How Banks Can Prepare to Embrace Payment Stablecoins
Banks that lean into the stablecoin revolution early, integrating compliant digital asset custody and transaction capabilities, will gain distinct competitive advantages.
Brought to you by RSM US LLP

The president signing the GENIUS Act into law last week marked a key step in establishing federal regulations for payment stablecoins, blockchain-based digital assets that hold a one-to-one peg to fiat currencies such as the U.S. dollar. After years of piecemeal movement on a regulatory framework, the new law represents an acceleration toward broader payment stablecoin adoption.
With the legislation enhancing the legitimacy of payment stablecoins, banks should take steps to determine the impact of payment stablecoin-related activities on their current business and how they potentially need to adjust their planning and ready their technology infrastructure. The banks that embrace payment stablecoin and integrate it into existing systems soonest will have a better chance at a competitive edge.
Bank directors should engage with their bank leadership teams about how payment stablecoin adoption will work, key considerations for implementation and what opportunities and challenges may lie ahead.
Payment stablecoins’ U.S. dollar-backed value makes them a natural settlement asset for digital transactions. Until recently, banks and fintechs faced an unclear regulatory environment. Policymakers are now addressing that gap to preserve the dollar’s supremacy on-chain. Much of the early regulatory hesitation reflected the steep learning curve of understanding new and novel risks that accompany these emerging payment rails compared with traditional systems.
Stablecoins such as USDC (Circle) or USDT (Tether) that exist on public blockchains already move trillions of dollars in weekly settlement value, and they do so without the prudential guardrails that protect deposits, money market funds or wire transfer messages.
The stablecoin legislation presents operational readiness implications for bank-regulated entities. Those considering engaging in payment stablecoin-related activities should proactively evaluate their current systems, risk management capabilities and compliance infrastructure. Enhanced reporting requirements, evolving anti-money-laundering obligations and precise redemption obligations will become baseline operational demands. Additionally, payment stablecoin-related activities will require banks to align their operations and risk management, preemptively addressing gaps and leveraging strengths while ensuring robust coordination between management and the board.
Fintech entities that become payment stablecoin issuers will face comprehensive licensing and supervisory scrutiny comparable to, or perhaps in some cases more than, established banking practices. This increased regulatory burden necessitates strategic planning, comprehensive technology investment and proactive regulatory engagement. Banks, meanwhile, will encounter new partnership opportunities alongside heightened competitive threats.
Key Considerations for Banks
Banks will be driven to adoption through regulatory clarity and consumer demand to engage with payment stablecoins. In the rapidly evolving financial services sector, banks may be asked to provide critical fiduciary services to customers and partners that require the integration with blockchain technology in addition to legacy fiat wire and automated clearing house (ACH) payment rails. Payment stablecoins provide significant opportunities for banks to grow deposits, make loans and extend credit.
Similar to internet banking in the early 2000s, organizations that don’t prioritize these types of new and novel capabilities may be at a disadvantage in the future. Here are some key areas of consideration that banks should focus on to prepare for integration and wider use of payment stablecoins:
1. Technology alignment. Core, treasury and settlement platforms will need an on-chain interface that can mint, burn and reconcile tokens in real time while still talking to ACH, FedNow, wires and the general ledger. Proper scoping now avoids a scramble once monthly reserve attestations and real-time redemption metrics become mandatory.
2. Governance and operational controls. The bills graft full Bank Secrecy Act coverage onto issuers, which means upgraded anti-money laundering (AML), liquidity and financial-control frameworks. Boards should refresh charters, define stable-coin risk appetite and decide whether internal audit will perform continuous testing of reserve, wallet-segregation and sanctions-screening routines.
3. Third-party risk management. Few banks keep blockchain engineers or analytics stacks in-house, so vendor or fintech partnerships are likely. Third party risk management teams must add node-hosting, smart-contract and chain-analytics risks to their due-diligence playbooks and negotiate data-access clauses that support examiner requests.
4. Build, buy or partner talent strategy. Decide now whether to hire in-house, license vendor platforms or co-issue with a fintech; each path sets a different timeline for regulatory engagement and supervisory reviews.
5. Regulatory relationship management. Examiner dialogues will expand beyond safety and soundness to include redemption testing, address-screening logic and contingency funding for same-day redemptions. Early engagement with your primary federal regulator — and the state supervisor if you keep a state charter — can clarify expectations and head-off surprises.
Ultimately, the endgame is clear. With the passage of the GENIUS Act, the U.S. has positioned itself to lead decisively in digital finance. Banks that lean into the payment stablecoin revolution early, integrating compliant digital asset custody and transaction capabilities, will gain distinct competitive advantages.