Articles
What Treasury and Payments Professionals Need to Know About Stablecoins After the GENIUS Act
- By AFP Staff
- Published: 11/3/2025

Stablecoins have been generating significant interest, particularly with the passage of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). But where do stablecoins fit into the future of corporate treasury and payments?
During an AFP webinar, Jason Ekberg, Partner at Oliver Wyman, shared practical considerations for treasury and payments professionals to keep in mind when considering stablecoin adoption.
Use cases for corporate treasury and payments
It’s important to first grasp how corporates can leverage stablecoins as part of their treasury and payments strategy. Ekberg outlined four broad categories where stablecoins are gaining traction:
- Collections in hard-to-reach markets – Corporates can receive real-time payments in emerging markets where traditional channels involve multiple intermediaries, foreign exchange drag or currency controls.
- Liquidity management – Treasurers can use stablecoins to pool cash across borders —without waiting for bank cut-off times — and have more flexible access to intraday liquidity.
- Yield generation – Once issued, stablecoins can be lent out (just like securities) to generate additional returns in addition to rebates and other cross-sell incentives
- Payments – Stablecoins enable instant supplier payouts, including milestone, escrow-based smart contracts that release funds automatically when predefined conditions are met.
“Of the clients I speak with, especially in Europe, all of these are being considered as strategies to optimize how they run their treasury,” said Ekberg.
Regulation and global developments
In the U.S., the GENIUS Act divides legislation between regulatory bodies at the federal and state levels. Rulemaking and oversight will primarily lie with the U.S. Treasury and federal banking regulators, and there will be a stablecoin certification review committee consisting of the U.S. Treasury, Fed and FDIC. Under review will be all state comparables, issuances and approvals to ensure coordination between federal and state authorities. In terms of accounting, U.S. GAAP and FASB still need to weigh in.
Globally, regulation is advancing quickly. Japan, Singapore, Hong Kong, Middle East and the EU. “There is a regulatory global framework now emerging that hopefully, in the near term, is going to give treasurers confidence and conviction that if they are running global or regional treasuries, they can take advantage of stablecoins,” said Ekberg.
There is one challenge in global development that remains: a lack of liquidity, which limits market access. However, solutions are emerging. For example, in some African markets, gateway providers and financial players help convert stablecoins like USDC into local currencies, creating off-ramps and building liquidity. At the same time, larger systems like SWIFT are developing solutions for cross-border stablecoin use, integrating regulatory and legal frameworks.
Choosing a network model
Stablecoins don’t operate in a vacuum — they run on blockchain networks. The choice of a private, public or hybrid network carries with it serious implications regarding security, scalability, governance and cost.
- Private – These networks are highly centralized and controlled by a few entities. Because access is restricted, they come with less risk, but they also have scalability limitations.
- Public – These networks are highly scalable and enable global reach. Because they’re open source, developers can build new apps and services on top of them, enabling innovation. The downside is that public chains may come with higher transaction costs (“gas fees”), periods of congestion and less centralized governance.
- Hybrid – This is the middle ground. These networks use public blockchain infrastructure but add permission layers; for example, restricting access to verified participants while still benefiting from the openness and scalability of a public chain. Ekberg likened it to carving out a private pool within the public ocean.
“In the most recent poll I conducted in Europe, the vast majority said they want hybrid solutions because they don’t want to be locked into a private closed network,” said Ekberg. “They want liquidity, but in a way that is controlled.”
If you’re using a stablecoin like USDC, you may have the option to transact on different blockchains (e.g., Ethereum, Polygon, Solana). Each chain offers different trade-offs in terms of cost, speed and interoperability. The network you choose depends on whether your treasury strategy prioritizes control, efficiency or reach. Getting these different “chains” to interoperate to enhance liquidity is a key effort in the industry.
Challenges and barriers to adoption
There are clear hurdles that many corporates face in adopting stablecoins. Some of the most common include:
- Internal knowledge and awareness gaps: Most people don’t understand what it means to use stablecoins. They don’t know if they can be regulated or plugged into their ERP and treasury workstations. Education is key to overcoming this hurdle. “A lot of my corporate and banking clients engage in monthly briefs, rotating accountabilities — legal, treasury and IT — for a shared understanding,” said Ekberg.
- Technology integration: ERP and treasury workstation systems need API connectivity to wallets and exchanges. Working with banks and providers, this hurdle is quite surmountable. In many cases, the technology already exists.
- Liquidity shortages: Liquidity remains a challenge, which is why it can be useful to focus on closed environments where less is required. For example, you might work with select suppliers on a specific use case that avoids the need to move across multiple blockchains or convert into lesser-used currencies.
- Compliance and regulatory uncertainty: To clear the regulation hurdle, focus on jurisdictions with clear rules (U.S., Japan, Singapore, Hong Kong, Dubai), test small pilots with legal and accounting involved early, and work only with trusted, regulated partners. Accounting treatment is still unclear, especially in the U.S., where the FASB has not weighed in, so finance teams need to be engaged from the start.
“Organizations only move as fast as their slowest part,” said Ekberg. “If your board doesn’t understand this [stablecoins], and is reluctant to act, it’s very hard for the corporate treasurer or head of finance to get into it.”
Stablecoin Q&A
How much money movement is happening today through stablecoin? What are the projections for 2026 and beyond?
Ekberg: Last I checked, the market cap was $200-250 billion. Total flows already surpass what you might see on a card network. The big difference is that most stablecoins are used for crypto trading versus real-world use cases with cards, but it’s really driven by the level of investment players are making in the space, given the increasing demand for crypto trading, cross-border payments and similar use cases.
Under the GENIUS ACT, can banks lend stablecoin balances?
Ekberg: Yes. Reserves are ring-fenced and not available for lending.
With multiple existing decentralized blockchain options (Ethereum, Solana, etc.) and new centralized layer-one blockchains in development (Google, Circle, Stripe), how should corporate treasurers evaluate the risks and opportunities of holding stablecoins across these different infrastructures?
Ekberg: Liquidity is a real issue. While in theory you would like to think one stablecoin is equal to one dollar, let’s say, in the recent past, that peg has been broken. This is part of a broader effort to ensure institutional regulation and compliance for systemic stability. Consequently, as you would do with any payment provider, you would need to do your own risk assessment on stablecoins, working with your partners.
Is there any opportunity to use stablecoin for intercompany dividend payments without having to set up an internal infrastructure?
Ekberg: Yes. This is one example use case: using programmability to manage the corporate actions, then triggering funds in USDC to be paid to wallets according to the applied logic. Minimal infrastructure is needed, and this can often be handled through your existing provider, like JPM Coin, or by working with an issuer, such as Circle. There are lots of direct routes to make it happen.
What are the ramifications to middle- and back-office operations as tokenized assets are more widely adopted?
Ekberg: In theory, smart contracts are meant to deliver automation beyond what we have today — things like reconciliations, fee analysis and real-time exposure tracking. From a banking perspective, it’s often said that the technology itself represents only a fraction of the cost of traditional banking infrastructure. For corporates, though, this doesn’t mean your TMS or ERP goes away.
Stablecoin issuers seem to be paying "rewards" as a workaround to the prohibition of paying interest produced by the reserves. How should that element be treated from an accounting perspective?
Ekberg: Last I checked, FASB hasn't come out on some of these points yet, so speaking with an accounting advisor is important. This is likely to come up increasingly — staking is a form of yield, rebates are a form of compensation, etc. My guidance is to speak with the accounting team; get them involved early so they can be most supportive.
How do you get Central Bank approval for stablecoin transactions in countries that are restricted for repatriation?
Ekberg: This is a multi-part question, and one you should speak to your treasury, procurement and legal teams about. It's less clear whether you can use stablecoins in such situations, given the controls, but there are likely some solutions that exist, e.g., onshore funds used as collateral, with a haircut to buy USDC for a cross-border payment. This is also something to discuss with your banker.
In a disrupted market, what happens to the legal structure of custody?
Ekberg: Under regulation, a custodian for digital assets is regulated by the SEC, Fed, etc. There are specialists emerging to support these players, e.g., new types of accountants, services for reserve management. Regulation continues to be an open question of how deep these players will be allowed into the banking system. For now, however, traditional custodians will likely continue to play a key role because we do not want more bank accounts. Ideally, we are working towards digital wallets, so that over time, we have greater flexibility.
Corporates often have many bank accounts across regions or countries (sometimes multiple accounts in a single country), which is complex to manage. That’s why we have middle- and back-office functions. Moving to a wallet structure and DLT could simplify this. DLT allows real-time traceability, so instead of being limited by local bank rails, you could see positions, exposures and locations in real time.
A wallet structure with smart contracts lets you manage multiple currencies and asset classes: A USDC wallet can hold both USD and EUR, enabling easy transfers and payments wherever accepted and reducing the need for 3-4 separate banks. Smart contracts could automate processes like payments and pooling.
If we start thinking about AI, the impact on middle- and back-office operations could be even bigger. Coupled with digital assets like stablecoins and agent-based payments, it could become really interesting, but it will take time to fully develop.
Given the increasing reliance on private entities to operate critical components of the global financial infrastructure, aren't we more vulnerable to systemic reliability (tech-specific) or solvency risk (e.g., should an issuer go bankrupt)? What's your take on addressing such concerns?
Ekberg: Interesting question, and here’s my two cents. Right now, we’re seeing DeFi and TradFi integrating. The DeFi players are getting bigger — Coinbase, but also digital asset treasuries — and that’s also leading some TradFi players to get bigger, think BlackRock, Cantor, Fidelity, etc.
There is a level of risk because the system hasn’t been stressed like the TradFi system. Not long ago, Circle broke its peg during the SVB meltdown. So yes, we need to be cautious about how we approach this — ratings, private vs. public ledgers, counterparties, all of that.
That said, I do think regulation is meant to make this easier. And as I mentioned earlier, lots of Layer 1 efforts are meant to address many of these concerns — institutional grade, privacy, and so on.
How do you see banking relationships evolving as reliance on traditional banks and banking systems decreases?
Ekberg: It is possible in some future state that the role of banks could diminish, but I think that is far off. Crypto needs banking more than banking needs crypto. I suspect the way many people will work with, say stablecoins, will be through their bank: asset manager vs. opening a Coinbase wallet. Both people and companies don't want more cards, more accounts; they want fewer and better. Banks sit at the heart of these wallets, as do many PSPs. I do think there is a risk for banks — the money market moment — where some portion of the population moves 5-10% of their funds from bank accounts to wallets. Even if the banks keep the wallets, the way they make money changes pretty dramatically. But, for the foreseeable future, banks will play a role, though it could be narrower.
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