Decision / Product
Adding stablecoin settlement to a US payments business
Can we settle in stablecoins without changing what we are?
Stablecoin settlement is usually presented as a treasury or engineering decision. In regulatory terms it is a change to how value is held and moved, which is one of the variables most likely to change an institution's position.
Simulating the decision before build shows which configurations move the position, which do not, and where the answer depends on judgement rather than fact.
Regulatory delta
What this decision tends to move
The delta is the difference between the institution's position today and its position if this decision were executed.
- Activity
- Whether a new regulated activity is introduced.
- Custody
- Who holds the asset, and what follows from that.
- Permissions
- Whether existing permissions still cover the flow.
- State exposure
- Which states treat the configuration differently.
- Controls
- What the operating model must be able to evidence.
Design space
Ways to reach the same commercial objective
Two configurations that achieve the same outcome frequently produce materially different regulatory deltas. Comparing them is how the decision is made.
Option 01
Settlement via a regulated counterparty
Consequence concentrates in the dependency.
Option 02
Settlement with institution-held balances
Consequence concentrates in the institution.
Option 03
Hybrid: on-chain leg, off-chain customer experience
Splits consequence between the legs.
Before committing
What management should establish first
- Which configuration achieves the commercial objective with the smallest delta
- Which US states change the answer
- What has to be true operationally for each option
Common questions
Questions this page answers
Is stablecoin settlement always a new regulated activity?
No. Whether it is depends on the configuration — who holds what, where, and what the customer actually receives.
Can this be tested before engineering starts?
Yes, and that is the point. The cost of changing a settlement design after build is what simulation is intended to avoid.
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