A Fortune 500 treasurer considering whether to leave $100 million in stablecoins overnight would probably ask a different set of questions than a payments executive deciding whether to use them to settle a transaction.
Who legally owes the company the money? What assets stand behind the token? Where are those reserves held? How quickly can $100 million be redeemed at par during a period of market stress? What happens if the issuer fails, a wallet is compromised or a blockchain becomes congested? And why should the company hold the token at all once the payment is complete?
These questions are now moving closer to the center of stablecoin policy in the United States. The U.S. Treasury Department on Monday (Aug. 17) formally opened proposed rulemaking implementing a key licensing section of the GENIUS Act, advancing the regulatory architecture that will determine which payment stablecoins can be issued and distributed in the U.S.
The immediate subject is regulation. The long-term consequence could be a new decision for corporate treasury. Should regulated stablecoins belong somewhere between a payment rail and a cash management instrument?
See also: Why Stablecoins Are a Money Story, Not a Consumer Story
Businesses Find That Moving Money Is Easier Than Holding It
The PYMNTS Intelligence and Citi report “Chain Reaction: Regulatory Clarity as the Catalyst for Blockchain Adoption” found that regulation will shape blockchain’s next leap. Per the Treasury’s announcement, beginning Jan. 18, 2027, issuers will generally need an appropriate federal or state license to issue payment stablecoins in the U.S.; by July 2028, digital asset service providers will generally be prohibited from offering stablecoins to U.S. customers unless those coins come from licensed issuers.
Stablecoins already have a relatively straightforward enterprise proposition as a rail. A company can convert dollars into tokens, transfer them around the clock and redeem them on the other side, potentially reducing some of the delays and intermediaries involved in conventional cross-border payments.
That does not require a chief financial officer to believe stablecoins are superior places to store liquidity. It only requires the token to be useful during the transaction. Holding stablecoins is different. Treasurers manage corporate liquidity around capital preservation, accessibility, counterparty exposure and return. A token that exists on a blockchain may move faster than a bank deposit, but speed alone does not answer those requirements.
The GENIUS framework as currently designed limits the ability to turn payment stablecoins into conventional interest-bearing investments. For corporate treasurers, that means the economic case may have to come from something other than yield. Stablecoin assets will need to earn their place operationally.
Read also: Stablecoins Have a Money Market Fund Problem
The Corporate Treasurer’s $100 Million Stablecoin Test
Large companies already experiment with blockchain-based payments, and major banks are developing stablecoins, deposit tokens and other forms of tokenized money. But the institutional test for stablecoins will be more demanding than just whether companies use them.
For a treasurer to willingly leave $100 million there overnight, regulation would have to make several uncertainties mundane, including issuer supervision, reserve quality, redemption rights, operational resilience, sanctions compliance and legal treatment during insolvency.
“Today, stablecoins are like a drug trying to treat 20 different problems,” Prajit Nanu, founder and CEO of real-time payments firm Nium, told PYMNTS in July.
“Where we see a significant amount of opportunity is stablecoin not as a payments value, but as a settlement value,” he said. “Where we think stablecoin has the biggest value … is a treasury layer across all the entities, where I can move money instantly among my entities.”
Stablecoin-as-rail asks whether blockchain infrastructure can move corporate money better. Stablecoin-as-asset asks whether the token itself deserves a place on the balance sheet. The GENIUS Act may make the first proposition easier to accept. Whether it can make the second compelling will determine if stablecoins become another payments technology or a genuinely new instrument in the corporate liquidity stack.
At the same time, “Waiting for Certainty: Why Most CFOs Are Holding Back on Crypto and Stablecoins,” the March installment of PYMNTS Intelligence’s 2026 Certainty Project, showed that most middle-market companies remain cautious about digital assets. Usage is limited, with 13% of firms using stablecoins and 5% employing other cryptocurrencies.
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