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Stablecoin projects and their role in crypto finance

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World Liberty Financial: The Future of Money, Backed by USD1

· 11 min read
Dora Noda
Software Engineer

Overview of World Liberty Financial

World Liberty Financial (WLFI) is a decentralized‑finance (DeFi) platform created by members of the Trump family and their partners. According to the Trump Organization’s site, the platform aims to bridge traditional banking and blockchain technology by combining the stability of legacy finance with the transparency and accessibility of decentralized systems. Its mission is to provide modern services for money movement, lending and digital‑asset management while supporting dollar‑backed stability, making capital accessible to individuals and institutions, and simplifying DeFi for mainstream users.

WLFI launched its governance token ($WLFI) in September 2025 and introduced a dollar‑pegged stablecoin called USD1 in March 2025. The platform describes USD1 as a “future of money” stablecoin designed to serve as the base pair for tokenized assets and to promote U.S. dollar dominance in the digital economy. Co‑founder Donald Trump Jr. has framed WLFI as a non‑political venture intended to empower everyday people and strengthen the U.S. dollar’s global role.

History and Founding

  • Origins (2024–2025). WLFI was announced in September 2024 as a crypto venture led by members of the Trump family. The company launched its governance token WLFIlaterthatyear.AccordingtoReuters,theenterprisesinitialWLFI later that year. According to Reuters, the enterprise’s initial WLFI token sale raised only about $2.7 million, but sales surged after Donald Trump’s 2024 election victory (information referenced in widely cited reports, though not directly available in our sources). WLFI is majority‑owned by a Trump business entity and has nine co‑founders, including Donald Trump Jr., Eric Trump and Barron Trump.
  • Management. The Trump Organization describes WLFI’s leadership roles as: Donald Trump (Chief Crypto Advocate), Eric Trump and Donald Trump Jr. (Web3 Ambassadors), Barron Trump (DeFi visionary), and Zach Witkoff (CEO and co‑founder). The company’s daily operations are managed by Zach Witkoff and partners such as Zachary Folkman and Chase Herro.
  • Stablecoin initiative. WLFI announced the USD1 stablecoin in March 2025. USD1 was described as a dollar‑pegged stablecoin backed by U.S. Treasuries, U.S. dollar deposits and other cash equivalents. The coin’s reserves are custodied by BitGo Trust Company, a regulated digital‑asset custodian. USD1 launched on Binance’s BNB Chain and later expanded to Ethereum, Solana and Tron.

USD1 Stablecoin: Design and Features

Reserve model and stability mechanism

USD1 is designed as a fiat‑backed stablecoin with a 1:1 redemption mechanism. Each USD1 token is redeemable for one U.S. dollar, and the stablecoin’s reserves are held in short‑term U.S. Treasury bills, dollar deposits and cash equivalents. These assets are custodied by BitGo Trust, a regulated entity known for institutional digital‑asset custody. WLFI advertises that USD1 offers:

  1. Full collateralization and audits. The reserves are fully collateralized and subject to monthly third‑party attestations, providing transparency over backing assets. In May 2025, Binance Academy noted that regular reserve breakdowns were not yet publicly available and that WLFI had pledged third‑party audits.
  2. Institutional orientation. WLFI positions USD1 as an “institutional‑ready” stablecoin aimed at banks, funds and large companies, though it is also accessible to retail users.
  3. Zero mint/redeem fees. USD1 reportedly charges no fees for minting or redemption, reducing friction for users handling large volumes.
  4. Cross‑chain interoperability. The stablecoin uses Chainlink’s Cross‑Chain Interoperability Protocol (CCIP) to enable secure transfers across Ethereum, BNB Chain and Tron. Plans to expand to additional blockchains were confirmed through partnerships with networks like Aptos and Tron.

Market performance

  • Rapid growth. Within a month of launch, USD1’s market capitalization reached about $2.1 billion, driven by high‑profile institutional deals such as a $2 billion investment by Abu Dhabi’s MGX fund into Binance using USD1. By early October 2025 the supply had grown to roughly $2.68 billion, with most tokens issued on BNB Chain (79 %), followed by Ethereum, Solana and Tron.
  • Listing and adoption. Binance listed USD1 on its spot market in May 2025. WLFI touts widespread integration across DeFi protocols and centralised exchanges. DeFi platforms like ListaDAO, Venus Protocol and Aster support lending, borrowing and liquidity pools using USD1. WLFI emphasises that users can redeem USD1 for U.S. dollars through BitGo within one to two business days.

Institutional uses and tokenized asset plans

WLFI envisions USD1 as the default settlement asset for tokenized real‑world assets (RWAs). CEO Zach Witkoff has said that commodities such as oil, gas, cotton and timber should be traded on‑chain and that WLFI is actively working to tokenize these assets and pair them with USD1 because they require a trustworthy, transparent stablecoin. He described USD1 as “the most trustworthy and transparent stablecoin on Earth”.

Products and Services

Debit card and retail apps

At the TOKEN2049 conference in Singapore, Zach Witkoff announced that WLFI will release a crypto debit card that allows users to spend digital assets in everyday transactions. The company planned to launch a pilot program in the next quarter, with a full rollout expected in Q4 2025 or Q1 2026. CoinLaw summarized key details:

  • The card will link crypto balances to consumer purchases and is expected to integrate with services like Apple Pay.
  • WLFI is also developing a consumer‑facing retail app to complement the card.

Tokenization and investment products

Beyond payments, WLFI aims to tokenize real‑world commodities. Witkoff said they are exploring tokenization of oil, gas, timber and real estate to create blockchain‑based trading instruments. WLFI’s governance token (WLFI), launched in September 2025, grants holders the ability to vote on certain corporate decisions. The project has also formed strategic partnerships, including ALT5 Sigma’s agreement to purchase \750 million of WLFI tokens as part of its treasury strategy.

Donald Trump Jr.’s Perspective

Co‑founder Donald Trump Jr. is a prominent public face of WLFI. His remarks at industry events and interviews reveal the motivations behind the project and his views on traditional finance, regulation and the U.S. dollar’s role.

Critique of traditional finance

  • “Broken” and undemocratic system. During a panel titled World Liberty Financial: The Future of Money, Backed by USD1 at the Token2049 conference, Trump Jr. argued that traditional finance is undemocratic and “broken.” He recounted that when his family entered politics, 300 of their bank accounts were eliminated overnight, illustrating how financial institutions can punish individuals for political reasons. He said the family moved from being at the top of the financial “pyramid” to the bottom, revealing that the system favours insiders and functions like a Ponzi scheme.
  • Inefficiency and lack of value. He criticised the traditional financial industry for being mired in inefficiencies, where people “making seven figures a year” merely push paperwork without adding real value.

Advocating for stablecoins and the dollar

  • Preserving dollar hegemony. Trump Jr. asserts that stablecoins like USD1 will backfill the role previously played by countries purchasing U.S. Treasuries. He told the Business Times that stablecoins could create “dollar hegemony” allowing the U.S. to lead globally and keep many places safe and sound. Speaking to Cryptopolitan, he argued that stablecoins actually preserve U.S. dollar dominance because demand for dollar‑backed tokens supports Treasuries at a time when conventional buyers (e.g., China and Japan) are reducing exposure.
  • Future of finance and DeFi. Trump Jr. described WLFI as the future of finance and emphasized that blockchain and DeFi technologies can democratize access to capital. At an ETH Denver event covered by Panews, he argued that clear regulatory frameworks are needed to prevent companies from moving offshore and to protect investors. He urged the U.S. to lead global crypto innovation and criticized excessive regulation for stifling growth.
  • Financial democratization. He believes combining traditional and decentralized finance through WLFI will provide liquidity, transparency and stability to underserved populations. He also highlights blockchain’s potential to eliminate corruption by making transactions transparent and on‑chain.
  • Advice to newcomers. Trump Jr. advises new investors to start with small amounts, avoid excessive leverage and engage in continuous learning about DeFi.

Political neutrality and media criticism

Trump Jr. stresses that WLFI is “100 % not a political organization” despite the Trump family’s deep involvement. He frames the venture as a platform to benefit Americans and the world rather than a political vehicle. During the Token2049 panel he criticized mainstream media outlets, saying they had discredited themselves, and Zach Witkoff asked the audience whether they considered The New York Times trustworthy.

Partnerships and Ecosystem Integration

MGX–Binance investment

In May 2025, WLFI announced that USD1 would facilitate a $2 billion investment by Abu Dhabi‑based MGX into crypto exchange Binance. The announcement highlighted WLFI’s growing influence and was touted as evidence of USD1’s institutional appeal. However, U.S. Senator Elizabeth Warren criticized the deal, calling it “corruption” because pending stablecoin legislation (the GENIUS Act) could benefit the president’s family. CoinMarketCap data cited by Reuters showed USD1’s circulating value reaching about $2.1 billion at that time.

Aptos partnership

At the TOKEN2049 conference in October 2025, WLFI and layer‑1 blockchain Aptos announced a partnership to deploy USD1 on the Aptos network. Brave New Coin reports that WLFI selected Aptos because of its high throughput (transactions settle in under half a second) and fees under one‑hundredth of a cent. The collaboration aims to challenge dominant stablecoin networks by providing cheaper, faster rails for institutional transactions. CryptoSlate notes that USD1’s integration will make Aptos the fifth network to mint the stablecoin, with day‑one support from DeFi protocols such as Echelon Market and Hyperion as well as wallets and exchanges like Petra, Backpack and OKX. WLFI executives view the expansion as part of a broader strategy to grow DeFi adoption and to position USD1 as a settlement layer for tokenized assets.

Debit‑card and Apple Pay integration

Reuters and CoinLaw report that WLFI will launch a crypto debit card bridging crypto assets with everyday spending. Witkoff told Reuters that the company expects to roll out a pilot program within the next quarter, with a full launch by late 2025 or early 2026. The card will integrate with Apple Pay, and WLFI will release a retail app to simplify crypto payments.

Controversies and Criticisms

Reserve transparency. Binance Academy highlighted that, as of May 2025, USD1 lacked publicly available reserve breakdowns. WLFI promised third‑party audits, but the absence of detailed disclosures raised investor concerns.

Political conflicts of interest. WLFI’s deep ties to the Trump family have drawn scrutiny. A Reuters investigation reported that an anonymous wallet holding $2 billion in USD1 received funds shortly before the MGX investment, and the owners of the wallet could not be identified. Critics argue that the venture could allow the Trump family to benefit financially from regulatory decisions. Senator Elizabeth Warren warned that the stablecoin legislation being considered by Congress would make it easier for the president and his family to “line their own pockets”. Media outlets like The New York Times and The New Yorker have described WLFI as eroding the boundary between private enterprise and public policy.

Market concentration and liquidity concerns. CoinLaw reported that more than half of USD1’s liquidity came from just three wallets as of June 2025. Such concentration raises questions about the organic demand for USD1 and its resilience in stressed markets.

Regulatory uncertainty. Trump Jr. himself acknowledges that U.S. crypto regulation remains unclear and calls for comprehensive rules to prevent companies from moving offshore. Critics argue that WLFI benefits from deregulatory moves by the Trump administration while shaping policy that could favour its own financial interests.

Conclusion

World Liberty Financial positions itself as a pioneer at the intersection of traditional finance and decentralized technology, using the USD1 stablecoin as the backbone for payments, tokenization and DeFi products. The platform’s emphasis on institutional backing, cross‑chain interoperability and zero‑fee minting distinguishes USD1 from other stablecoins. Partnerships with networks like Aptos and major deals such as the MGX‑Binance investment underscore WLFI’s ambition to become a global settlement layer for tokenized assets.

From Donald Trump Jr.’s perspective, WLFI is not merely a commercial venture but a mission to democratize finance, preserve U.S. dollar hegemony and challenge what he sees as a broken and elitist traditional‑finance system. He champions regulatory clarity while criticizing excessive oversight, reflecting broader debates within the crypto industry. However, WLFI’s political associations, opaque reserve disclosures and concentration of liquidity invite skepticism. The company’s success will depend on balancing innovation with transparency and navigating the complex interplay between private interests and public policy.

The GENIUS Act: Transforming the Stablecoin Landscape

· 9 min read
Dora Noda
Software Engineer

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

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

· 5 min read
Dora Noda
Software Engineer

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

TL;DR

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

What each person is emphasizing

1) Scotty James — Mainstream accessibility & culture

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

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

2) Sam Liu — Product architecture & fairness

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

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

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

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

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

What’s already live (concrete facts)

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

The near‑term arc of the vision

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

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

Why this is different

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

Open questions to watch

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

Quick source highlights

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

Stablecoin Chains

· 10 min read
Dora Noda
Software Engineer

What if the most lucrative real estate in crypto isn't a Layer 1 protocol or a DeFi application—but the pipes beneath your digital dollars?

Circle, Stripe, and Tether are betting hundreds of millions that controlling the settlement layer for stablecoins will prove more valuable than the stablecoins themselves. In 2025, three of the industry's most powerful players announced purpose-built blockchains designed specifically for stablecoin transactions: Circle's Arc, Stripe's Tempo, and Plasma. The race to own stablecoin infrastructure has begun—and the stakes couldn't be higher.

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.

How Stablecoins Can Go Mainstream Like Credit Cards

· 8 min read
Dora Noda
Software Engineer

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

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

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

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

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

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

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

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

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

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

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

1) Convenience (The Gap Is Narrowing)

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

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

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

2) Incentives (For Both Merchants and Consumers)

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

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

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

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

3. How to Bootstrap a Stablecoin Payment Network

Step One: Build Self-Contained "Strongholds"

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

  • Niche A: Relative Convenience + New Sales.

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

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

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

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

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

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

4. Common Objections and Counterarguments

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

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

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

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

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

5. Verifiable Milestones in 12–24 Months

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

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

Conclusion

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