Circle, Paxos, Gemini
New York Licensed Stablecoin Issuers
Strong brand recognition positions them well once New York receives state certification from Stablecoin Certification Review Committee. Expedited certification likely for states with pre-existing regimes. Well-positioned to partner with big technology companies, retailers, and financial services firms seeking stablecoin market entry.
JPMorgan Chase, Bank of America, Wells Fargo, Citigroup
Money Center Banks
Significant first-mover advantage through existing regulatory infrastructure. Ability to leverage subsidiary structure for rapid market entry. Access to large-scale payment processing revenue streams.
BlackRock, Vanguard, State Street Global Advisors
Treasury Bill and Reserve Management Firms
Massive opportunity to manage stablecoin reserves invested in Treasury securities. Expertise in short-duration government securities creates competitive advantage. Potential for billions in assets under management from reserve requirements.
Bank of New York Mellon, State Street, Northern Trust
Custody Banks
Mandatory requirement for qualified custodians creates guaranteed demand. Opportunity to capture custody fees on substantial reserve assets. Strategic positioning as infrastructure backbone.
Anchorage Digital, BitGo, Fireblocks
Digital Asset Custodians and Custody Software
Specialized infrastructure for digital asset custody becomes essential. Technical requirements for freeze and block capabilities favor sophisticated providers. Recurring revenue from custody and infrastructure services.
American Express, Capital One
Bank-Integrated Card Networks
Direct banking relationships enable seamless stablecoin integration. Closed-loop networks provide enhanced control over payment flows. Better positioned than standalone networks for compliance requirements.
Meta, Google, Amazon
Big Technology Companies
Partnership opportunities with licensed issuers bypass direct issuance restrictions. Enhanced data collection through stablecoin payment flows. Development of alternative consumer engagement models without regulatory burden.
Fidelity National Information Services, Fiserv, Jack Henry
Legacy Banking Infrastructure
Traditional core banking systems face disruption from blockchain-native solutions. New technical requirements may favor modern infrastructure providers. Risk of disintermediation as banks build direct capabilities.
Visa, Mastercard
Standalone Payment Networks
Stablecoins enable direct bank-to-bank transfers bypassing traditional rails. Reduced transaction fees pressure existing business models. Must adapt to blockchain-based payment infrastructure.
Tether, Binance USD, International Issuers
Foreign Stablecoin Issuers
Must wait for reciprocal regime recognition from Treasury Department. Cannot operate in United States without full registration and compliance. Subject to United States regulatory enforcement regardless of domicile.
Regional Banks, Community Banks
Smaller Financial Institutions
Lack resources to build competitive stablecoin infrastructure. Risk deposit outflows to stablecoin wallets. Cannot match money center banks' scale advantages. May become acquisition targets.
Western Union, MoneyGram, Remitly
Traditional Money Transfer Operators
Stablecoins enable instant, low-cost cross-border transfers. Core remittance business faces direct disruption. Twenty-four hour redemption requirement surpasses traditional settlement times. Regulatory moat eroded by new entrants.
Offshore Crypto Banks
Non-U.S. Digital Asset Banks
United States registration requirements eliminate regulatory arbitrage opportunities. Cannot serve United States customers without full compliance. Business model of serving crypto firms faces disruption from traditional banks entering space.
DAI, Frax, Other Algorithmic Stablecoins
Non-Treasury Backed Stablecoins
Explicitly excluded from regulatory framework as non-payment stablecoins. Cannot compete in regulated United States market. Must maintain offshore operations or restructure entirely.
RELX, NICE, FICO
Regulatory Technology Renaissance
Explosive growth in demand for compliance infrastructure providers. Every issuer requires sophisticated anti-money laundering and transaction monitoring systems. Positioned to capture significant market share from mandatory requirements.
State-Licensed Issuers
Consolidation Wave Approaching
Ten billion dollar threshold creates natural consolidation pressure. State-licensed issuers become attractive acquisition targets. Market structure likely to concentrate around major financial institutions.
Chainalysis, Elliptic, TRM Labs
Infrastructure Investment Cycle
Blockchain analytics companies see dramatic valuation increases. Gain strategic importance from mandatory monitoring requirements. Create sustainable recurring revenue streams from compliance needs.
JPMorgan, Bank of America, Wells Fargo
Traditional Finance Advantage
Regulatory framework favors established financial institutions over crypto-native firms. Existing compliance infrastructure provides competitive moat. Partnership models emerge between traditional and digital finance players.