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Hello and welcome to this week’s Stablescope Weekend Edition.
This week, stablecoins moved forward on two fronts that increasingly define institutional adoption: regulatory classification and settlement infrastructure.
Recap on the two headliners this week:
SS #127 - Treasury Proposes Stablecoin GENIUS Act Rules
SS #128 - Visa Seeks New Stablecoin Settlement Partner
The US Treasury’s proposed GENIUS Act rules begin translating legislation into operational requirements, particularly for foreign issuers seeking access to the US market. Meanwhile, Visa’s search for a new multi-region settlement partner demonstrates that stablecoin adoption is no longer constrained primarily by blockchain technology—it is constrained by licensing, liquidity and regulated market access.
Together, the headlines point to the next phase of the market: stablecoins are becoming regulated payment infrastructure, and the most valuable positions will sit at the junction of issuance, compliance and settlement.
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Treasury’s decision to treat payment stablecoins primarily as payment instruments, rather than forcing them into traditional securities frameworks, provides an important foundation for adoption. However, the commercial impact will depend on the definitions embedded in the final rules—especially what constitutes issuing, offering or selling a stablecoin in the United States.
Foreign issuers face the greatest uncertainty. A framework requiring comparable supervision, technical compliance with lawful orders and reciprocal arrangements could materially change how offshore stablecoins reach US users. This is particularly relevant to Tether, whose international scale has historically operated outside the same framework as US-regulated issuers.
Visa’s partner search reveals the corresponding infrastructure challenge. The company reportedly requires a provider capable of stablecoin conversion and settlement across the US, Canada, the UK and Singapore. That combination of licences, banking relationships, liquidity and technical capability exists among only a limited group of providers.
Our view is that stablecoin competition is moving beyond market capitalisation. The next institutional winners will be determined by regulatory portability, distribution access and the ability to provide compliant settlement across several jurisdictions.
Major Stablecoin Issuers
Mixed
Domestic regulated issuers gain clarity, while foreign issuers may face higher compliance and market-access requirements.
Banks & Financial Institutions
Winner
Clearer payment treatment creates more room for banks to offer custody, reserve, settlement and distribution services.
Regulators
Winner
Treasury gains a clearer supervisory perimeter, although coordination with state and foreign authorities remains complex.
Corporates & Enterprises
Winner
Better-defined rules and Visa-led infrastructure should reduce barriers to using stablecoins for treasury and cross-border payments.
Retail Users & Crypto Natives
Mixed
Greater protection and institutional access may come with tighter controls, geographic restrictions and reduced rewards.
Developers & Protocol Founders
Mixed
Payment applications benefit from clarity, but compliance-by-design becomes increasingly necessary.
Institutional Investors & VCs
Winner
Licensed infrastructure providers become scarcer and more strategically valuable acquisition and investment targets.
Infrastructure & Service Providers
Strong Winner
Providers combining licences, fiat rails, liquidity and multi-stablecoin settlement gain substantial negotiating leverage.
DAOs & Governance Communities
Loser
Permissionless or governance-led stablecoin models may struggle to satisfy issuer accountability and compliance requirements.
Exchanges
Mixed
Regulated venues benefit, while platforms serving US customers may need to restrict non-compliant foreign-issued stablecoins.
Treasury’s proposal addresses more than issuer licensing. It begins defining when stablecoin activity has a sufficient US nexus, when foreign-issued tokens can be offered to US users and what obligations apply to intermediaries distributing them.
The proposed framework is especially consequential for exchanges, wallets and payment providers. Even if these platforms do not issue stablecoins, they may become responsible for determining whether a token is eligible for distribution in the United States. Treasury states that, beginning January 18, 2027, issuing a payment stablecoin in the US will generally require an appropriate licence. Foreign-issued stablecoins will also face conditions relating to lawful-order compliance and reciprocal regulatory arrangements. US Treasury
Visa’s situation illustrates how those regulatory requirements translate into commercial advantage. Stablecoin settlement requires more than an API: the provider must maintain licences, banking access, fiat liquidity, treasury operations and compliance controls across each relevant market.
Following Mastercard’s acquisition of BVNK, Visa is reportedly seeking a replacement capable of operating across the US, Canada, the UK and Singapore. The partner would also support Open USD and multiple stablecoin conversions. CoinDesk
Visa already provides wallet, minting, redemption and transfer capabilities through its Stablecoin Platform, initially supporting OUSD. Yet its new search shows that product infrastructure and regulated settlement coverage remain distinct capabilities. Visa
The long-term implication is a more modular institutional stack:
Issuers provide regulated digital money.
Settlement providers connect stablecoins with local banking systems.
Networks orchestrate acceptance and distribution.
Compliance platforms determine where and how assets can move.
Control over these interfaces—not simply issuance volume—will increasingly determine market power.
Stablecoin adoption is often measured by supply, transaction volume or blockchain activity. For institutions, however, the decisive question is whether a token can be legally issued, held, converted and settled across the markets where their customers operate.
Visa’s search highlights this distinction. The relevant partner is not necessarily the provider with the most advanced blockchain product. It is the provider that can combine licences, liquidity and operational reliability across four strategically important jurisdictions.
Treasury’s proposal reinforces the same point. A stablecoin may circulate globally on a permissionless blockchain, but its institutional distribution can still be controlled through issuers, exchanges, custodians, wallets and regulated service providers.
This means the market is likely to consolidate around two types of platforms:
Large issuers with compliant, widely distributed digital dollars; and
Neutral infrastructure providers capable of supporting several issuers across multiple regulated markets.
The second category may become particularly valuable as banks, card networks and fintechs seek stablecoin capabilities without becoming dependent on a single issuer.
**Foreign-Issuer Treatment:**The final definition of foreign stablecoin eligibility could materially affect Tether, exchanges and international payment providers. Uneven treatment may fragment global liquidity.**Implementation Timing:**The comment process leaves important definitions unresolved ahead of the expected January 18, 2027 effective date, creating a compressed implementation period.**Licensed-Provider Concentration:**Few providers can combine regulatory coverage, banking access and liquidity across several major markets. This creates pricing power, concentration risk and strategic dependency.**Competitive Conflicts:**Mastercard’s acquisition of BVNK shows that infrastructure partners can become strategically unavailable. Networks may respond through acquisitions, exclusivity arrangements or greater vertical integration.**Interoperability and Liquidity:**Open USD introduces a new institutional stablecoin, but its success will depend on redemption access, secondary liquidity and interoperability with USDC, USDT and bank-issued alternatives.**Intermediary Liability:**Exchanges, wallets and payment platforms may bear increasing responsibility for determining which stablecoins can be offered in each jurisdiction, raising compliance costs and delisting risks.
Onigiri Capital (onigiri.vc), a US$50 million blockchain-focused investment fund, launched by Saison Capital, the venture arm of Japan’s Credit Saison. Onigiri Capital is on a mission to chart the next chapter of finance and invest in seed and Series A blockchain startups in stablecoins, payments, RWAs, DeFi and financial infrastructure. The fund’s strategy emphasizes connecting startups to Asia’s growing digital asset markets.
If you’d like to discuss or contribute to the next Institutional Lens, contact us at hi@onigiri.vc
Disclaimer: All the information presented in this publication and its affiliates is strictly for educational purposes only. It should not be construed or taken as financial, legal, investment, or any other form of advice.
