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Regulatory Radar 2#
The Journey of the GENIUS Act: A Timeline
This timeline-driven feature traces the GENIUS Act -Guiding and Establishing National Innovation for U.S. Stablecoins Act - from its early conceptualization in February 2025 through its swift bipartisan progress in both chambers of Congress, culminating in Senate approval in just over four months.
With final passage expected before the August 2025 recess, the focus will soon shift to implementation—anticipated throughout 2026 and 2027 via rulemaking from key federal agencies including the Federal Reserve, OCC, SEC, and FinCEN.
The GENIUS Act represents the culmination of years of debate, shaped by numerous legislative efforts aimed at stablecoin oversight.
As the U.S. accelerates its response to digital asset regulation, it stands at a pivotal moment—poised to catch up with the EU’s more mature MiCA framework.
A (not so) brief history of US stablecoin legislation
The House of Representatives and the Senate have been pro-active in formulating draft laws - or bills - to create a dedicated and comprehensive US regulatory framework for payment stablecoins.
Since 2017, both the Republican and Democratic parties have proposed a plethora of legislation relating directly or indirectly to stablecoins, and payment stablecoins in particular.
The first wave of legislative proposals for a regulatory framework for stablecoins date back to 2019, in reaction to the emergence of Facebook’s Diem (ex - Libra) project. However, legislative momentum really began to pick up in 2022 with a second wave of legislation that aimed to define payment stablecoins, the legal pathways to issuing payment stablecoins as well as regulatory oversight, reserve requirements, etc.
First wave of U.S. Stablecoin Regulations
Second Wave of U.S. Stablecoin Regulations
A Step-by-Step Timeline of the GENIUS Act
Stage 1: Conception and Drafting
Stage 2: Introduction and Committee Review
Stage 3: Floor Debate and Vote
Floor Debate
Senate Consideration and Bipartisan Compromise
Final Vote (Senate)
Next Steps : from House Review to Implementation
From House Review to Official Publication
Entry into Force & Implementation
Key Timing Observations: EU vs. USA
Given the breakneck speed at which the GENIUS Act has passed the Senate, despite political frictions, it is interesting to compare the regulatory trajectories of the EU’s pioneering MiCA Regulation and the U.S. GENIUS Act:
- Where do the MiCA and GENIUS Act timelines converge—if at all?
- What can expect moving forward - which imperatives are likely to shape these distinctive trajectories?
Here are some quick takeaways.
The EU has already operationalized a leading licensing framework, placing it ahead in terms of legal certainty and supervisory action - the Market in Crypto Assets Regulation - a comprehensive digital asset framework, covering stablecoins, utility tokens, and crypto-asset service providers (CASPs).
MiCA was introduced in September 2020 and came into full legal effect in June 2023, with stablecoin provisions applicable from June 30, 2024, and broader rules from December 30, 2024.
MiCA took nearly 3 years from the introduction of the proposal to full applicability but this reflects:
- the EU’s methodical regulatory sequencing, shaped by pan-European consensus-building across EU institutions and 27 EU Member States.
- The scope of MiCA which covers all crypto-assets and crypto-asset service providers
If passed by August 2025, the GENIUS Act could be passed in only 6 to 7 months, which is by no means a small accomplishment —driven by political urgency, industry support, and a Republican led framing of the bill as a way of protecting the US dollar’s dominance (dollar-centric geopolitical strategy).
Moving forward, stakeholders looking at US developments should monitor:
- The House reconciliation process for the GENIUS Act and its coordination with the STABLE Act. The House review could escalate the debate over scope, ethics, and Big Tech carveouts—potentially merging with broader frameworks like the CLARITY Act.
- Political frictions could very well intensify as Trump’s personal crypto interests remain unchecked, attracting further pro-consumer amendments or opposition.
- The actual activation timeline of U.S. regulatory implementation : the GENIUS Act will rely heavily on subsequent rulemaking by federal agencies, with effective implementation deferred up to 18 months after enactment (i.e., late 2026 or early 2027).
- Closely linked to the previous point, the 2026 midterms may see renewed debate, shaped by campaign financing from crypto PACs and additional scrutiny over amendments (like anti-bailout measures or privacy protections).
As this series continues, we’ll unpack how these two landmark regulatory frameworks align or diverge on crucial issues such as licensing, reserve requirements, consumer protections, and oversight mechanisms.
🧭 Stay tuned for our next edition, where we will delve deeper into the MiCA-GENIUS comparison and what it means for global crypto regulation and innovation!
The Journey of the GENIUS Act: A Timeline
This timeline-driven feature traces the GENIUS Act -Guiding and Establishing National Innovation for U.S. Stablecoins Act - from its early conceptualization in February 2025 through its swift bipartisan progress in both chambers of Congress, culminating in Senate approval in just over four months.
With final passage expected before the August 2025 recess, the focus will soon shift to implementation—anticipated throughout 2026 and 2027 via rulemaking from key federal agencies including the Federal Reserve, OCC, SEC, and FinCEN.
The GENIUS Act represents the culmination of years of debate, shaped by numerous legislative efforts aimed at stablecoin oversight.
As the U.S. accelerates its response to digital asset regulation, it stands at a pivotal moment—poised to catch up with the EU’s more mature MiCA framework.
A (not so) brief history of US stablecoin legislation
The House of Representatives and the Senate have been pro-active in formulating draft laws - or bills - to create a dedicated and comprehensive US regulatory framework for payment stablecoins.
Since 2017, both the Republican and Democratic parties have proposed a plethora of legislation relating directly or indirectly to stablecoins, and payment stablecoins in particular.
The first wave of legislative proposals for a regulatory framework for stablecoins date back to 2019, in reaction to the emergence of Facebook’s Diem (ex - Libra) project. However, legislative momentum really began to pick up in 2022 with a second wave of legislation that aimed to define payment stablecoins, the legal pathways to issuing payment stablecoins as well as regulatory oversight, reserve requirements, etc.
First wave of U.S. Stablecoin Regulations
Second Wave of U.S. Stablecoin Regulations
A Step-by-Step Timeline of the GENIUS Act
Stage 1: Conception and Drafting
Stage 2: Introduction and Committee Review
Stage 3: Floor Debate and Vote
Floor Debate
Senate Consideration and Bipartisan Compromise
Final Vote (Senate)
Next Steps : from House Review to Implementation
From House Review to Official Publication
Entry into Force & Implementation
Key Timing Observations: EU vs. USA
Given the breakneck speed at which the GENIUS Act has passed the Senate, despite political frictions, it is interesting to compare the regulatory trajectories of the EU’s pioneering MiCA Regulation and the U.S. GENIUS Act:
- Where do the MiCA and GENIUS Act timelines converge—if at all?
- What can expect moving forward - which imperatives are likely to shape these distinctive trajectories?
Here are some quick takeaways.
The EU has already operationalized a leading licensing framework, placing it ahead in terms of legal certainty and supervisory action - the Market in Crypto Assets Regulation - a comprehensive digital asset framework, covering stablecoins, utility tokens, and crypto-asset service providers (CASPs).
MiCA was introduced in September 2020 and came into full legal effect in June 2023, with stablecoin provisions applicable from June 30, 2024, and broader rules from December 30, 2024.
MiCA took nearly 3 years from the introduction of the proposal to full applicability but this reflects:
- the EU’s methodical regulatory sequencing, shaped by pan-European consensus-building across EU institutions and 27 EU Member States.
- The scope of MiCA which covers all crypto-assets and crypto-asset service providers
If passed by August 2025, the GENIUS Act could be passed in only 6 to 7 months, which is by no means a small accomplishment —driven by political urgency, industry support, and a Republican led framing of the bill as a way of protecting the US dollar’s dominance (dollar-centric geopolitical strategy).
Moving forward, stakeholders looking at US developments should monitor:
- The House reconciliation process for the GENIUS Act and its coordination with the STABLE Act. The House review could escalate the debate over scope, ethics, and Big Tech carveouts—potentially merging with broader frameworks like the CLARITY Act.
- Political frictions could very well intensify as Trump’s personal crypto interests remain unchecked, attracting further pro-consumer amendments or opposition.
- The actual activation timeline of U.S. regulatory implementation : the GENIUS Act will rely heavily on subsequent rulemaking by federal agencies, with effective implementation deferred up to 18 months after enactment (i.e., late 2026 or early 2027).
- Closely linked to the previous point, the 2026 midterms may see renewed debate, shaped by campaign financing from crypto PACs and additional scrutiny over amendments (like anti-bailout measures or privacy protections).
As this series continues, we’ll unpack how these two landmark regulatory frameworks align or diverge on crucial issues such as licensing, reserve requirements, consumer protections, and oversight mechanisms.
🧭 Stay tuned for our next edition, where we will delve deeper into the MiCA-GENIUS comparison and what it means for global crypto regulation and innovation!
Regulatory Radar #1
Welcome to the first edition of Regulatory Radar—a space for short, sharp insights into the rules, tools, and trends shaping financial regulation!
We’re starting with a timely topic: the no-action letter—a somewhat obscure but important regulatory instrument used by European Supervisory Authorities (ESAs). On 10 June 2025, the European Banking Authority (EBA) issued a no-action letter addressing the interaction between PSD2 and MiCA—marking the first time this tool has been used to navigate the complex overlap between legacy payments regulation and Europe’s new crypto framework.
But what exactly is a no-action letter in the EU context? Who can issue one? What’s its legal weight? And why should market participants and policymakers alike pay attention?
Let’s take a closer look.
Which EU supervisory authorities can issue a no-action letter?
Following the 2019 ESA Reform Regulation, all European Supervisory Authorities (ESAs) were given the authority to issue no-action letters:
What is the legal basis of a no-action letter?
The legal basis of a no-action letter differs across the European Supervisory Authorities:
- European Banking Authority (EBA): Article 9c of EBA’s founding regulation - Regulation (EU) 1093/2010 - grants the EBA the authority to expeditiously issue no-action letters
- European Securities and Markets Authority (ESMA): Article 9a of ESMA’s founding regulation - Regulation (EU) 1095/2010 - grants the ESMA the authority to expeditiously issue no-action letters.
- European Insurance and Occupational Pensions Authority (EIOPA): Article 9a of EIOPA’s founding regulation - Regulation (EU) 1094/2010- grants the EIOPA the authority to expeditiously issue no-action letters.
The EBA, ESMA and EIOPA may equally participate in joint ESA no-action letters as was the case in December 2023 on EMIR Margin Requirements.
Specifically, on essentially the same terms, the EBA, ESMA, and EIOPA may issue a no-action letter in the following three circumstances:
- Provisions contained in a relevant EU Legislative act may directly conflict with another relevant EU legislative act.
- The absence of delegated or implementing acts that complement or specify a legislative act raises legitimate doubts concerning the legal consequences from the legislative act or its proper application.
- The absence of EBA guidelines or recommendations would raise practical difficulties concerning the application of the relevant legislative act.
What is the aim of an ESA no-action letter?
In the European Union, no-action letters are not addressed to individual firms, but rather address an issue affecting the market as a whole. The pattern across ESAs suggests that only exceptional, systemic regulatory conflicts, as opposed to firm-specific or minor compliance issues, have triggered the issuance of no-action letters.
No-action letters issued by ESAs do not change EU law but they provide interim guidance to regulators and market participants on how to handle problematic provisions until a more permanent solution is in place.
Usually addressed primarily to all national regulators in the EU, this interim guidance may provide :
- Short-term non-supervisory or non-enforcement guidance :
- A no-action letter may state that no supervisory or enforcement actions should be taken against firms for non-compliance with specified provisions, for a limited time or until certain conditions are met.
- A no-action letter may outline supervisory expectations during an interim period when the timing of implementation or the scope of two regulatory regimes are misaligned.
- Long-Term legislative action :
- ESAs may issue a public opinion to the European Commission (EC) on any action it considers appropriate, in the form of a new legislative proposal or a proposal for a new delegated or implementing act, and on the urgency that, in the Authority’s judgment, is attached to the issue.
- ESAs may equally evaluate as soon as possible the need to adopt further relevant guidelines or recommendations that do not warrant further legislative action.
- Each no-action letter issued by ESAs so far has been accompanied by outreach to the European Commission.
Is a no-action letter legally binding?
A no-action letter is delivered as an opinion (soft-law) and is therefore not legally binding on relevant National Competent Authorities (NCAs) or firms operating in the EU. The ESAs’ respective Founding Regulations do not grant ESA’s authority the power to disapply or suspend the law.
However, a no-action letter constitutes an important precedent - NCAs have strong incentives to follow the guidance to maintain a level-playing field and avoid fragmentation.
Welcome to the first edition of Regulatory Radar—a space for short, sharp insights into the rules, tools, and trends shaping financial regulation!
We’re starting with a timely topic: the no-action letter—a somewhat obscure but important regulatory instrument used by European Supervisory Authorities (ESAs). On 10 June 2025, the European Banking Authority (EBA) issued a no-action letter addressing the interaction between PSD2 and MiCA—marking the first time this tool has been used to navigate the complex overlap between legacy payments regulation and Europe’s new crypto framework.
But what exactly is a no-action letter in the EU context? Who can issue one? What’s its legal weight? And why should market participants and policymakers alike pay attention?
Let’s take a closer look.
Which EU supervisory authorities can issue a no-action letter?
Following the 2019 ESA Reform Regulation, all European Supervisory Authorities (ESAs) were given the authority to issue no-action letters:
What is the legal basis of a no-action letter?
The legal basis of a no-action letter differs across the European Supervisory Authorities:
- European Banking Authority (EBA): Article 9c of EBA’s founding regulation - Regulation (EU) 1093/2010 - grants the EBA the authority to expeditiously issue no-action letters
- European Securities and Markets Authority (ESMA): Article 9a of ESMA’s founding regulation - Regulation (EU) 1095/2010 - grants the ESMA the authority to expeditiously issue no-action letters.
- European Insurance and Occupational Pensions Authority (EIOPA): Article 9a of EIOPA’s founding regulation - Regulation (EU) 1094/2010- grants the EIOPA the authority to expeditiously issue no-action letters.
The EBA, ESMA and EIOPA may equally participate in joint ESA no-action letters as was the case in December 2023 on EMIR Margin Requirements.
Specifically, on essentially the same terms, the EBA, ESMA, and EIOPA may issue a no-action letter in the following three circumstances:
- Provisions contained in a relevant EU Legislative act may directly conflict with another relevant EU legislative act.
- The absence of delegated or implementing acts that complement or specify a legislative act raises legitimate doubts concerning the legal consequences from the legislative act or its proper application.
- The absence of EBA guidelines or recommendations would raise practical difficulties concerning the application of the relevant legislative act.
What is the aim of an ESA no-action letter?
In the European Union, no-action letters are not addressed to individual firms, but rather address an issue affecting the market as a whole. The pattern across ESAs suggests that only exceptional, systemic regulatory conflicts, as opposed to firm-specific or minor compliance issues, have triggered the issuance of no-action letters.
No-action letters issued by ESAs do not change EU law but they provide interim guidance to regulators and market participants on how to handle problematic provisions until a more permanent solution is in place.
Usually addressed primarily to all national regulators in the EU, this interim guidance may provide :
- Short-term non-supervisory or non-enforcement guidance :
- A no-action letter may state that no supervisory or enforcement actions should be taken against firms for non-compliance with specified provisions, for a limited time or until certain conditions are met.
- A no-action letter may outline supervisory expectations during an interim period when the timing of implementation or the scope of two regulatory regimes are misaligned.
- Long-Term legislative action :
- ESAs may issue a public opinion to the European Commission (EC) on any action it considers appropriate, in the form of a new legislative proposal or a proposal for a new delegated or implementing act, and on the urgency that, in the Authority’s judgment, is attached to the issue.
- ESAs may equally evaluate as soon as possible the need to adopt further relevant guidelines or recommendations that do not warrant further legislative action.
- Each no-action letter issued by ESAs so far has been accompanied by outreach to the European Commission.
Is a no-action letter legally binding?
A no-action letter is delivered as an opinion (soft-law) and is therefore not legally binding on relevant National Competent Authorities (NCAs) or firms operating in the EU. The ESAs’ respective Founding Regulations do not grant ESA’s authority the power to disapply or suspend the law.
However, a no-action letter constitutes an important precedent - NCAs have strong incentives to follow the guidance to maintain a level-playing field and avoid fragmentation.
The Great Fintech Migration: Why Every Payment Company Will Run on Stablecoins
Forward-thinking payment companies are rebuilding their infrastructure for the next decade of financial services
In February 2025, Stripe paid $1.1 billion for Bridge. Three weeks later, Visa announced stablecoin card partnerships across six Latin American countries. Last month, Mastercard launched end-to-end stablecoin processing with major crypto platforms. Last week, Stripe doubled down with the acquisition of Privy.
Stablecoin networks have quietly grown to process $27.6 trillion in annual volume - outpacing Visa and Mastercard combined.
Stablecoin infrastructure is faster and cheaper, and companies are using it to fundamentally rebuild payment infrastructure for the next decade of financial services. The great fintech migration isn't coming. It's here.
Forward-thinking companies are making the transition now
The numbers tell a story of unprecedented acceleration. In the past six months alone:
- Stripe completed their largest acquisition frenzy ever, securing stablecoin infrastructure
- RedotPay raised $40 million to expand crypto card programs globally
- MoonPay acquired Iron for $100+ million to compete with Stripe
- PayPal announced PayPal USD (PYUSD) expansion to Stellar network, targeting remittances and "PayFi" solutions for their 400+ million users
- Nubank partnered with Lightspark to integrate Bitcoin Lightning Network for their 100+ million customers across Latin America
This is a land grab for infrastructure that will power payments for the next decade. Stablecoin supply grew 59% in 2024 alone, with companies like Starlink using stablecoins to repatriate funds from international operations.
The scale and speed of these moves signal that stablecoin infrastructure has reached a tipping point.
The hidden crisis of legacy payment infrastructure
Every payment company will eventually migrate to stablecoin infrastructure. While some debate the merits of moving onchain, others are already processing billions in stablecoin volume and unlocking cost advantages today.
The companies making this transition first understand something crucial: this isn't about replacing existing systems overnight. It's about building the foundational infrastructure that can support the next decade of financial services.
Legacy payment rails carry deep, structural inefficiencies - what we call the "Money Prison." Capital gets trapped in transit between financial institutions, creating friction that erodes profitability and user experience. The pain points are systemic:
1. Capital trapped in motion
Consider a typical cross-border payment. When a business in New York sends $50,000 to a supplier in Singapore, that money begins a multi-day journey through correspondent banks, clearing houses, and regulatory checkpoints. Each step introduces delays, fees, and failure points. These delays are not just inconvenient—they're expensive. Slow settlement processes cost institutions $100 billion annually, while global corporations lose $120 billion annually in cross-border fees. Companies like Wise have optimized the costs for some major corridors by netting the transfers they have to execute, although this is also very capital-intensive.
2. Capital locked in collateral
Money doesn't move 24/7 instantly in traditional banking systems. This creates counterparty risk during settlement windows. Companies need to maintain collateral and pre-funded accounts to cover these gaps. This capital sits idle instead of being deployed productively.
3. The reconciliation nightmare
Finance teams spend 30% of their time manually matching financial records across unsynchronized systems including banks, card networks, payment processors, and accounting platforms. These discrepancies are the result of outdated infrastructure that was never designed to operate in real-time.
The stablecoin infrastructure advantage
Forward-thinking payment companies are discovering a different approach:
→ 24/7/365 settlement capabilities
Unlike traditional banking systems that operate on business hours and batch processing schedules, stablecoin networks never sleep. A payment initiated at 11 PM on Christmas Day settles with the same speed and reliability as one sent during peak business hours.
→ Programmable money flows
Smart contracts can automate complex payment logic that currently requires manual intervention. Unlike traditional systems that require separate agreements and integrations for each payment rule, smart contracts can execute multi-party splits, conditional releases, and escrow arrangements automatically without intermediaries.
→ Global reach without correspondent banking
Traditional cross-border payments require relationships with correspondent banks in each jurisdiction - relationships that come with compliance costs and operational complexity. Stablecoin infrastructure provides direct settlement without intermediaries.
→ Transparent, auditable transaction history
Every transaction on a blockchain creates an immutable audit trail - one single source of truth that eliminates reconciliation nightmares. Instead of matching records across multiple systems, everyone looks at the same blockchain ledger. This dramatically reduces dispute resolution time and costs while providing real-time visibility into payment flows.
→ Direct crypto spending through cards
The missing piece has been enabling real-world spending. While stablecoins excel at B2B transfers and cross-border payments, consumers need a familiar way to spend without cumbersome off-ramping processes.
Crypto cards solve this by connecting stablecoin wallets directly to existing payment networks. Kulipa provides this functionality to wallets and PayFi apps, bridging on-chain balances with traditional card networks like Visa and Mastercard.
Crypto cards eliminate the multi-step conversion process that previously kept crypto in a separate financial universe from daily commerce - no more transferring to exchanges, converting to fiat, then withdrawing to bank accounts. Visa has settled over $225 million in stablecoin transactions using Solana and Ethereum networks, proving this direct spending approach works at scale. Users can now spend stablecoins anywhere traditional cards are accepted through familiar interfaces.
The complete infrastructure transformation
Why are industry leaders like Stripe and MoonPay investing billions in stablecoin infrastructure? The answer lies in the fundamental limitations of current payment architecture.
Traditional payment systems require separate integrations and capital requirements for different payment products (access to US bonds, PE funds, high-risk debt etc). Stablecoin infrastructure helps reduce operational complexity while making it easy to launch these new payment products.
The current acquisition frenzy reflects this strategic shift. Companies aren't just buying technology - they're positioning themselves to operate with fundamentally different payment architecture while maintaining familiar user experiences. The goal is to combine on-chain settlement efficiency with interfaces users already trust, so customers get faster, cheaper, more transparent payments without needing to understand blockchain technology.
Whether this approach delivers the anticipated benefits remains to be seen, but the scale of investment suggests industry leaders believe the transition is inevitable.
The cost of waiting
We're at an inflection point for fintechs. Customers increasingly expect seamless financial experiences. Companies building on traditional banking rails face settlement delays and operational inefficiencies that become more costly as stablecoin infrastructure demonstrates superior performance.
The most successful fintechs are responding by rebuilding their core infrastructure around stablecoin settlement while partnering with specialized providers to offer complete solutions. This approach addresses both backend efficiency gains and frontend user expectations without requiring companies to build everything in-house.
The window to make this transition is narrowing. As regulatory frameworks solidify and major payment networks accelerate their crypto integrations, fintechs who act now can offer their users complete financial sovereignty, combining the operational efficiency of stablecoin infrastructure with the spending capabilities users demand.
The great fintech migration has begun. The question is whether your platform will become a complete on-chain product built around stablecoins or remain constrained by legacy systems and limited user capabilities.
Forward-thinking payment companies are rebuilding their infrastructure for the next decade of financial services
In February 2025, Stripe paid $1.1 billion for Bridge. Three weeks later, Visa announced stablecoin card partnerships across six Latin American countries. Last month, Mastercard launched end-to-end stablecoin processing with major crypto platforms. Last week, Stripe doubled down with the acquisition of Privy.
Stablecoin networks have quietly grown to process $27.6 trillion in annual volume - outpacing Visa and Mastercard combined.
Stablecoin infrastructure is faster and cheaper, and companies are using it to fundamentally rebuild payment infrastructure for the next decade of financial services. The great fintech migration isn't coming. It's here.
Forward-thinking companies are making the transition now
The numbers tell a story of unprecedented acceleration. In the past six months alone:
- Stripe completed their largest acquisition frenzy ever, securing stablecoin infrastructure
- RedotPay raised $40 million to expand crypto card programs globally
- MoonPay acquired Iron for $100+ million to compete with Stripe
- PayPal announced PayPal USD (PYUSD) expansion to Stellar network, targeting remittances and "PayFi" solutions for their 400+ million users
- Nubank partnered with Lightspark to integrate Bitcoin Lightning Network for their 100+ million customers across Latin America
This is a land grab for infrastructure that will power payments for the next decade. Stablecoin supply grew 59% in 2024 alone, with companies like Starlink using stablecoins to repatriate funds from international operations.
The scale and speed of these moves signal that stablecoin infrastructure has reached a tipping point.
The hidden crisis of legacy payment infrastructure
Every payment company will eventually migrate to stablecoin infrastructure. While some debate the merits of moving onchain, others are already processing billions in stablecoin volume and unlocking cost advantages today.
The companies making this transition first understand something crucial: this isn't about replacing existing systems overnight. It's about building the foundational infrastructure that can support the next decade of financial services.
Legacy payment rails carry deep, structural inefficiencies - what we call the "Money Prison." Capital gets trapped in transit between financial institutions, creating friction that erodes profitability and user experience. The pain points are systemic:
1. Capital trapped in motion
Consider a typical cross-border payment. When a business in New York sends $50,000 to a supplier in Singapore, that money begins a multi-day journey through correspondent banks, clearing houses, and regulatory checkpoints. Each step introduces delays, fees, and failure points. These delays are not just inconvenient—they're expensive. Slow settlement processes cost institutions $100 billion annually, while global corporations lose $120 billion annually in cross-border fees. Companies like Wise have optimized the costs for some major corridors by netting the transfers they have to execute, although this is also very capital-intensive.
2. Capital locked in collateral
Money doesn't move 24/7 instantly in traditional banking systems. This creates counterparty risk during settlement windows. Companies need to maintain collateral and pre-funded accounts to cover these gaps. This capital sits idle instead of being deployed productively.
3. The reconciliation nightmare
Finance teams spend 30% of their time manually matching financial records across unsynchronized systems including banks, card networks, payment processors, and accounting platforms. These discrepancies are the result of outdated infrastructure that was never designed to operate in real-time.
The stablecoin infrastructure advantage
Forward-thinking payment companies are discovering a different approach:
→ 24/7/365 settlement capabilities
Unlike traditional banking systems that operate on business hours and batch processing schedules, stablecoin networks never sleep. A payment initiated at 11 PM on Christmas Day settles with the same speed and reliability as one sent during peak business hours.
→ Programmable money flows
Smart contracts can automate complex payment logic that currently requires manual intervention. Unlike traditional systems that require separate agreements and integrations for each payment rule, smart contracts can execute multi-party splits, conditional releases, and escrow arrangements automatically without intermediaries.
→ Global reach without correspondent banking
Traditional cross-border payments require relationships with correspondent banks in each jurisdiction - relationships that come with compliance costs and operational complexity. Stablecoin infrastructure provides direct settlement without intermediaries.
→ Transparent, auditable transaction history
Every transaction on a blockchain creates an immutable audit trail - one single source of truth that eliminates reconciliation nightmares. Instead of matching records across multiple systems, everyone looks at the same blockchain ledger. This dramatically reduces dispute resolution time and costs while providing real-time visibility into payment flows.
→ Direct crypto spending through cards
The missing piece has been enabling real-world spending. While stablecoins excel at B2B transfers and cross-border payments, consumers need a familiar way to spend without cumbersome off-ramping processes.
Crypto cards solve this by connecting stablecoin wallets directly to existing payment networks. Kulipa provides this functionality to wallets and PayFi apps, bridging on-chain balances with traditional card networks like Visa and Mastercard.
Crypto cards eliminate the multi-step conversion process that previously kept crypto in a separate financial universe from daily commerce - no more transferring to exchanges, converting to fiat, then withdrawing to bank accounts. Visa has settled over $225 million in stablecoin transactions using Solana and Ethereum networks, proving this direct spending approach works at scale. Users can now spend stablecoins anywhere traditional cards are accepted through familiar interfaces.
The complete infrastructure transformation
Why are industry leaders like Stripe and MoonPay investing billions in stablecoin infrastructure? The answer lies in the fundamental limitations of current payment architecture.
Traditional payment systems require separate integrations and capital requirements for different payment products (access to US bonds, PE funds, high-risk debt etc). Stablecoin infrastructure helps reduce operational complexity while making it easy to launch these new payment products.
The current acquisition frenzy reflects this strategic shift. Companies aren't just buying technology - they're positioning themselves to operate with fundamentally different payment architecture while maintaining familiar user experiences. The goal is to combine on-chain settlement efficiency with interfaces users already trust, so customers get faster, cheaper, more transparent payments without needing to understand blockchain technology.
Whether this approach delivers the anticipated benefits remains to be seen, but the scale of investment suggests industry leaders believe the transition is inevitable.
The cost of waiting
We're at an inflection point for fintechs. Customers increasingly expect seamless financial experiences. Companies building on traditional banking rails face settlement delays and operational inefficiencies that become more costly as stablecoin infrastructure demonstrates superior performance.
The most successful fintechs are responding by rebuilding their core infrastructure around stablecoin settlement while partnering with specialized providers to offer complete solutions. This approach addresses both backend efficiency gains and frontend user expectations without requiring companies to build everything in-house.
The window to make this transition is narrowing. As regulatory frameworks solidify and major payment networks accelerate their crypto integrations, fintechs who act now can offer their users complete financial sovereignty, combining the operational efficiency of stablecoin infrastructure with the spending capabilities users demand.
The great fintech migration has begun. The question is whether your platform will become a complete on-chain product built around stablecoins or remain constrained by legacy systems and limited user capabilities.