highest-conviction forward-looking opportunities. The World Economic Forum projects the decentralized physical infrastructure networks category will grow to $3.5 trillion by 2028. Helium's network already serves 1.4 million daily active users across 111,000+ user-operated hotspots providing 5G cellular coverage. The model of using token incentives to bootstrap physical infrastructure networks has proven viable at scale. Wyoming's DUNA legal structure provides DAOs with legitimate incorporation, liability protection, and tax clarity—removing a major obstacle that previously made operating these networks legally precarious. Builders can now pursue opportunities in wireless networks, distributed energy grids, sensor networks, and transportation infrastructure with clear regulatory frameworks.

The AI-crypto convergence creates perhaps the most speculative but potentially transformative opportunities. With 88% of AI-native company revenue controlled by just OpenAI and Anthropic, and 63% of cloud infrastructure controlled by Amazon, Microsoft, and Google, crypto offers a counterbalance to AI's centralizing forces. Gartner estimates the machine customer economy could reach $30 trillion by 2030 as AI agents become autonomous economic participants. Protocol standards like x402 are emerging as financial backbones for autonomous AI agents to make payments, access APIs, and participate in markets. World has verified over 17 million people for proof-of-personhood, establishing a model for differentiating humans from AI-generated content and bots—increasingly critical as AI proliferates.

A16Z's Eddy Lazzarin highlights decentralized autonomous chatbots (DACs) as a frontier: chatbots running in Trusted Execution Environments that build social media followings, generate income from their audiences, manage crypto assets, and operate entirely autonomously. These could become the first truly autonomous billion-dollar entities. More pragmatically, AI agents need wallets to participate in DePIN networks, execute high-value gaming transactions, and operate their own blockchains. The infrastructure for AI-agent wallets, payment rails, and autonomous transaction capabilities represents greenfield territory for builders.

Strategic imperatives separate winners from the also-rans

The report outlines clear strategic shifts required for success in crypto's maturation phase. The most fundamental is what A16Z calls "hiding the wires"—successful products don't explain their underlying technology, they solve problems. Email users don't think about SMTP protocols; they click send. Credit card users don't consider payment rails; they swipe. Spotify delivers playlists, not file formats. The era of expecting users to understand EIPs, wallet providers, and network architectures is over. Builders must abstract away technical complexity, design simply, and communicate clearly. Over-engineering breeds fragility; simplicity scales.

This connects to a paradigm shift from infrastructure-first to user-first design. Previously, crypto startups chose their infrastructure—specific chains, token standards, wallet providers—which then constrained their user experience. With maturing developer tooling and abundant programmable blockspace, the model inverts: define the desired end-user experience first, then select appropriate infrastructure to enable it. Chain abstraction and modular architecture democratize this approach, allowing designers without deep technical knowledge to enter crypto. Critically, startups no longer need to over-index on specific infrastructure decisions before finding product-market fit—they can focus on actually finding product-market fit and iterate on technical choices as they learn.

The "build with, not from scratch" principle represents another strategic shift. Too many teams have been reinventing the wheel—building bespoke validator sets, consensus protocols, programming languages, and execution environments. This wastes massive time and effort while often producing specialized solutions that lack baseline functionality like compiler optimizations, developer tooling, AI programming support, and learning materials that mature platforms provide. A16Z's Joachim Neu expects more teams to leverage off-the-shelf blockchain infrastructure components in 2025—from consensus protocols and existing staked capital to proof systems—focusing instead on differentiating product value where they can add unique contributions.

Regulatory clarity enables a fundamental shift in token economics. The GENIUS Act's passage establishing stablecoin frameworks and the CLARITY Act's progression through Congress create a clear path for tokens to generate revenue via fees and accrue value to tokenholders. This completes what the report calls the "economic loop"—tokens become viable as "new digital primitives" akin to what websites were for previous internet generations. Crypto projects brought in $18 billion last year, with $4 billion flowing to tokenholders. With regulatory frameworks established, builders can design sustainable token economies with real cash flows rather than speculation-dependent models. Structures like Wyoming's DUNA give DAOs legal legitimacy, enabling them to engage in economic activity while managing tax and compliance obligations that previously operated in gray areas.

The enterprise sales imperative nobody wants to hear

Perhaps the report's most uncomfortable message for crypto-native builders is that enterprise sales capability has become non-negotiable. A16Z dedicates an entire companion piece to making this case, emphasizing that the customer base has fundamentally changed from crypto insiders to mainstream enterprises and traditional institutions. These customers don't care about breakthrough technology or community alignment—they care about return on investment, risk mitigation, integration with existing systems, and compliance frameworks. The procurement process involves lengthy negotiations over pricing models, contract duration, termination rights, support SLAs, indemnification, liability limits, and governing law considerations.

Successful crypto companies must build dedicated sales functions: sales development representatives to generate qualified leads from mainstream customers, account executives to interface with prospects and close deals, solutions architects who are deep technical experts for customer integration, and customer success teams for post-sale support. Most enterprise integration projects fail, and when they do, customers blame the product regardless of whether process issues caused the failure. Building these functions "sooner than later" is essential because best sales strategies are built through iteration over time—you can't suddenly develop enterprise sales capability when demand overwhelms you.

The mindset shift is profound. In crypto-native communities, products often found users through organic community growth, crypto Twitter virality, or Farcaster discussions. Enterprise customers don't hang out in these channels. Discovery and distribution require structured outbound strategies, partnerships with established institutions, and traditional marketing. Messaging must translate from crypto jargon into business language that CFOs and CTOs understand. Competitive positioning requires demonstrating specific, measurable advantages rather than relying on technical purity or philosophical alignment. Every step of the sales process requires deliberate strategy, not just charm or product benefits—it's "games of inches," as A16Z describes it.

This represents an existential challenge for many crypto builders who entered the space precisely because they preferred building technology to selling it. The meritocratic ideal that great products naturally find users through viral growth has proven insufficient at the enterprise level. The cognitive and resource demands of enterprise sales compete directly with engineering-focused cultures. However, the alternative is ceding the massive enterprise opportunity to traditional software companies and financial institutions that excel at sales but lack crypto-native expertise. Those who master both technical excellence and sales execution will capture disproportionate value as the world comes onchain.

Geographic and demographic patterns reveal distinct building strategies

Regional dynamics suggest wildly different approaches for builders depending on their target markets. Emerging markets show the strongest growth in actual crypto usage rather than speculation. Argentina's 16-fold increase in mobile wallet users over three years directly correlates with its currency crisis—people use crypto for value storage and payments, not trading. Colombia, India, and Nigeria follow similar patterns, with growth driven by remittances, currency hedging, and accessing dollar-denominated stablecoins when local currencies prove unreliable. These markets demand simple, reliable payment solutions with local fiat on-ramps and off-ramps, mobile-first design, and resilience to intermittent connectivity.

Developed markets like Australia and South Korea exhibit opposite behavior—high token-related web traffic but focus on trading and speculation rather than utility. These users demand sophisticated trading infrastructure, derivatives products, analytics tools, and low-latency execution. They're more likely to engage with complex DeFi protocols and advanced financial products. The infrastructure requirements and user experiences for these markets differ fundamentally from emerging market needs, suggesting specialization rather than one-size-fits-all approaches.

The report notes that 70% of crypto developers were offshore due to previous regulatory uncertainty in the United States, but this is reversing with improved clarity. The GENIUS Act and CLARITY Act signal that building in the U.S. is viable again, though most developers remain distributed globally. For builders targeting Asian markets specifically, the report emphasizes that success requires physical local presence, alignment with local ecosystems, and partnerships for legitimacy—remote-first approaches that work in Western markets often fail in Asia where relationships and on-the-ground presence matter more than the underlying technology.

The report directly addresses the elephant in the room: 13 million memecoins launched in the past year. However, launches have cooled substantially—56% fewer in September compared to January—as regulatory improvements reduce the appeal of pure speculation plays. Notably, 94% of memecoin owners also own other crypto, suggesting memecoins function more as an onramp or gateway than a destination. Many users enter crypto through memecoins drawn by social dynamics and potential returns, then gradually explore other applications and use cases.

This data point matters because critics of crypto often point to memecoin proliferation as evidence the entire industry remains a speculative casino. Stephen Diehl, a prominent crypto skeptic, published "The Case Against Crypto in 2025" arguing that crypto is "intellectual three-card monte designed to exhaust and confuse critics" that "morphs into whatever its marks most desperately want to see." He highlights use in sanctions evasion, narcotics trade money laundering, and the fact that "the only consistent thread is the promise of getting rich through speculation rather than productive work."

The A16Z report implicitly rebuts this by emphasizing the shift from speculation to utility. Stablecoin transaction volume being largely uncorrelated with broader crypto trading volumes demonstrates genuine non-speculative use. The enterprise adoption wave by JPMorgan, BlackRock, and Visa suggests legitimate institutions have found real applications beyond speculation. The $3 billion in revenue generated by Solana native applications and Hyperliquid's $1 billion in annualized revenue represent actual value creation, not just speculative trading. The convergence toward proven use cases—payments, remittances, tokenized real-world assets, decentralized infrastructure—indicates market maturation even as speculative elements persist.

For builders, the strategic implication is clear: focus on use cases with genuine utility that solve real problems rather than speculative instruments. The regulatory environment is improving for legitimate applications while becoming more hostile to pure speculation. Enterprise customers demand compliance and legitimate business models. The passive-to-active user conversion depends on applications worth using beyond price speculation. Memecoins may serve as marketing or community-building tools, but sustainable businesses will be built on infrastructure, payments, DeFi, DePIN, and AI integration.

What mainstream really means and why 2025 is different

The report's declaration that crypto has "left its adolescence and entered adulthood" isn't mere rhetoric—it reflects concrete shifts across multiple dimensions. Three years ago when A16Z started this report series, blockchains were "much slower, more expensive, and less reliable." Transaction costs that made consumer applications economically nonviable, throughput that limited scale to niche use cases, and reliability issues that prevented enterprise adoption have all been addressed through Layer 2s, improved consensus mechanisms, and infrastructure optimization. The 100x throughput improvement represents crossing from "interesting technology" to "production-ready infrastructure."

The regulatory transformation particularly stands out. The United States reversed its "formerly antagonistic stance toward crypto" through bipartisan legislation. The GENIUS Act providing stablecoin clarity and the CLARITY Act establishing market structure passed with support from both parties—a remarkable achievement for a previously polarizing issue. Executive Order 14178 reversed earlier anti-crypto directives and created a cross-agency task force. This isn't just permission; it's active support for the industry's development balanced with investor protection concerns. Other jurisdictions are following suit—the UK is exploring issuing government bonds onchain through the FCA sandbox, signaling that sovereign debt tokenization may become normalized.

The institutional participation represents genuine mainstreaming rather than exploratory pilots. When BlackRock's Bitcoin ETP becomes the most traded launch of all time, when Circle IPOs with a 300% pop, when Stripe acquires stablecoin infrastructure for over a billion dollars, when Robinhood generates 2.5x more revenue from crypto than equities—these aren't experiments. These are strategic bets by sophisticated institutions with massive resources and regulatory scrutiny. Their participation validates crypto's legitimacy and brings distribution advantages that crypto-native companies cannot match. If development continues along current trajectories, crypto becomes deeply integrated into everyday financial services rather than remaining a separate category.

The shift in use cases from speculation to utility represents perhaps the most important transformation. In years past, stablecoins primarily settled crypto trades between exchanges. Now they're the fastest, cheapest way to send dollars globally, with transaction patterns uncorrelated with crypto price movements. Real-world assets aren't a future promise; $30 billion in tokenized Treasuries, credit, and real estate operate today. DePIN isn't vaporware; Helium serves 1.4 million daily users. Perpetual futures DEXs don't just exist; they generate over $1 billion in annual revenue. The economic loop is closing—networks generate real value, fees accrue to tokenholders, and sustainable business models emerge beyond speculation and venture capital subsidy.

The path forward requires uncomfortable evolution

The synthesis of A16Z's analysis points to an uncomfortable truth for many crypto-native builders: succeeding in crypto's mainstream era requires becoming less crypto-native in approach. The technical purity that built the infrastructure must give way to user experience pragmatism. The community-driven go-to-market that worked in crypto's early days must be supplemented—or replaced—by enterprise sales capabilities. The ideological alignment that motivated early adopters won't matter to enterprises evaluating ROI. The transparent, on-chain operations that defined crypto's ethos must sometimes be hidden behind simple interfaces that never mention blockchains.

This doesn't mean abandoning crypto's core value propositions—permissionless innovation, composability, global accessibility, and user ownership remain differentiating advantages. Rather, it means recognizing that mainstream adoption requires meeting users and enterprises where they are, not expecting them to climb the learning curve crypto natives already conquered. The 617 million passive holders and billions of potential new users won't learn to use complex wallets, understand gas optimization, or care about consensus mechanisms. They'll use crypto when it solves their problems better than alternatives while being equally or more convenient.

The opportunity is immense but time-limited. Infrastructure readiness, regulatory clarity, and institutional interest have aligned in a rare confluence. However, traditional financial institutions and tech giants now have clear paths to integrate crypto into their existing products. If crypto-native builders don't capture the mainstream opportunity through superior execution, well-resourced incumbents with established distribution will. The next phase of crypto's evolution won't be won by the most innovative technology or the purest decentralization—it will be won by the teams that combine technical excellence with enterprise sales execution, abstract complexity behind delightful user experiences, and focus relentlessly on use cases with genuine product-market fit.

The data supports cautious optimism. Market capitalization at $4 trillion, stablecoin volumes rivaling global payment networks, institutional adoption accelerating, and regulatory frameworks emerging suggest the foundation is solid. DePIN's projected growth to $3.5 trillion by 2028, the AI agent economy potentially reaching $30 trillion by 2030, and stablecoins scaling to $3 trillion all represent genuine opportunities if builders execute effectively. The shift from 40-70 million active users toward the 716 million who already own crypto—and eventually billions beyond—is achievable with the right products, distribution strategies, and user experiences. Whether crypto-native builders rise to meet this moment or cede the opportunity to traditional tech and finance will define the industry's next decade.

Conclusion: The infrastructure era ends, the application era begins

A16Z's State of Crypto 2025 report marks an inflection point—the problems that constrained crypto for years have been substantially solved, revealing that infrastructure was never the primary barrier to mainstream adoption. With 100x throughput improvements, sub-penny transaction costs, regulatory clarity, and institutional support, the excuse that "we're still building the rails" no longer applies. The challenge has shifted entirely to the application layer: converting passive holders to active users, abstracting complexity behind intuitive experiences, mastering enterprise sales, and focusing on use cases with genuine utility rather than speculative appeal.

The most actionable insight is perhaps the most prosaic: crypto builders must become great product companies first and crypto companies second. The technical foundation exists. The regulatory frameworks are emerging. The institutions are entering. What's missing are applications that mainstream users and enterprises want to use not because they believe in decentralization but because they work better than alternatives. Stablecoins achieved this by being faster, cheaper, and more accessible than traditional dollar transfers. The next wave of successful crypto products will follow the same pattern—solving real problems with measurably superior solutions that happen to use blockchains rather than leading with blockchain technology seeking problems.

The 2025 report ultimately poses a challenge to the entire crypto ecosystem: the adolescent phase where experimentation, speculation, and infrastructure development dominated is over. Crypto has the tools, the attention, and the opportunity to remake global financial systems, upgrade payment infrastructure, enable autonomous AI economies, and create genuine user ownership of digital platforms. Whether the industry graduates to genuine mainstream utility or remains a niche speculative asset class depends on execution over the next few years. For builders entering or operating in web3, the message is clear—the infrastructure is ready, the market is open, and the time to build products that matter is now.

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.

Wall Street’s Biggest Macro Shift Since the Gold Standard

· 15 min read
Dora Noda
Software Engineer

Introduction

The U.S. dollar’s decoupling from gold in August 1971 (the Nixon Shock) marked a watershed moment in monetary history. By closing the Treasury’s “gold window” the United States transformed the dollar into a free‑floating fiat currency. A Harvard thesis describes how the dollar’s value stopped tracking gold and instead derived its worth from government decree; this change allowed the U.S. to print money without having to maintain gold reserves. The post‑1971 regime made international currencies “floating,” created a debt‑based monetary system and facilitated a surge in government borrowing. This move helped spur rapid credit creation and the petrodollar arrangement—oil producers priced their product in dollars and reinvested surplus dollars in U.S. debt. While fiat money facilitated economic growth, it also introduced vulnerabilities: currency values became functions of institutional credibility rather than physical backing, creating the potential for inflation, political manipulation and debt accumulation.

More than five decades later, a new monetary transition is underway. Digital assets—particularly cryptocurrencies and stablecoins—are challenging the dominance of fiat money and transforming the plumbing of global finance. A 2025 white‑paper from researchers McNamara and Marpu calls stablecoins “the most significant evolution in banking since the abandonment of the gold standard,” arguing that they could enable a Banking 2.0 system that seamlessly integrates cryptocurrency innovation with traditional finance. Fundstrat’s Tom Lee has popularised the idea that Wall Street is experiencing its “biggest macro shift since the gold standard”; he likens the current moment to 1971 because digital assets are catalysing structural changes in capital markets, payment systems and monetary policy. The following sections examine how crypto’s rise parallels and diverges from the 1971 shift, why it constitutes a macro pivot, and what it means for Wall Street.

From Gold‑Backed Money to Fiat and Debt‑Based Money

Under the Bretton Woods system (1944‑1971) the dollar was convertible to gold at $35 per ounce, anchoring global exchange rates. Pressures from inflation, the Vietnam War and growing U.S. deficits caused gold outflows and speculative attacks. By 1971 the dollar started to devalue against European currencies, and President Nixon suspended gold convertibility. After the “gold window” closed, the dollar became a floating currency whose supply could expand without metal backing. Economist J. Robinson notes that fiat currencies do not derive value from anything tangible; their worth depends on scarcity maintained by the issuing government. With no commodity constraint, the U.S. could print money to fund wars and domestic programs, fuelling credit booms and persistent fiscal deficits.

This shift had profound macro implications:

  1. Debt‑based monetary system: fiat currency allowed governments, businesses and consumers to spend more than they had, fostering a credit‑driven economy.
  2. Petrodollar arrangement: the U.S. convinced oil‑producing nations to price oil in dollars and invest surplus dollars in U.S. Treasury securities, creating permanent demand for dollars and U.S. debt. The arrangement strengthened dollar hegemony but tethered global finance to energy markets.
  3. Currency floating and volatility: with the gold anchor removed, exchange rates floated and became subject to market forces. Currency instability made reserve management a critical function for central banks. The Cato Institute explains that by mid‑2024 monetary authorities held roughly $12.3 trillion in foreign exchange and 29,030 metric tons of gold (≈$2.2 trillion); gold still comprised about 15 % of global reserves because it hedges currency risk and political risk.

Macro Conditions Driving the New Shift

Several structural forces in the 2020s–2025s have set the stage for another monetary pivot:

  1. Inflation–productivity imbalance: the Banking 2.0 white‑paper notes that unlimited monetary expansion has created money supplies that grow faster than productivity. The U.S. money supply expanded dramatically after the 2008 crisis and the COVID‑19 response while productivity growth stagnated. This divergence produces persistent inflation that erodes purchasing power and savings, especially for middle‑ and lower‑income households.
  2. Loss of trust in fiat systems: fiat money depends on institutional credibility. Unlimited money creation and rising public debt have undermined confidence in some currencies. Countries like Switzerland, Singapore, the United Arab Emirates and Saudi Arabia now maintain significant gold reserves and increasingly explore crypto reserves as hedges.
  3. De‑dollarization: a 2025 news report notes that central banks are diversifying reserves away from the U.S. dollar amid inflation, U.S. debt and geopolitical tensions, shifting into gold and considering Bitcoin. BlackRock highlighted this trend, observing that non‑dollar reserves are rising while dollar reserves decline. The report emphasises that Bitcoin, due to its limited supply and blockchain transparency, is gaining attention as “digital gold”.
  4. Technological maturation: blockchain infrastructure matured after 2019, enabling decentralized networks that can process payments 24/7. The COVID‑19 pandemic exposed the fragility of traditional payment systems and accelerated the adoption of crypto for remittances and commerce.
  5. Regulatory clarity and institutional adoption: the U.S. Securities and Exchange Commission approved spot Bitcoin exchange‑traded funds (ETFs) in early 2024 (not directly quoted in sources but widely reported), and the GENIUS Act of 2025 created a regulatory framework for stablecoins. Institutional investors such as PayPal, JPMorgan and major asset managers have integrated crypto payment services and tokenized assets, signalling mainstream acceptance.

Stablecoins: Bridging Crypto and Traditional Finance

Stablecoins are digital tokens designed to maintain a stable value, typically pegged to a fiat currency. The 2025 Banking 2.0 white‑paper argues that stablecoins are poised to become the foundational infrastructure of future banking systems. The authors assert that this transformation is “the most significant evolution in banking since the abandonment of the gold standard” because stablecoins integrate cryptocurrency innovation with traditional finance, offering a stable alternative that unifies global transactions, reduces fees and settlement times and delivers superior value to end‑users. Several developments illustrate this shift:

Institutional adoption and regulatory frameworks

  • GENIUS Act (2025): The Futurist Speaker’s 2025 article notes that President Trump signed the GENIUS Act on 18 July 2025, the first comprehensive federal framework for stablecoin regulation. The law gives the Federal Reserve oversight of large stablecoin issuers and provides them access to master accounts, legitimising stablecoins as components of the U.S. monetary system and positioning the Fed as the infrastructure provider for private stablecoin operations.
  • Explosive growth and payment volume: By 2024 stablecoin transfer volume reached $27.6 trillion, surpassing the combined throughput of Visa and Mastercard, and the market capitalisation of stablecoins reached $260 billion. Tether accounted for $154 billion and became the third‑largest cryptocurrency. Such volumes demonstrate that stablecoins have evolved from niche trading tools into critical payment infrastructure processing more value than the world’s largest card networks.
  • Impact on dollar dominance: A senior U.S. Treasury official stated that stablecoin growth would have “significant impact on the dominance of the US dollar and demand for US debt”. By providing programmable alternatives to bank deposits and Treasury securities, large‑scale stablecoin adoption could reduce reliance on the existing dollar‑based financial system.
  • Corporate stablecoins: The Futurist Speaker article predicts that by 2027 Amazon and Walmart will issue branded stablecoins, transforming shopping into closed‑loop financial ecosystems that bypass banks. Large merchants are drawn by near‑zero payment costs; credit‑card fees typically amount to 2–4 % per transaction, whereas stablecoins offer instant settlement with negligible fees.

Advantages over traditional fiat systems

Stablecoins address vulnerabilities inherent in fiat money. Modern fiat currencies derive value entirely from institutional trust rather than physical backing. Unlimited creation of fiat money creates inflation risk and makes currencies vulnerable to political manipulation. Stablecoins mitigate these vulnerabilities by using diversified reserves (cash, government bonds, commodities or even crypto collateral) and transparent on‑chain accounting. The Banking 2.0 paper argues that stablecoins provide enhanced stability, reduced fraud risk and unified global transactions that transcend national boundaries. They also reduce transaction costs and settlement times, enabling cross‑border payments without intermediaries.

Addressing macroeconomic imbalances

The white‑paper highlights that stablecoins can help resolve the inflation‑productivity imbalance by using more robust backing mechanisms. Because stablecoins can be backed by diversified assets (including commodities and digital collateral), they may provide a counterweight to fiat supply expansion. By facilitating deregulation and efficiency gains, stablecoins pave the way for a more interconnected international financial system.

Emerging reserve asset

Countries are beginning to view stablecoins and other crypto assets as potential reserve assets alongside gold. The white‑paper notes that nations like the UAE and Saudi Arabia preserve substantial physical gold reserves while exploring crypto reserves as additional backing. The UAE, for instance, facilitated over $300 billion in regional crypto transactions and boosted its gold reserves by 19.3 % in Q1 2025, adopting a dual strategy of traditional safe‑haven assets and digital alternatives. This dual approach reflects a hedging strategy against monetary instability.

Bitcoin and “Digital Gold”

Bitcoin, the first cryptocurrency, is often compared to gold because of its finite supply and independence from central banks. A research paper on safe‑haven assets observes that while physical gold and stable fiat currencies have traditionally been preferred safe‑havens, Bitcoin’s decentralisation and limited supply have attracted investors seeking to hedge against currency devaluation, inflation and stock‑market fluctuations. Some scholars consider Bitcoin a digital counterpart to gold. However, the same study highlights Bitcoin’s extreme volatility; its price fluctuates more than eight times the volatility of conventional stock markets. During the COVID‑19 period Bitcoin’s price ranged from $5,000 to $60,000 and then back to $20,000, underscoring its risk. As a result, investors often look to stablecoins or fiat currencies to hedge Bitcoin volatility.

The Cato Institute adds perspective by explaining why governments hold reserves of foreign currencies and gold. As of mid‑2024, global monetary authorities held $12.3 trillion in foreign exchange assets and 29,030 metric tons of gold (~$2.2 trillion). Gold makes up roughly 15 % of global reserves because it hedges currency and political risk. Bitcoin proponents argue that a strategic Bitcoin reserve could play a similar role. However, Cato notes that building a Bitcoin reserve would not strengthen the U.S. dollar or address the reasons for diversification, implying that Bitcoin’s role as a reserve asset is still speculative.

De‑dollarization and Reserves Diversification

The macro environment is increasingly characterised by de‑dollarization—a gradual shift away from exclusive reliance on the U.S. dollar in global trade and reserves. A July 2025 report from Coinfomania highlights BlackRock’s observation that central banks are moving away from the dollar amid rising inflation, high U.S. debt and political risks. These institutions are increasing holdings of gold and exploring Bitcoin as a complementary reserve asset. The article states that Bitcoin is gaining serious attention not just from retail investors but from big institutions and even central banks, illustrating how digital assets are entering reserve‑asset discussions. The report interprets this shift as “a new era where crypto could join global reserve assets”.

While the U.S. dollar remains dominant—comprising about 58 % of global foreign exchange reserves—its share has been declining, partly because countries worry about exposure to U.S. sanctions and desire more diversified reserves. Some nations see Bitcoin and stablecoins as means of reducing their dependency on U.S. banks and payment networks, especially for cross‑border transactions. The Banking 2.0 paper notes that countries like Switzerland, Singapore, the UAE and Saudi Arabia are increasing their gold holdings while exploring crypto reserves, reflecting a hedging strategy that echoes the gold accumulation of the early 1970s.

How Crypto Resembles the Gold‑Standard Shift

The transition from a gold‑backed monetary regime to a fiat system and the current emergence of crypto share several macroeconomic parallels:

  1. Loss of tangible backing → new monetary experiment: In 1971 the dollar lost its commodity backing, making money wholly dependent on government credibility. The Harvard thesis emphasises that since 1971 the dollar has been a floating currency printed at will. Today’s fiat system is again being questioned because unlimited money creation and rising debts undermine trust. Cryptocurrencies propose a new system where monetary units are backed by algorithmic scarcity (Bitcoin) or diversified reserves (stablecoins) rather than government promises.
  2. Inflation and macro instability: Both shifts arise amid inflationary pressures. The early 1970s witnessed stagflation due to oil shocks and war spending. The 2020s have seen high inflation following the pandemic, supply chain disruptions and expansive fiscal policy. Stablecoins and digital assets are being promoted as hedges against such macro instability.
  3. Rewriting reserve management: Ending the gold standard forced central banks to manage reserves through currency baskets and gold holdings. The current shift is prompting a re‑evaluation of reserve composition, with gold purchases hitting multi‑decade highs and discussions about including Bitcoin or stablecoins in reserve portfolios.
  4. Redefining payment infrastructure: Bretton Woods established a dollar‑centric payment system. Today, stablecoins threaten to bypass card networks and correspondent banking. With transfer volumes exceeding $27.6 trillion, stablecoins process more value than Visa and Mastercard. Predictions suggest that by 2032 stablecoins will make 2 % transaction fees obsolete, forcing card networks to reinvent themselves. This is analogous to the rapid adoption of electronic payments after 1971, but on a larger scale.
  5. Institutional adoption: Just as banks and governments gradually accepted fiat currency, major financial institutions are integrating crypto. JPMorgan’s deposit token (JPMD), PayPal’s “Pay with Crypto” service and state approval of Bitcoin ETFs exemplify the mainstreaming of digital assets.

Implications for Wall Street

Wall Street is at the centre of this macro shift. The integration of crypto into financial markets and corporate balance sheets could alter investment flows, trading infrastructure and risk management.

  1. New asset class and investment flows: Digital assets have grown from speculative instruments into a recognized asset class. Spot Bitcoin and Ether ETFs approved in 2024 enable institutional investors to gain exposure through regulated products. Crypto now competes with equities, commodities and bonds for capital, affecting portfolio construction and risk diversification strategies.
  2. Tokenization of real‑world assets (RWAs): Blockchain technology enables the issuance and fractional ownership of securities, commodities and real estate on chain. Tokenization reduces settlement times and counterparty risk, potentially displacing traditional clearinghouses and custodians. The Futurist Speaker article predicts that stablecoin‑backed mortgages will make home‑buying instant and bank‑free by 2031, demonstrating how tokenized assets could transform lending and capital markets.
  3. Disintermediation of payment networks: Stablecoins offer near‑zero fees and instant settlement, threatening the revenue models of Visa, Mastercard and correspondent banks. By 2032 these networks may have to evolve into blockchain infrastructure providers or risk obsolescence.
  4. Corporate treasury and supply chain transformation: Companies are exploring stablecoins to manage treasury operations, automate vendor payments and optimise cash across subsidiaries. Branded stablecoins (e.g., Amazon or Walmart coins) will create closed‑loop ecosystems that bypass banks.
  5. De‑dollarization pressures: As central banks diversify reserves and some countries embrace crypto transactions, demand for U.S. Treasuries could decline. A senior Treasury official warned that stablecoin growth would significantly impact U.S. debt demand. For Wall Street, which depends on the Treasury market for liquidity and collateral, shifts in reserve preferences could affect interest rates and funding dynamics.
  6. Regulatory and compliance challenges: Crypto’s rapid growth raises concerns about consumer protection, financial stability and money laundering. Frameworks like the GENIUS Act provide oversight, but global coordination remains fragmented. Wall Street firms must navigate a complex regulatory landscape while integrating digital asset services.

Challenges and Differences from 1971

While crypto represents a profound shift, it differs from the gold‑standard transition in several ways:

  1. Decentralization vs. centralization: The move away from gold empowered central banks and governments to control money supply. In contrast, cryptocurrencies are designed to be decentralised and resistant to central control. Stablecoins, however, introduce a hybrid model—often issued by private entities but regulated by central banks.
  2. Volatility and adoption: Bitcoin’s volatility remains a major barrier to its use as a stable store of value. Studies show that Bitcoin’s price volatility is eight times higher than that of conventional stock markets. Therefore, while Bitcoin is called digital gold, it has not yet achieved gold’s stability. Stablecoins attempt to solve this problem, but they depend on the quality of their reserves and regulatory oversight.
  3. Technological complexity: The gold‑standard exit was primarily a macroeconomic decision. Today’s shift involves complex technology (blockchains, smart contracts), new cyber risks and interoperability challenges.
  4. Regulatory fragmentation: Whereas Bretton Woods was a coordinated international agreement, the crypto transition is happening in a patchwork of national regulations. Some countries embrace crypto innovation; others impose strict bans or explore central‑bank digital currencies, leading to regulatory arbitrage.

Conclusion

Crypto and stablecoins are catalysing the most significant macro shift on Wall Street since the United States abandoned the gold standard. Like the 1971 transition, this shift stems from erosion of confidence in existing monetary arrangements and emerges during periods of inflation and geopolitical tension. Stablecoins—digital tokens designed to maintain stable value—are central to this transformation. Researchers call them the most significant banking innovation since the end of the gold standard because they integrate digital assets with traditional finance, unify global transactions and address vulnerabilities of fiat money. Their adoption is exploding: by 2024 stablecoins processed $27.6 trillion in transactions, and a regulatory framework now grants them legitimacy.

De‑dollarization pressures are pushing central banks to diversify reserves into gold and even consider Bitcoin. Countries such as the UAE and Saudi Arabia hedge with both gold and crypto reserves. These trends suggest that digital assets may join gold and foreign currencies as reserve instruments. For Wall Street, the implications are profound: new asset classes, tokenized securities, disintermediation of payment networks, corporate stablecoins and potential changes in demand for U.S. debt.

The transition is far from complete. Cryptocurrencies face high volatility, regulatory uncertainty and technological challenges. Yet the trajectory points to an era where money is programmable, borderless and backed by diversified reserves rather than government fiat alone. As with the 1971 shift, those who adapt early stand to benefit, while those who ignore the changing monetary landscape risk being left behind.

OKX Pay: Smart Accounts, Stablecoin Rails, and What to Watch

· 7 min read
Dora Noda
Software Engineer

OKX is quietly pushing deeper into consumer payments with OKX Pay, a smart-account-powered mode that lives inside the main OKX app. Below is a concise, researcher-style briefing on what the product is, how it works, the rails it rides on, the compliance context, and the key questions to keep on your diligence checklist.

TL;DR

  • What it is: A self-custody-style payment mode for verified users that lets them send or receive USDC and USDT with zero user fees on X Layer, the OKX-operated Polygon CDK Layer 2. It relies on a smart-contract "Smart Account" secured with passkeys while OKX co-signs on-chain actions to complete transfers.
  • Scope today: OKX is positioning Pay for consumer P2P and social payments via contacts, gift flows, and shareable payment links. Merchant acceptance is explicitly off-limits unless OKX grants permission, so any merchant reach is expected to land through the upcoming OKX Card and Mastercard’s stablecoin capabilities.
  • Rails & assets: Pay defaults to X Layer (OKB gas), and users can bridge funds with Convert to Pay from Ethereum, TRON, Arbitrum, Base, Avalanche, or Optimism into USDC/USDT on X Layer.
  • Costs & rewards: P2P transfers on X Layer are marketed as fee-free; converting from external chains still consumes that chain’s native gas. Stablecoin balances can earn daily-accruing, monthly-paid rewards, although rates vary and OKX can pause or change them.
  • Availability & risk: Access requires an OKX account plus KYC, and Pay is not available in every jurisdiction. OKX’s February 2025 U.S. AML guilty plea leaves it under an independent monitor through 2027, a meaningful compliance consideration for American strategies.

Product Snapshot

User flow

  • Switch the mobile app to Pay mode, then send value by name, phone, email, QR code, or payment link. Payments that go unclaimed automatically return after 48 hours.
  • Convert to Pay pulls assets from multiple EVM and TRON networks into X Layer stablecoins. Conversions that stay inside X Layer have their gas covered by OKX.

Security and custody model

  • Pay relies on a Smart Account, which is a smart-contract wallet where every transaction needs signatures from the user and OKX. Assets are marketed as “not directly managed or hosted by OKX,” but the co-signature requirement makes Pay effectively semi-custodial.
  • Users authenticate with passkeys stored in iCloud or Google Password Manager. ZK-Email supports passkey resets (except on TRON), and each chain can store up to three passkeys.

Assets and networks

  • Pay currently supports USDC and USDT, with OKX hinting that more stablecoins are on the roadmap.
  • On-chain sends and receives work across X Layer, Ethereum, TRON, “and many other networks,” but the Pay experience is optimized for X Layer.

Fees, limits, and rewards

  • OKX advertises no additional fees for P2P stablecoin transfers on X Layer. Moving funds from other networks still requires paying that network’s gas.
  • Internal transfers and deposits are free, while on-chain withdrawals incur normal network gas.
  • Stablecoin balances inside Pay can enter Smart Savings, where rewards accrue daily and pay monthly; OKX can change, pause, or terminate the program at will, and identity verification is required to participate.

Messaging and social layer

  • Pay bakes in chat and gift-giving flows to emphasize social tipping and casual P2P use cases.

Rails & Ecosystem: X Layer

  • X Layer is OKX’s Ethereum Layer 2 built on Polygon CDK. An August 2025 upgrade pushed throughput toward ~5,000 TPS and moved the gas token to OKB, while subsidizing near-zero gas fees for Pay.
  • X Layer ties directly into OKX Wallet and the centralized exchange, enabling features like “0-gas fast withdrawal” rails that reuse Pay’s infrastructure.

Merchant Reach (Now vs. Next)

  • Today: OKX Pay’s terms explicitly prohibit business-to-business or merchant transactions unless OKX authorizes them, cementing Pay as a consumer P2P feature for now.
  • Near-term: Merchant reach is expected to flow through the OKX Card in partnership with Mastercard, which is rolling out end-to-end stablecoin acceptance capabilities so wallets can spend at traditional merchants.

Availability, KYC, and Compliance

  • Activating Pay demands an OKX account and completed KYC, and recipients must also verify their identity to receive funds.
  • OKX cautions that Pay is not offered in every jurisdiction and maintains a list of restricted regions.
  • Compliance observers should note OKX’s February 2025 guilty plea in the United States over AML violations. The settlement included roughly $505 million in penalties and an independent monitor through February 2027. Conversely, OKX has achieved in-principle approval from Singapore’s MAS for a payments licence and now supports instant SGD transfers via DBS rails.

Competitive Snapshot (Payments)

FeatureOKX PayBinance PayBybit PayCoinbase Payments / Commerce
Core useP2P stablecoin pay on X Layer; social gifting; fee-free UXP2P plus merchant ecosystem; zero gas for users; 80+ assetsP2P with web/app/POS integrationsUSDC checkout infrastructure (Base) for platforms; Coinbase Commerce for merchants
Merchant useRestricted unless OKX authorizes; merchant reach via OKX Card & Mastercard stackBroad merchant program & partnersPositioning toward merchant integrationsPlatform-level stablecoin rails; Commerce charges 1% today
FeesNo user fee on X Layer P2P; conversion gas for external chains“Zero gas fees” positioning for usersMarketing around low feesCommerce currently 1% to merchants
AssetsUSDT, USDC (more stablecoins “later”)80+ assets including BTC/ETH/USDT/USDCMulti-assetPrimarily USDC (with PYUSD promos)
RailsX Layer (OKB gas)Binance internal + supported networksBybit internal + networksBase + Coinbase stack

Strengths

  • Frictionless UX: passkeys, phone/email/links, and 48-hour auto-returns keep the Pay experience friendly for consumers.
  • Gas-abstracted P2P: zero-fee transfers on X Layer plus covered intra-X Layer conversions reduce user friction.
  • Exchange adjacency: tight links to the OKX exchange, X Layer, and the forthcoming OKX Card create an on/off-ramp bundle.

Frictions and Risks

  • Semi-custodial design: every Smart Account action depends on an OKX co-signature, so users inherit OKX’s availability and policy decisions.
  • Merchant gap today: Pay’s consumer-first positioning limits merchant adoption until card and Mastercard flows mature.
  • Regulatory overhang: the U.S. enforcement outcome and jurisdictional restrictions constrain global rollout.

What to Watch (3–9 Months)

  • OKX Card rollout: geography, fees, FX, rewards, BIN controls, and whether card spend can directly draw from Pay balances.
  • Stablecoin coverage: expansion beyond USDT/USDC and how APY tiers evolve by region.
  • Merchant pilots: concrete examples of Mastercard stablecoin settlement or OKX-authorized merchant flows inside Pay.
  • X Layer economics: the impact of OKB-as-gas, throughput upgrades, and gas subsidies on Pay growth and on-chain activity.

Diligence Checklist

  • Regulatory scope: confirm jurisdictional eligibility and service availability before planning deployments.
  • KYC and data flows: document the identity verification steps and what transaction metadata is shared between counterparties.
  • Custody model: map failure modes if OKX cannot co-sign or if passkey resets are required; test ZK-Email recovery.
  • Cost validation: measure actual user fees on X Layer versus gas consumed when bridging from other chains.
  • Rewards: track APY, accrual, and payout mechanics while noting OKX’s right to adjust or suspend the program.

Sources: OKX Pay FAQ and documentation, OKX Smart Account terms, X Layer upgrade announcements, Mastercard OKX Card partnership materials, Mastercard stablecoin settlement releases, OKX risk and compliance disclosures, Reuters coverage of the February 2025 U.S. enforcement action.

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.

U.S. Crypto Policy as Global Catalyst

· 31 min read
Dora Noda
Software Engineer

Bo Hines and Cody Carbone are architecting America's transformation from crypto skeptic to global leader through stablecoin legislation, regulatory clarity, and strategic positioning that extends dollar dominance worldwide. Their complementary visions—Hines executing from the private sector after shaping White House policy, Carbone orchestrating congressional advocacy through The Digital Chamber—reveal how deliberate U.S. policy frameworks will become the template for international crypto adoption. The July 2025 passage of the GENIUS Act, which both champions helped architect, represents not just domestic regulation but a strategic play to ensure dollar-backed stablecoins become global payment infrastructure, reaching billions who currently lack access to digital dollars.

This policy revolution matters because it resolves a decade-long regulatory stalemate. From 2021-2024, unclear U.S. rules drove innovation offshore to Singapore, Dubai, and Europe. Now, with comprehensive frameworks in place, the U.S. is reclaiming leadership at precisely the moment when institutional capital is ready to deploy—71% of institutional investors plan crypto allocations, up from negligible percentages just years ago. The backstory involves Trump's January 2025 executive order establishing crypto as a national priority, the creation of David Sacks' White House Crypto Council where Hines served as executive director, and The Digital Chamber's bipartisan congressional strategy that delivered 68-30 Senate passage of stablecoin legislation.

The broader implication: this isn't just American policy reform but a geopolitical strategy. By establishing clear rules that enable private dollar-backed stablecoins while explicitly banning government-issued CBDCs, the U.S. is positioning digital dollars as the alternative to China's digital yuan and Europe's planned digital euro. Hines and Carbone both predict other nations will adopt U.S. regulatory frameworks as the global standard, accelerating worldwide crypto adoption while maintaining American financial hegemony.

Two architects of crypto's American moment

Bo Hines, at just 30, embodies the political-to-private sector pipeline that now defines crypto leadership. After failing twice in congressional races despite Trump endorsements, he leveraged his law degree and early crypto exposure (first learning about Bitcoin at the 2014 BitPay-sponsored bowl game) into a pivotal White House role. As executive director of the Presidential Council of Advisers on Digital Assets from January to August 2025, he coordinated weekly meetings with SEC, CFTC, Treasury, Commerce, and bank regulators—approximately 200 stakeholder meetings in seven months. His fingerprints are all over the GENIUS Act, which he calls "the first piece of the puzzle" in revolutionizing America's economic state.

Within days of resigning in August 2025, Hines received "well over 50 job offers" before joining Tether as strategic advisor and then CEO of Tether USA in September 2025. This positioned him to launch USAT, the first federally-compliant U.S. stablecoin designed to meet GENIUS Act standards. His political capital—direct Trump connections, regulatory expertise, and policy-crafting experience—makes him uniquely valuable as Tether navigates the new regulatory environment while competing against Circle's established USDC dominance in U.S. markets.

Cody Carbone represents a different archetype: the patient institution-builder who spent years preparing for this moment. With a JD and MPA from Syracuse, plus six years at EY's Office of Public Policy before joining The Digital Chamber, he brings legislative and financial services expertise to crypto advocacy. His April 2025 promotion from Chief Policy Officer to CEO marked a strategic shift from defensive posture to proactive policy development. Under his leadership, The Digital Chamber—the nation's first and largest blockchain trade association with 200+ members spanning miners, exchanges, banks, and Fortune 500 companies—released the comprehensive U.S. Blockchain Roadmap in March 2025.

Carbone's approach emphasizes bipartisan consensus-building over confrontation. He downplayed Democratic opposition to stablecoin legislation, highlighting support from Senators Gillibrand and others, and maintained direct engagement with both parties throughout the process. This pragmatism proved essential: the GENIUS Act passed with 68-30 Senate support, far exceeding the simple majority needed. His stated goal is ensuring "the U.S. leads in blockchain innovation" through "clear, common-sense rules" that don't stifle development.

The stablecoin foundation for dollar dominance

Both executives identify stablecoin legislation as the critical foundation for global crypto adoption, but they articulate complementary rationales. Hines frames it through national economic strategy: "Stablecoins could usher in U.S. dollar dominance for decades to come." His White House experience taught him that archaic payment rails—many unchanged for three decades—needed blockchain-based alternatives to maintain American competitiveness. The GENIUS Act's requirement for 1:1 backing with U.S. dollars, insured bank deposits, or Treasury bills means every stablecoin creates demand for dollar-denominated assets.

Carbone emphasizes the geopolitical dimension. In his view, if Congress wants to "compete with state-controlled digital currencies abroad, the only path is to pass the GENIUS Act and let private stablecoins thrive in the U.S." This positions dollar-backed stablecoins as America's answer to CBDCs without the government surveillance concerns. The Digital Chamber's advocacy highlighted how 98% of existing stablecoins are USD-pegged and over 80% of stablecoin transactions occur outside the U.S.—demonstrating massive untapped global demand for digital dollars.

The legislation's structure reflects careful balance between innovation and oversight. Federal oversight applies to issuers over $10 billion (targeting major players like Circle's USDC at $72 billion), while smaller issuers under $10 billion can choose state regulation if "substantially similar." Monthly public disclosures of reserve composition with executive certification ensure transparency without creating the rigid, bank-like constraints some feared. Both executives note this creates a "first-mover advantage" for U.S. regulatory frameworks that other jurisdictions will emulate.

Treasury Secretary Bessent projected the stablecoin market will exceed $1 trillion "in the next few years" from current $230+ billion levels. Hines believes this conservative: "As tokenization continues to occur, it can be much greater than that." His USAT launch targets becoming the "first federally licensed stablecoin product in the U.S." with Anchorage Digital as issuer and Cantor Fitzgerald as custodian—partnerships that leverage both regulatory compliance and political capital (Cantor's CEO Howard Lutnick serves as Trump's Commerce Secretary).

Carbone sees the institutional adoption pathway clearly. The Digital Chamber's surveys show 84% of institutions are using or considering stablecoins for yield generation (73%), foreign exchange (69%), and cash management (68%). The GENIUS Act removes the regulatory uncertainty that previously blocked deployment of this capital. "For the first time, we have a government that recognizes the strategic importance of digital assets," he stated when promoted to CEO.

Regulatory clarity as the unlock for institutional capital

Both executives emphasize that regulatory uncertainty—not technology limitations—was crypto's primary barrier to mainstream adoption. Hines describes the Biden era as requiring "demolition" of hostile regulations before "construction" of new frameworks could begin. His three-phase White House strategy started with reversing "Operation Chokepoint 2.0" enforcement patterns, dropping SEC lawsuits against Coinbase and Ripple, and hosting the first White House Crypto Summit in March 2025. The construction phase centered on the GENIUS Act and market structure legislation, with implementation focusing on integrating blockchain into financial infrastructure.

The specific regulatory changes both champions highlight reveal what institutional players needed. The January 2025 rescission of SAB 121—which required banks to hold custodied digital assets on their balance sheets—was critical. Carbone called it "low hanging fruit that signaled an immediate shift from the Biden/Gensler era and greenlit financial institutions to enter the market." This enabled BNY Mellon, State Street, and other traditional custodians to offer crypto services without prohibitive capital requirements. The result: 43% of financial institutions now collaborate with crypto custodians, up from 25% in 2021.

Carbone's policy advocacy through The Digital Chamber focused on creating "clear jurisdictional lines between the SEC and CFTC so issuers can plan for clarity who their regulator is." The FIT21 market structure bill, which passed the House 279-136 in May 2024, establishes three asset categories: Restricted Digital Assets under SEC jurisdiction, Digital Commodities under CFTC oversight, and Permitted Payment Stablecoins. A five-step decentralization test determines commodity classification. Senate passage is expected in 2025 following GENIUS Act momentum.

Hines coordinated the interagency process that made this jurisdictional clarity possible. His weekly working group meetings brought together SEC, CFTC, Treasury, Commerce, and bank regulators to ensure "everyone is singing from the same sheet of music." This unprecedented coordination—culminating in the first joint SEC-CFTC roundtable in 14 years (October 2025) and joint staff statements on spot crypto trading—ended the regulatory turf wars that previously paralyzed the industry.

The institutional response validates their thesis. A 2025 EY survey found 71% of institutional investors are invested or planning investment in digital assets, with 59% planning to allocate more than 5% of AUM—an 83% increase. Primary driver cited: regulatory clarity at 57%. Spot Bitcoin ETFs approved in January 2024 accumulated ~$60 billion in AUM by early 2025, demonstrating pent-up institutional demand. Major players like BlackRock, Fidelity, and ARK now offer crypto products, while JPMorgan CEO Jamie Dimon—previously crypto-skeptical—now permits Bitcoin purchases and considers crypto-backed loans.

Strategic Bitcoin Reserve and digital gold narrative

Both executives strongly support the Strategic Bitcoin Reserve established by Trump's March 6, 2025 executive order, though they emphasize different strategic rationales. Hines articulates the "digital gold" framing: "We view bitcoin as digital gold. We want as much of it as we can possibly have for the American people." When pressed on target amounts, he offered: "That's like asking a country how much gold do you want, right? As much as we can get."

His budget-neutral approach addresses fiscal concerns. Creative mechanisms under White House consideration included revaluing U.S. gold holdings from the statutory $42.22 per ounce to current market levels around $3,400, generating paper profits usable for Bitcoin purchases. Other options: monetizing government-held energy assets, conducting mining operations on federal land, and utilizing the approximately 198,012 BTC already seized from criminal cases. "It's not going to cost the taxpayer a dime," Hines emphasized repeatedly, knowing congressional appetite for new expenditures is limited.

Carbone frames the reserve through competitive lens. He notes premature sales have cost U.S. taxpayers over $17 billion as Bitcoin appreciated after government auctions. No clear policy previously existed for managing seized crypto assets across federal agencies. The reserve establishes a "no-sell" protocol that prevents future opportunity losses while positioning the U.S. among the first sovereign nations to treat Bitcoin as strategic reserve asset—similar to gold, foreign currencies, or special drawing rights.

The global implications extend beyond direct holdings. As Carbone explains, establishing a Strategic Bitcoin Reserve sends powerful signal to other nations that Bitcoin deserves consideration as reserve asset. The Digital Chamber's U.S. Blockchain Roadmap advocates for enactment of the BITCOIN Act to codify this reserve legislatively, ensuring future administrations cannot easily reverse the policy. This permanence would accelerate international central bank accumulation, potentially driving Bitcoin into traditional reserve asset frameworks alongside the dollar itself.

Neither executive sees contradiction between promoting dollar-backed stablecoins and accumulating Bitcoin. Hines explains they serve different functions: stablecoins as payment rails extending dollar utility, Bitcoin as store-of-value reserve asset. The complementary strategy strengthens U.S. financial hegemony through both medium of exchange dominance (stablecoins) and reserve asset diversification (Bitcoin)—covering multiple dimensions of monetary leadership.

Cross-border payments transformation

Hines envisions stablecoins revolutionizing cross-border payments by eliminating intermediaries and reducing costs. His focus on "updating the payment rails that existed, many of which were archaic" reflects frustration with systems fundamentally unchanged since the 1970s. Traditional correspondent banking networks involve multiple intermediaries, 2-5 day settlement times, and fees reaching 5-7% for remittances. Stablecoins enable 24/7/365 near-instantaneous settlement at fractional costs.

The existing market demonstrates this potential. Tether's USDT processes over $1 trillion monthly volume—exceeding major credit card companies—and serves nearly 500 million users globally. USDT is particularly popular in emerging markets with high banking fees and currency instability, serving "hundreds of millions of underserved people living in emerging markets" who use it for savings, payments, and business operations. This real-world adoption in Latin America, Sub-Saharan Africa, and Southeast Asia proves demand for dollar-denominated digital payment tools.

Carbone emphasizes how GENIUS Act compliance transforms this from gray-market activity into legitimate financial infrastructure. Requiring AML/CFT compliance, reserve transparency, and regulatory oversight addresses the "wild west" concerns that previously prevented institutional and government embrace. Banks can now integrate stablecoins into treasury operations knowing they meet regulatory standards. Corporations can use them for international payroll, vendor payments, and supply chain finance without compliance risk.

The geopolitical dimension is explicit in both executives' thinking. Every stablecoin transaction, regardless of where it occurs globally, reinforces dollar utility and demand for Treasury bills held as reserves. This extends American monetary influence to populations and regions historically beyond the dollar's reach. As Carbone puts it, if Congress wants to "compete with state-controlled digital currencies abroad," enabling private dollar stablecoins is essential. The alternative—China's digital yuan facilitating yuan-denominated trade outside dollar rails—poses direct threat to American financial hegemony.

Market data supports the cross-border narrative. Sub-Saharan Africa and Latin America show high year-over-year growth in retail stablecoin transfers, while North America and Western Europe dominate institutional-sized transfers. Lower-income countries use stablecoins for actual payments (remittances, business transactions), while developed markets use them for financial operations (trading, treasury management, yield generation). This bifurcated adoption pattern suggests stablecoins serve multiple global needs simultaneously.

How U.S. policy becomes the global template

Both executives explicitly predict international regulatory convergence around U.S. frameworks. At Token 2049 Singapore in September 2025, Hines stated: "You'll start to see other regulatory frameworks around the world start to match what we did." He emphasized "the US is the powerhouse in the stablecoin space" and urged other countries including South Korea to "follow what the US has laid out." His confidence stems from first-mover advantage in comprehensive regulation—the GENIUS Act is the first major economy's complete stablecoin framework.

The mechanism for this global influence operates through multiple channels. Article 18 of the GENIUS Act includes a reciprocity clause allowing foreign stablecoin issuers to operate in U.S. markets if their home jurisdictions maintain "substantially similar" regulatory frameworks. This creates strong incentive for other countries to align their regulations with U.S. standards to enable their stablecoin issuers to access massive American markets. The Eurozone's MiCA regulation, while more prescriptive and bank-like, represents similar thinking—comprehensive frameworks that provide legal certainty.

Carbone sees U.S. regulatory clarity attracting global capital flows. The U.S. already represents 26% of global cryptocurrency transaction activity with $2.3 trillion in value from July 2024-June 2025. North America leads in high-value activity with 45% of transactions over $10 million—the institutional segment most sensitive to regulatory environment. By providing clear rules while other jurisdictions remain uncertain or overly restrictive, the U.S. captures capital that might otherwise deploy elsewhere.

The competitive dynamics between jurisdictions validate this thesis. From 2021-2024, unclear U.S. regulations drove companies to Singapore, UAE, and Europe for regulatory certainty. Exchanges, custody providers, and blockchain companies established offshore operations. The 2025 policy shift is reversing this trend. Ripple's CEO Brad Garlinghouse noted "more U.S. deals in 6 weeks post-election than previous 6 months." Binance, Coinbase, and Kraken are expanding U.S. operations. The talent and capital that left is returning.

Hines articulates the long-term vision at Token 2049: establishing U.S. leadership in crypto means "ensuring that the dollar not only remains dominant in the digital age, but thrives." With 98% of stablecoins USD-pegged and over 80% of transactions occurring abroad, clear U.S. regulation proliferates digital dollars globally. Countries wanting to participate in this financial infrastructure—whether for remittances, trade, or financial services—must engage with dollar-based systems. The network effects become self-reinforcing as more users, businesses, and institutions adopt dollar stablecoins as standard.

Institutional adoption pathways now open

The regulatory clarity both executives championed removes specific barriers that prevented institutional deployment. Hines identifies the target audience for USAT explicitly: "businesses and institutions operating under U.S. regulatory framework." These entities—pension funds, endowments, corporate treasuries, asset managers—previously faced compliance uncertainty. Legal departments couldn't approve crypto allocations without clear regulatory treatment. The GENIUS Act, FIT21 market structure frameworks, and SAB 122 custody rules resolve this.

Carbone's Digital Chamber surveys quantify the opportunity. 71% of institutional investors are invested or planning investment in digital assets, with 85% having already allocated or planning allocation. The use cases extend beyond speculation: 73% cite yield generation, 69% foreign exchange, 68% cash management. These operational uses require regulatory certainty. A CFO can't put corporate treasury into stablecoins for yield without knowing the legal status, custody requirements, and accounting treatment.

Specific institutional developments both executives highlight demonstrate momentum. Spot Bitcoin ETFs accumulating ~$60 billion in AUM by early 2025 prove institutional demand exists. Traditional custodians like BNY Mellon ($2.1 billion digital AUM) and State Street entering crypto custody validates the infrastructure. JPMorgan conducting blockchain-based repo transactions and tokenized Treasury settlement on public ledgers shows major banks experimenting with integration. Visa and Mastercard supporting 75+ banks via blockchain networks and moving USDC onto Solana indicate payment giants embrace the technology.

The tokenized real-world assets (RWAs) segment particularly excites both executives as institutional bridge. U.S. Treasury tokenization grew from ~$2 billion to over $8 billion AUM between August 2024 and August 2025. These products—tokenized Treasury bills and bonds—combine blockchain infrastructure with familiar sovereign debt instruments. They offer 24/7 trading, instant settlement, transparent pricing, and programmability while maintaining the safety profile institutions require. This provides onramp for traditional finance to adopt blockchain infrastructure for core operations.

Hines predicts rapid acceleration: "You're going to see tokenized public securities start to happen very quickly... you're going to see market efficiency, you're going to see commodity exchange efficiency. Everything moves onchain." His timeline envisions 24/7 markets with instant settlement becoming standard within years, not decades. The CFTC's September 2025 initiative seeking input on tokenized collateral and stablecoins as derivatives margin demonstrates regulators are preparing for this future rather than blocking it.

Political economy of crypto's Washington victory

The crypto industry's 2024 political strategy, which both executives benefited from, reveals how targeted advocacy secured policy wins. The sector spent over $100 million on congressional races through Super PACs like Fairshake, which supported pro-crypto candidates in both parties. This bipartisan approach, championed by Carbone's Digital Chamber, proved essential. The GENIUS Act passed with 68-30 Senate support including Democrats like Gillibrand and Alsobrooks. FIT21 secured 71 Democratic House votes alongside Republican support.

Carbone emphasizes this bipartisan consensus as critical for durability. Single-party legislation gets repealed when power shifts. Broad support across the political spectrum—reflecting crypto's appeal to both tech-friendly progressives and market-oriented conservatives—provides staying power. His strategy of "building bipartisan coalitions" through education rather than confrontation avoided the polarization that killed previous legislative efforts. Meeting with policy organizations that interact with Democratic members ensured the message reached both sides.

Hines' White House tenure institutionalized crypto within executive branch. The Presidential Council of Advisers on Digital Assets, chaired by David Sacks, gave industry direct line to administration. The July 2025 Working Group report—"the most comprehensive report that's ever been produced, in terms of regulatory framework"—involving SEC, CFTC, Treasury, Commerce, and bank regulators, established coordinated federal approach. This interagency alignment means regulatory agencies "have some autonomy to act independently without constantly needing an executive order."

The personnel dimension matters enormously. Trump appointed crypto advocates to key positions: Paul Atkins (former Digital Chamber board advisor) as SEC Chair, Caroline D. Pham as CFTC Acting Chair, Brian Quintenz as CFTC Chair nominee. Hines notes these individuals "understand the technology" and are "very business-friendly." Their regulatory philosophy emphasizes clear rules enabling innovation rather than enforcement actions blocking development. The contrast with Gary Gensler's SEC—125 enforcement actions totaling $6.05 billion in penalties—couldn't be starker.

Both executives acknowledge expectations are now "sky-high." Carbone describes the atmosphere as "chaotic energy with all-time high vibes and optimism" but cautions "we haven't gotten much done yet" beyond executive actions and the GENIUS Act. Market structure legislation, DeFi frameworks, taxation clarity, and banking integration all remain works in progress. The industry built a "heftier war chest" for future political engagement, recognizing that maintaining favorable policy requires sustained effort beyond single election cycle.

DeFi and decentralization challenges

Decentralized finance presents regulatory challenges both executives address carefully. Hines strongly supports DeFi innovation, stating the administration intends to ensure DeFi projects "stay in the U.S." and that "DeFi has a secure place." However, he balances this with acknowledgment that some compliance is necessary. The Treasury's decision to drop Tornado Cash sanctions and forthcoming DOJ guidance on "software neutrality" suggest frameworks that protect protocol developers while targeting malicious users.

Carbone celebrated the Congressional Review Act resolution rolling back the Biden-administration IRS rule treating DeFi projects as brokerages, calling it "a good day for DeFi." This rule would have required decentralized protocols to collect user information for tax reporting—practically impossible for truly decentralized systems and potentially forcing them offshore or shuttering. Its reversal signals regulatory approach that accommodates DeFi's unique technical architecture.

The FIT21 market structure bill includes DeFi safe harbor provisions attempting to balance innovation and oversight. The challenge both executives recognize: how to prevent illicit activity without undermining the censorship-resistant, permissionless properties that make DeFi valuable. Their approach appears to be enforcing against bad actors while protecting neutral protocols—similar to not holding broadband providers liable for user actions while prosecuting criminals who use internet infrastructure.

This represents sophisticated evolution from blanket skepticism to nuanced understanding. Early regulatory responses treated all DeFi as high-risk or potentially illegal. Both Hines and Carbone recognize legitimate use cases: automated market makers providing efficient trading, lending protocols offering permissionless credit, decentralized exchanges enabling peer-to-peer transactions. The question becomes implementing AML/CFT requirements without centralization mandates that destroy DeFi's core value proposition.

Banking system modernization through blockchain

Both executives view blockchain integration into banking as inevitable and beneficial. Hines emphasizes "we're talking about revolutionizing a financial marketplace which has basically been archaic for the last three decades." The correspondent banking system, ACH transfers taking days, and settlement delays costing trillions in locked capital all represent inefficiencies blockchain eliminates. His vision extends beyond crypto-native companies to transforming traditional banking infrastructure through distributed ledger technology.

The Digital Chamber's U.S. Blockchain Roadmap advocates for "modernizing the U.S. banking system" as one of six core pillars. Carbone notes "many companies are hesitant to adopt blockchain technology due to the confusion between blockchain and crypto in policymaking circles." His educational mission distinguishes between cryptocurrency speculation and blockchain infrastructure applications. Banks can use blockchain for settlement, record-keeping, and automated compliance without exposing customers to volatile crypto assets.

Concrete developments demonstrate this integration beginning. JPMorgan's blockchain-based repo transactions settle same-day rather than next-day, reducing counterparty risk. Tokenized Treasury bills trade 24/7 rather than during exchange hours. Digital bond issuances on public ledgers provide transparent, immutable records reducing administrative costs. These applications deliver clear operational benefits—faster settlement, lower costs, better transparency—without requiring banks to fundamentally change their risk models or customer relationships.

The SAB 122 rescission removing balance sheet barriers was critical enabler both executives highlight. Requiring banks to hold custodied crypto assets as liabilities artificially inflated capital requirements, making custody economically unviable. Its reversal allows banks to offer custody services with appropriate risk management rather than prohibitive capital charges. This opened flood gates for traditional financial institutions to enter digital asset services, competing with crypto-native custodians while bringing regulatory sophistication and institutional trust.

The Federal Reserve master account process remains area needing reform, per the U.S. Blockchain Roadmap. Crypto firms and blockchain-based banks struggle to obtain direct Fed access, forcing reliance on intermediary banks that can "de-bank" them arbitrarily. Carbone and The Digital Chamber advocate for transparent, fair criteria enabling crypto firms meeting regulatory standards to access Fed services directly. This would complete the integration of blockchain-based finance into official banking infrastructure rather than treating it as peripheral.

Energy security through Bitcoin mining

Hines and Carbone both emphasize Bitcoin mining as strategic infrastructure beyond financial considerations. The U.S. Blockchain Roadmap—which Carbone oversees—declares "Bitcoin mining is a critical pillar of U.S. energy security and technological leadership." The argument: mining operations can monetize stranded energy, provide grid flexibility, and reduce reliance on foreign-controlled digital infrastructure.

Bitcoin mining's unique properties enable using energy that otherwise goes to waste. Natural gas flaring at oil wells, curtailed renewable energy when supply exceeds demand, and off-peak nuclear generation all become monetizable through mining. This provides economic incentive to develop energy resources that lack transmission infrastructure or steady demand. Mining companies increasingly partner with energy producers to capture this otherwise-wasted capacity, effectively functioning as controllable load that improves project economics.

Grid stability represents another strategic dimension. Mining operations can shut down instantly when electricity demand spikes, providing flexible load that helps balance supply and demand. Texas grid operator ERCOT has tested programs using miners as demand response resources during peak consumption. This flexibility becomes increasingly valuable as renewable energy—which is intermittent—comprises larger grid share. Miners essentially act as energy buyers of last resort, supporting renewable development by ensuring consistent demand.

The competitive and national security argument resonates particularly with policymakers. Currently, China and Central Asia host significant mining operations despite China's official ban. If adversarial nations control Bitcoin mining, they could potentially influence the network or monitor transactions. U.S.-based mining—supported by clear regulations and cheap domestic energy—ensures American participation in this strategic digital infrastructure. It also provides intelligence community means to monitor blockchain activity and enforce sanctions through collaboration with domestic mining pools.

Both executives support "clear, consistent regulations for mining operations" that enable growth while addressing environmental concerns. The Biden-era proposals for 30% excise tax on mining electricity consumption have been abandoned. Instead, the approach focuses on requiring grid connectivity, environmental reporting, and energy efficiency standards while avoiding punitive taxation that would drive mining offshore. This reflects broader philosophy: shape industry development through smart regulation rather than attempting to ban or heavily tax it.

The "everything moves onchain" thesis

Hines' long-term prediction that "everything moves onchain"—tokenized securities, commodity trading, market infrastructure—reflects both executives' belief that blockchain becomes the backbone of future finance. This vision extends far beyond cryptocurrency speculation to fundamentally reimagining how value transfers, assets are represented, and markets operate. The transition from today's hybrid systems to fully blockchain-based infrastructure will unfold over years but is in their view inevitable.

Tokenized securities offer compelling advantages both executives cite. 24/7 trading instead of exchange hours, instant settlement rather than T+2, fractional ownership enabling smaller investments, and programmable compliance embedded in smart contracts. A tokenized stock could automatically enforce transfer restrictions, distribute dividends, and maintain shareholder registries without intermediaries. This reduces costs, increases accessibility, and enables innovations like dynamic ownership structures adjusting based on real-time data.

Derivatives and commodity markets benefit similarly from blockchain infrastructure. The CFTC's September 2025 initiative exploring tokenized collateral and stablecoins as derivatives margin demonstrates regulatory readiness. Using stablecoins for futures margin eliminates settlement risk and enables instant margin calls rather than daily processes. Tokenized gold, oil, or agricultural commodities could trade continuously with instant physical delivery coordination. These efficiency gains compound across the financial system's trillions in daily transactions.

Carbone emphasizes blockchain's applications beyond finance prove the technology's broader value. Supply chain tracking provides immutable records of product provenance—critical for pharmaceuticals, luxury goods, and food safety. Government operations could use blockchain for transparent fiscal oversight, reducing fraud and improving accountability. Cybersecurity applications include decentralized identity systems reducing single points of failure. These uses demonstrate blockchain's utility extends far beyond payments and trading.

The skeptical question—why do established financial institutions need blockchain when current systems work?—both executives answer with efficiency and access arguments. Yes, current systems work, but they're expensive, slow, and exclude billions globally. Blockchain reduces intermediaries (each taking fees), operates 24/7 (vs. business hours), settles instantly (vs. days), and requires only internet access (vs. bank relationships and minimum balances). These improvements matter to both underserved populations in emerging markets and sophisticated institutions seeking operational efficiency.

The anti-CBDC consensus as strategic decision

Both executives strongly oppose central bank digital currencies while championing private stablecoins—a position now enshrined in U.S. policy through Trump's executive order banning federal CBDC development. Hines states explicitly: "The federal government will never issue a stablecoin and firmly opposes anything resembling a central bank digital currency." He frames private stablecoins as "effectively accomplish[ing] the same goal without government overreach."

The philosophical distinction matters enormously for global crypto adoption. CBDCs give governments programmable, surveillable money enabling unprecedented control. The People's Bank of China's digital yuan trials demonstrate the model: direct central bank accounts for citizens, transaction monitoring, and potential for controls like expiration dates or location-based spending restrictions. Over 130 countries are exploring CBDCs following this template. The U.S. choosing a different path—enabling private stablecoins instead—represents fundamental ideological and strategic divergence.

Carbone argues this private-sector approach better aligns with American values and economic system. "If Congress wants to ban a CBDC and compete with state-controlled digital currencies abroad, the only path is to pass the GENIUS Act and let private stablecoins thrive in the U.S." This frames dollar stablecoins as the democratic answer to authoritarian CBDCs—maintaining privacy, innovation, and competition while still enabling digital payments and extending dollar reach.

The global implications extend beyond technology choice to competing visions of digital financial systems. If the U.S. successfully demonstrates that private stablecoins can deliver the efficiency and accessibility benefits of digital currency without centralized control, other democracies may follow. If U.S. dollar stablecoins become dominant international payment rails, China's digital yuan loses strategic opportunity to displace dollar in global trade. The competition isn't just currencies but governing philosophies embedded in monetary infrastructure.

Both executives emphasize that stablecoin success depends on regulatory frameworks that enable private innovation. The GENIUS Act's requirements—full reserves, transparency, AML/CFT compliance—provide oversight without nationalization. Banks, fintech companies, and blockchain projects can compete to offer best products rather than government monopoly. This preserves innovation incentives while maintaining financial stability. The model more resembles how private banks issue deposits backed by FDIC insurance rather than government fiat.

Complementary visions from different vantage points

The synthesis of Hines' and Carbone's perspectives reveals how private-sector execution and policy advocacy reinforce each other in driving crypto adoption. Hines embodies the revolving door between government and industry—bringing policy expertise to Tether while his White House connections provide ongoing access and intelligence. Carbone represents sustained institutional advocacy—The Digital Chamber's decade-plus work building coalitions and educating lawmakers created foundation for current policy momentum.

Their different vantage points generate complementary insights. Hines speaks from operational experience launching USAT, competing in markets, and navigating actual compliance requirements. His perspectives carry practitioner authenticity—he must live with the regulations he helped create. Carbone operates at meta-level, coordinating 200+ member companies with diverse needs and maintaining relationships across political spectrum. His focus on durable bipartisan consensus and long-term frameworks reflects institutional timeframes rather than product launch pressures.

Both executives' emphasis on education over confrontation marks departure from crypto's earlier libertarian, anti-establishment ethos. Hines spent seven months in ~200 stakeholder meetings explaining blockchain benefits to skeptical regulators. Carbone emphasizes that "so many lawmakers and policymakers don't understand the use cases of blockchain technology" despite years of advocacy. Their patient, pedagogical approach—treating regulators as partners to educate rather than adversaries to defeat—proved more effective than confrontational strategies.

The age dimension adds interesting dynamic. Hines at 30 represents first generation of policymakers who encountered crypto during formative years (his 2014 Bitcoin bowl exposure) rather than viewing it as alien technology. His comfort with both digital assets and traditional policy processes—law degree, congressional campaigns, White House service—bridges two worlds that previously struggled to communicate. Carbone, with more extensive traditional finance and government experience, brings institutional credibility and relationships that opened doors for newer crypto perspectives.

Their predictions for how U.S. policy accelerates global adoption ultimately rest on network effects thesis. As Hines frames it, regulatory clarity attracts institutional capital, which builds infrastructure, which enables applications, which attract users, which increase adoption, which brings more capital—a virtuous cycle. The U.S. providing first-mover clarity in world's largest financial market means this cycle initiates onshore with dollar-denominated products. Other jurisdictions then face choice: adopt compatible regulations to participate in this growing network, or isolate themselves from largest digital asset market.

Novel insights about the path forward

The most striking revelation from synthesizing these perspectives is how policy clarity itself functions as competitive technology. Both executives describe American companies and capital fleeing to Singapore, UAE, and Europe during 2021-2024 regulatory uncertainty. The 2025 policy shift isn't primarily about specific rule changes but about ending existential uncertainty. When companies can't determine if their business model is legal or if regulators will shut them down via enforcement, they cannot plan, invest, or grow. Clarity—even with imperfect rules—enables development that uncertainty prevents.

This suggests the global crypto adoption race isn't won by most permissive regulations but by clearest frameworks. Singapore's success attracting blockchain companies stemmed from transparent licensing requirements and responsive regulators more than lax rules. The EU's MiCA regulation, while more prescriptive than U.S. approach, provides comprehensive certainty. Both executives predict American hybrid model—comprehensive federal frameworks (GENIUS Act) with state innovation (smaller stablecoin issuers)—strikes optimal balance between oversight and experimentation.

The stablecoin-as-geopolitical-strategy dimension reveals sophisticated thinking about digital currency competition. Rather than racing to create U.S. government CBDC to compete with China's digital yuan, U.S. strategy leverages private innovation while maintaining dollar dominance. Every private stablecoin becomes dollar proliferation vehicle requiring no government infrastructure investment or ongoing operational costs. The regulatory framework just enables private companies to do what they would attempt anyway, but safely and at scale. This approach plays to American strengths—innovative private sector, deep capital markets, strong rule of law—rather than attempting centralized technological feat.

The timing dimension both executives emphasize deserves attention. The confluence of technological maturity (blockchain scalability improvements), institutional readiness (71% planning allocations), political alignment (pro-crypto administration), and regulatory clarity (GENIUS Act passage) creates unique window. Hines' comment that the administration "moves at tech speed" reflects understanding that policy delays of even 1-2 years could surrender opportunities to faster-moving jurisdictions. The urgency both express isn't manufactured—it reflects recognition that global standards are being set now, and absent U.S. leadership, other powers will shape the frameworks.

Perhaps most significantly, both executives articulate vision where crypto adoption becomes largely invisible as technology gets embedded in infrastructure. The end state Hines describes—tokenized securities trading 24/7, commodity exchanges on blockchain, instant settlement as default—doesn't look like "crypto" in today's sense of speculative digital assets. It looks like normal financial operations that happen to use blockchain backend infrastructure. Carbone's emphasis on distinguishing blockchain technology from cryptocurrency speculation serves this vision: making blockchain adoption about modernization and efficiency rather than ideological cryptocurrency embrace.

The path forward both executives outline faces implementation challenges they acknowledge but downplay. Legislative consensus on stablecoins proves easier than market structure details where SEC-CFTC jurisdictional battles persist. DeFi frameworks remain conceptual more than operational. International coordination on standards requires diplomacy beyond U.S. unilateral action. Banking system integration faces cultural and technological inertia. But both express confidence these obstacles are surmountable with sustained focus—and that rivals face same challenges without America's advantages in capital, technology, and institutional development.

Their complementary work—Hines building products within new regulatory frameworks, Carbone advocating for continued policy improvements—suggests this is marathon not sprint. The July 2025 GENIUS Act passage marks inflection point, not conclusion. Both emphasize expectations are "sky-high" but caution much work remains. The success of their shared vision depends on translating policy clarity into actual adoption: institutional capital deploying, traditional banks offering services, global users adopting dollar stablecoins, and infrastructure proving reliable at scale. The next 2-3 years will reveal whether American regulatory frameworks actually do become template others follow, or if competing approaches from EU, Asia, or elsewhere prove more attractive.

What's certain is that U.S. crypto policy has fundamentally transformed from hostile to enabling in remarkably short time—18 months from peak enforcement to comprehensive legislation. Bo Hines and Cody Carbone, from their respective positions orchestrating this transformation, offer rare insight into both the deliberate strategy behind the shift and ambitious vision for how it accelerates global adoption. Their playbook—regulatory clarity over ambiguity, private stablecoins over government CBDCs, institutional integration over parallel systems, and bipartisan consensus over partisan battles—represents calculation that American competitive advantages lie in enabling innovation within frameworks rather than attempting to control or suppress technologies that will develop regardless. If they're right, the next decade sees blockchain become invisible infrastructure powering global finance, with dollar-denominated stablecoins serving as rails reaching billions currently beyond traditional banking access.

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

· 8 min read
Dora Noda
Software Engineer

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


What the Law Locks In

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

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

The “No-Interest” Rule and the Rewards Debate

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

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

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


Why This Unlocks New Markets for Blockchain Infrastructure

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

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

Architecture Patterns That Will Win

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

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

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

A Practical Builder’s Checklist

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

The Bottom Line

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

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