Stablecoins are a new platform

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Hey Fintech Nerds 👋

I was in New York all week for an incredible first-ever Stablecon by Nik and the TWIF folks. The momentum is palpable; the whole week felt like stablecoin week. I was in closed-door meetings with senior bankers, Fortune 500 companies, VCs, and asset managers. You cannot afford to miss next year. Mark it on your calendar now.

I’ll be in Amsterdam for Money 2020 next week. No rest for the wicked. I’m doing various things on stage on the scamdemic, stablecoins and AI. Come say hi?

I haven’t written up the news this week because life is intense enough rn. However, I noticed that Square is accepting Bitcoin at the Bitcoin conference, and the SEC states that staking isn’t a security. What goes up must come down, but secular shifts tend to survive that cycle. Stablecoins are absolutely a secular shift, and platform shift. That’s your rant this week. 📣

Here's this week's Brainfood in summary

📣 Rant: Stablecoins are the new platform

💸 4 Fintech Companies:

1. Nekuda - Makes AI Agents “Checkout Ready”

2. Celery - AI Powered Financial Monitoring

3. Filed - The Tax Prepper AI.

4. GoDutch - The business account for business owners in Europe

👀 Things to Know: I was at Stablecon this week, so I didn’t write up the news. 😇 

📚 Good Reads:

1. Agentic Commerce and the Original Sin of the Internet

2. AI Agents as Adversaries for Fintech Product pen testing

Gmail hates me so click below for the best reading experience Gmail users 👇

Weekly Rant 📣

The Stablecoin Platform Era.

Every fintech company will be a stablecoin company.

While there’s a ton of hype, cynicism, hope, worry, and other emotions stablecoins evoke, I do believe we’ve crossed a Rubicon. From the age of Banking as a Service, to stablecoins as infrastructure. Stablecoin-first companies in B2C, B2B, and infrastructure will shape the next decade. 

This shift will be 10x more dramatic than the fintech boom of the past decade. 

Because we’re heading to a new infrastructure layer. People still see stablecoins as a new payments rail, when they should be seeing it as a layer above all the others, and, eventually, we’ll go fully stablecoin-native. Stablecoins are a platform.

Today’s Rant

• The last era: Banking as a Service and lessons for stablecoins

• Why stablecoins are the infrastructure layer (not just a new rail)

• The stablecoin gold rush and regulatory unlock

• Use cases across the stack

• Strategic positioning, and what's next

1. Lessons from BaaS for Stablecoins

The old saying is that fools rush in.

We just saw this play out in BaaS.

The 2010s era of financial services was characterized by companies adopting mobile-first distribution and cloud-first infrastructure. 

We saw a generation of new infrastructure providers specific to financial services. Every bank department and IT system was now available as an API. Onboarding, Fraud, AML, Cards, in some cases, even customer service. This allowed new companies to launch mobile apps, wallets, and “accounts” that could acquire and service customers at a much lower cost than incumbents.

Combining APIs, mobile, and cloud, the Fintech companies also benefited from a small handful of “sponsor banks” who saw an opportunity to give this new segment access to banking rails, store money, and move money. And some of those banks won big by being “easy to work with.” 

For Fintech companies, their business model was initially:

1. Revenue from card swipe fees (interchange)

2. Reduce customer acquisition costs (CAC) with frictionless, digital onboarding.

You know the saying: Show me the incentive and I’ll show you the outcome?

Some (not all) fintech companies are optimized for conversion, and when you do that, a lot of the norms of financial services look like friction. Things like having people provide pages of documents for “Know Your Customer” checks, or having to monitor transactions for the risk of international terrorism when the vast majority of customers are domestic.

When I wrote BaaS is dead in March 2023, we could see the writing on the wall.

If you’re a bad guy. Attacking the small, Neobanks, and digital banks was low-hanging fruit. 

It did not end well.

When BaaS provider Synapse went bankrupt on April 22nd, 2024, 10s of thousands of customers lost access to their life savings. Fintech apps could not access the funds, and the underlying banks couldn’t trace or reconcile where the funds had gone. 

This flashpoint created headlines in mainstream media, and in the banking industry, regulators issued a blizzard of consent orders, after finding banks had been deficient in things like 

• Third-party risk management (i.e., the API provider and Fintech companies)

• Anti Money Laundering (i.e., those companies' controls may not have aligned)

• Board governance (i.e., Were you holding management to account)

The consequences of these failures are massive.

If you can’t stop money from flowing to bad guys, criminals get paid, they fund human misery.

Yet the lesson here isn’t that BaaS or fintech is bad; far from it.

Today we have

• The ability for immigrants and low-income consumers to open no-fee accounts

• The ability to use cashflow (money you have) to underwrite lending, meaning more people can make it through the week without bankruptcy

• Spend management cards that don’t suck 

• Embedded lending for marketplaces, SMBs, and vertical SaaS

The mega finance brands that made it reshaped the industry. Cash App, Venmo, Chime, Affirm, Revolut, Monzo, Nubank, Stripe, Adyen, and insert your favorite here are household names in their markets and industries. Fintech fundamentally shifted how finance was distributed and raised the bar on user experience. 

We just had to learn some lessons along the way.

The scale of investment and cross-border activity in stablecoins could make any blow-ups biblical in proportion.

Although I know there’s no way to prevent bad things from happening, I do hope those building stablecoin-first can learn from the mistakes of the BaaS era, as well as the successes, and don’t get swept away by the gold rush fever that's coming.

2. The Regulatory Unlock and Funding Explosion

2.1 The Regulatory Unlock

The current draft of the GENIUS Act might change everything. As drafted, if you're a permitted stablecoin issuer, you can treat stablecoins as cash equivalents on your balance sheet. This is a HUGE DEAL.

Take prepaid cards. They require money transmission licensing, escheatment rules, and consumer protection requirements. Cash is like cash in your pocket. It’s much simpler to hold and manage. Stablecoins could inherit this simplicity.

2.2 The Stablecoin gold rush

The amount of funding pouring into stablecoins is set to 10x YoY.

If the GENIUS Act passes, there will be a new, regulated stablecoin rail and a new type of narrow banking category, known as Permitted Payment Stablecoin Issuers (PPSIs).

This means every entrepreneur, VC, payments company, shadow bank, and even big banks will make a play to defend or attack this new opportunity.

3. Thesis: Stablecoins as a platform.

Stablecoins today are used as an alternative cross-border payments rail, and in time, maybe they will become a domestic payments rail. 

But if that’s all you see, you’re missing the big picture. Stablecoins are also a platform above rails like SWIFT, ACH, PIX, and UPI, becoming the infrastructure that connects them all. This unlocks new use cases and opportunities.

I picture it like this:

Here's what platform disruption looks like. Telco traffic grows at +60% YoY. Revenues grow at +1% YoY. Over 15 years, traffic growth outpaces revenues by >1000x. 

The incumbents that don't adapt to the new platform layer get commoditized. 

Stablecoins are doing to payments what the internet did to telecom - creating a platform layer that makes the underlying infrastructure commodity pipes. 

We can see this infrastructure layer emerging across every payment flow and business model. Here's how it's playing out.

4. How Stablecoins work across the stack

Yes, stablecoins work as an alternative payment rail today. But that's table stakes. Most people see it like the picture below instead of as a platform:

The real opportunity is what they enable as infrastructure.

4.1 Stablecoins for International Payments - Where it started

Unquestionably, the primary use case for stablecoins is cross-border payments. The primary currency routes are Singapore ← → China, followed by the USA to LATAM countries (Mexico, Brazil, Argentina). 

There are many types of cross-border payment flows. So lets go a layer deeper into each of the flows.

B2B early adopter use cases:

• Scale-ups doing Market expansion: (e.g.,, SpaceX) Treasury management, supplier payments, and inter-company payments.

• International payroll and payouts: (e.g., Deel, Remote). Contractor and EOR payouts to stablecoin wallets.

Artemis surveyed 30+ companies working in stablecoins and found that B2B, as a category, was growing 400% year-over-year (and accelerating), making it the fastest-growing category. (Note the volumes shown below are a fraction of the overall market)

Today, the last-mile liquidity and FX spread is the bottleneck, but new companies like Stablesea, OpenFX, and Velocity are entering the market to change that.

The cross-border stablecoin use cases for consumers are: 

• Remittances and P2P: (e.g. Sling Money) customers using stablecoins to send money across borders faster and often cheaper.

• Stablecoin-linked cards: AKA “dollar cards” allowing consumers to buy Netflix, ChatGPT, or Amazon from the global south. 

The Artemis survey also showed P2P and stablecoin-linked cards growing over 100% YoY, with at least $1bn of TPV in their sample.

Stablecoins are becoming a feature in Neobanks (like Revolut and Nubank) and while their use cases today are still narrow, we might see that expand in time. Apps like Revolut, in particular, which were initially started in remittance and P2P, feel uniquely placed to take advantage of this new rail.

Today, the FX spreads for transactions in local currency are often quite high, and liquidity is low. But that’s changing.

The domestic picture is still emerging, but fascinating.

4.2 Stablecoins for domestic payments (where it’s going)

Domestic B2B Use cases include:

• Stablecoins for 24/7 yield (e.g. ONDO or BUIDL). Today crypto native treasuries swap stablecoins for tokenized treasuries to avoid off-ramping into fiat. This 24/7 capability could be interesting for any corporate treasurer if it were available in their ERP system. 

• Stablecoins as an alternative to the FBO structure (e.g., Modern Treasury). A quirk of US regulation is that, as a nonbank, to move money on behalf of your customer, you often need a for the benefit of account structure. These can be complex to set up. Modern Treasury’s stablecoin product lets treasury teams set up payment flows on behalf of customers that don’t require the FBO construct. 

• Stablecoin native B2B accounts (e.g., Altitude). The “borderless account” Wise or Airwallex offers businesses can be stablecoin native. They live in USD as their primary currency but get an operating front end to manage invoicing, expenses and treasury.

Domestic consumer use cases are early but include:

• Stablecoin native “checking” accounts (e.g., Fuse). Similar to the consumer experience of Wise, Revolut, or a remittance app, but global by default. These are appearing in global south countries, but could be a new, lower-cost model for consumer fintech programs.

• Prepaid Card programs. Because stablecoins may have cash equivalence, instead of managing prepaid liability complexity, treasurers get programmable money that sits on the balance sheet like cash but moves like digital payments.

• Stablecoins for P2P. Zelle, Venmo, Pix, and Faster Payments all dominate distribution in their home markets, but if stablecoins become another rail, then perhaps these apps would simply support it as a front end.

4.3 Treasury and Infrastructure (The hidden layer)

The hidden layer is infrastructure. Banking technology itself is becoming stablecoin-native.

• Stablecoin issuing-as-a-service (e.g. Brale, M^0). Banks and non banks may want to create their own stablecoin to attract deposits, or to avoid fees from other issuers. 

• Stablecoins as a side-core (e.g. Stablecore). Banks may want to create a system of record that interacts with stablecoins that’s outside their legacy platform. “Side cores” enable you to do that, but reconcile back to the main core.

• Stablecoins could provide a BaaS-like infrastructure (e.g., Squads Grid), offering developers simple APIs to create consumer, B2B, or embedded finance products quickly.

What is massively underestimated by most of the market is how much developers love the simplicity of working with stablecoins. Developer simplicity has been the secret to success for companies like Stripe. 

You can imagine other things too. As a thought experiement, think of stablecoins as a global, programmable system of record that everyone can reconcile and see.

Every wallet address could be assigned to a known front end or wallet creator, and in the event of KYC or AML issues, you could have those companies collaborate instantly. Oh, and guess what, that’s already happening in Crypto (look into IVMS101 and how travel rule works in this context).

4.4 Strategic positioning for stablecoins

The current market has attackers, opportunists, and those still waiting and strategizing. 

Today, the vast majority of activity is happening on new platforms like crypto exchanges and wallets, but opportunists are several companies now positioning to take advantage of stablecoins as a new payments rail: 

Here’s how I’m thinking about which is which:

On offense: 

• Asset managers. Blackrock, Franklink Templeton, and Fidelity (et al) all rely on the banks for settlement of wires. Since the financial crisis, they’ve been able to take market share from banks in credit, and with money market funds. Stablecoins link all of that together with an instant, 24/7 settlement layer.

• Payment companies, such as Stripe, WorldPay, and Dlocal, are expanding the number of markets they can operate in and the types of payment flows they can offer. “Financial accounts” eat into what was the big money center bank's core playbook, but often for a newer segment of customers. 

On defense: 

• Big banks: JP Morgan, Bank of America, Citi, and other US banks were in early talks to launch their own stablecoin. This would, I assume, be an attempt to grab market share of this new domestic and cross-border payment “rail,” perhaps just as the banks dominated P2P (with Zelle), they’ll “inevitably” dominate this new rail too. 

• Smaller banks Have started to lobby against stablecoins. They have the most to lose from stablecoin issuers, asset managers,, and big banks potentially drawing deposits away from their lower-yielding checking accounts. 

There will be a group of opportunistic banks that, like we saw with sponsor banking, get a massive opportunity with the stablecoin disruption.

The reality is that the opportunity varies depending on the use case. Start-up companies are exploring new payment flows, while PSPs are expanding market access with existing flows. In time, asset managers and banks will find their niche in the market, likely closer to their existing core business.

5. The criticisms, worries, and why most are overstated

I’d summarize the criticisms as follows: 

Criticism: Stablecoins will create a run on the bank scenario. Counter: This assumes Terra-style algorithmic stablecoins, not treasury-backed PPSIs under the GENIUS Act.

Criticism: Big tech will create an oligopoly on money. Counter: Valid concern, but the framework makes direct issuance by big tech unlikely - they'll use stablecoins, not issue them. Becoming a PPSI would be a high regulatory barrier for them.

Criticism: It will lead to deposit flight from community banks. Counter: Already happening via money market funds. Community banks that adapt to offer stablecoin services will thrive.

Criticism: “It’s crypto,” which means it's full of crime and scams. Counter: Time to move past this. The future of finance is on-chain, and institutional capital is building the infrastructure. There are real, novel risks. Key management, custody, liquidity, integration, and credit risk. Focus on those.

Criticism: Stablecoins are just regulatory arbitrage because “holding USDC should be as hard as holding USD.” Counter: Fintech itself was regulatory arbitrage via the Durbin amendment. It is easier to develop on stablecoins, but there’s also a full licensing regime. 

I’m sure this debate will rumble on.

Stablecoins will drive the next era of finance, and we’re only scratching the surface of what comes next.

6. Why every company needs a stablecoin strategy

Everything we do today can be made stablecoin-native, and when that happens, finance gets superpowers. We can build instant, global, 24/7 finance. We can remix financial Lego blocks, and it's much more developer-friendly.

The BaaS era taught us that new infrastructure creates massive opportunities and massive risks. The companies that learned from both the successes and failures of that era will be the ones that win in the stablecoin-first era.

Every company needs a stablecoin strategy. Every fintech, every bank, every treasury team. Because this isn't just a new payment rail. It's the platform layer that everything else will be built on.

I implore anyone reading this to build with the lessons of the past.

There will be a blow up, things will go wrong, that much is inevitable. 

And that includes how you’ll protect yourself when things inevitably blow up.

Build cool sh*t.

And stay safe.

ST.

4 Fintech Companies 💸

1. Nekuda - Makes AI Agents “Checkout Ready”

Nekuda safely stores and protects payment credentials that AI Agents can inject at checkout for “human not present” transactions. The Nekuda SDK collects user mandates and securely manages payment credentials, sharing them with merchants, processors and networks. 

🧠 “Human not present” has a nice ring to it. Fraud teams will instantly shudder with memories of “card not present” and of course “card on file.” Human not present and “Agent on file” feel like nice collararies. I’m guessing their SDK sets them up as the Merchant of Record (MOR) for the Agent? They’re a flagship partner for Visa’s Intelligent Commerce (which uses an MOR model) so it would suggest so.

2. Celery - AI Powered Financial Monitoring

Celery watches for mistakes in payroll, or billing before they become costly. With integrations to payroll and accounts payable systems it aims to cut manual reviews by 90+%. It can also spot cost trends in PTO, overtime, and identify unprofitable transactions or customers. 

🧠Their ideal customer profitle isn’t who I expected. They’re going after Healthcare, Logistics, Retail, Construction and Hospitality. Industries where overtime and flexible work patterns are common. The AI-first finops space is quite crowded, but this segment makes me wonder about distribution. They have traction already in the care and healthcare sector, and they’re likely to drive deeper there.

3. Filed - The Tax Prepper AI.

Filed helps accounting firms file returns in less time by automating manual work by extracting structured data from documents, applying to the tax firms logic (e.g. thresholds and tolerances), and then reviews for any anomalies. It connects with industry specific tools like ultra tax, DS Drake, and Pro Series. 

🧠This is the perfect case study for niche industry knowledge + AI = company. Knowing that firms have their own logic to apply, that their goal is to do more returns but can’t scale headcount is one of those perfectly shaped pitches you only get when you have that level of experience. 

4. GoDutch - The business account for business owners in Europe

Godutch is a business account that saves owners and employees time and money (sounds familiar). They open an account with an IBAN and virtual card in 3 hours, offer unlimited cashback and aim to save time for users by automating their admin.

🧠 There’s still a lot of room for EU Fintech solutions in B2B that solve UX and automation. There are established, large companies in this category, but none of them are really great (except maybe Payhawk, and they aim at growth companies more than mainstream freelancers and businesses).

Good Reads 📚

1. Agentic Commerce and the Original Sin of the Internet

The original sin of the internet was we had no native payments infrastructure, so we built ads and subscriptions as the default model. Ben Thompson argues these aren’t bad things. We got an e-commerce flywheel that works, but it breaks when you need AI Agents to be able to pay for tiny fractions of things. Stablecoins are cheap(er), infinitely divisible, and more code-friendly than legacy rails. Ben posits this will build an entirely new marketplace for content.

🧠This is the first time I’ve seen the mainstream tech crowd fully embrace stablecoins. I honestly believe Stripe’s acquisition won hearts and minds for a tech that was (understandably) considered mostly grift (and don’t get me wrong, there’s still plenty of that)

2: AI Agents as Adversaries for Fintech Product pen testing

Every Fintech operator knows, when you get ready to launch a new product or feature, the fraudsters will find a way to attack it, you just don’t know how. In big banks, the fraud team comes up with a list of potential controls through comittees, fintech companies try to manage best practices. But Kunle asks a greate question. What if we had AI Agents that acted as white-hat adversaries?

🐟We’ve been working on something like this at Sardine* with some academics and former criminals. If you want to know more, I’d love to talk to you. 

Tweets of the week 🕊

That's all, folks. 👋

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(1) All content and views expressed here are the authors' personal opinions and do not reflect the views of any of their employers or employees.

(2) All companies or assets mentioned by the author in which the author has a personal and/or financial interest are denoted with a *. None of the above constitutes investment advice, and you should seek independent advice before making any investment decisions.

(3) Any companies mentioned are top of mind and used for illustrative purposes only.

(4) A team of researchers has not rigorously fact-checked this. Please don't take it as gospel—strong opinions weakly held

(5) Citations may be missing, and I’ve done my best to cite, but I will always aim to update and correct the live version where possible. If I cited you and got the referencing wrong, please reach out