Key concepts

Six companies can touch one payment (payer, payee, orchestrator, off-ramp, issuer, custodian), and each is checked by someone. On the chain the counterparty is only an address: free to create, anonymous on its face, and one company can have hundreds. The work is mapping addresses to companies: an allowlist that ties each address to a verified owner, and a deposit address or payment request per payer so incoming coins can be matched. Regulators are pushing the same way. In the EU a firm must check who owns a self-hosted wallet above €1,000, with a signed message or a test transfer, and Brazil asks providers to identify the owners of self-hosted wallets they deal with.

Picture a supplier that emails to say its USDC address has changed. Nothing on the chain checks that the new address belongs to the supplier, so the check lives in the payer's change-of-details flow, as it does for bank details: a call to a known contact and a test payment.

Identity also decides which law applies. Under Treasury's August 2026 proposal, a coin is "issued in the US" when the issuer or the recipient is in the US, so the address map also says who counts as American. On bank tokenized-deposit networks every participant is the bank's own client, which makes identity stronger than on a public chain.

A stablecoin payment adds states that ACH doesn't have: broadcast, confirmed at some number of blocks, final, screened, held for review, converted and paid out. Everyone says "paid" at a different moment: the orchestrator when coins leave its wallet, the chain at the confirmation depth the receiver chose, the off-ramp when it starts the payout, the supplier when pesos are usable. On the chain that takes seconds; cash in a bank account comes later.

Then there are legal states: frozen by the issuer, blocked under sanctions, redemption deferred during stress, or stuck in an insolvency. Redemption normally takes up to two business days under the GENIUS Act; in an issuer bankruptcy, law firms expect at least two weeks, because holders must ask the court before reserves are paid out.

Chains stall too. Base, Coinbase's network, halted twice in June 2026, for 116 and 20 minutes, when its single sequencer (the one machine that orders transactions) failed; payments waited and no funds were lost. I'd only show customers a state I can prove, and on many routes the last thing the payer knows for sure is "sent".

A pass-through payment touches four ledgers, and none of them is complete.

The custodian's books can decide who owns the coins. When the crypto lender Celsius failed, a US bankruptcy court ruled in January 2023 that coins in its interest-bearing accounts belonged to the estate, because the terms of use moved title to Celsius; those customers became unsecured creditors. The contract's word on ownership counts for more than the chain.

Accounting follows the model. In a pure pass-through, the payer books accounts payable against cash and a fee, and never records a coin. A company that holds coins books an asset, and whether it's a cash equivalent depends on the FASB proposal's test (see How the rules work); Coinbase has booked USDC and PYUSD as cash equivalents since the end of 2025. Coins in transit need a clearing account until the off-ramp confirms, and some accounting integrations don't support stablecoin transactions yet (Stripe's docs offer a CSV export instead). Tokenized-deposit networks put the bank back as the single book of record, which is much of their appeal.

Public chains have no rulebook like Nacha's for ACH: no return codes, no debit authorization standard, no dispute window. The rules that apply sit in contracts.

• Issuer terms: when the issuer may freeze, who may redeem, and that transfers are final. Circle says it "does not have the ability to reverse or recall any transaction".
• Orchestrator and ramp terms: Bridge's terms for customers outside the US and EU let it freeze funds "without prior notice" and reverse transactions it suspects, and limit its liability to gross negligence, intentional misconduct or fraud.
• Network rules: Circle Payments Network's rules say participants act "at their own risk", and card networks set the rules for banks that settle in coins.
• Chains and banks: a chain's validators set its fees, and for tokenized deposits the bank's account terms apply.

The company's own policy fills the rest. I'd write down which coins, issuers and chains it accepts, how many confirmations count as final on each chain, the screening threshold for inbound addresses, how fast coins are converted, and the most it will hold. The coin list needs dates, because the US rules on permitted issuers start in January 2027 and tighten in July 2028.

Dates I'd keep on a calendar as of October 2026:

Prices move as well: Tron cut its energy price on August 29, 2025, changing what a USDT transfer costs, and Circle's docs say to check its cross-chain fees weekly. I'd store the coin, chain, fees, route and rule version each payment used.

A stablecoin product speaks token standards that differ by chain (ERC-20 on Ethereum, SPL on Solana, TRC-20 on Tron, TIP-20 on Tempo), issuers' APIs such as Circle Mint, Circle's Cross-Chain Transfer Protocol (CCTP), which burns USDC on one chain and mints it on another, and several Travel Rule protocols. ISO 20022 appears only on the bank legs; I found no mapping for coin transfers.

The gap that matters most to a B2B product is the invoice reference. A plain transfer on Ethereum carries an address and an amount and nothing else. Tempo has a 32-byte memo and Stellar and Solana have memo fields, but in practice remittance data travels in the orchestrator's API, an email or a portal.

The other trap is look-alike coins. A coin bridged by a third party is a different asset from the issuer's own coin on that chain, even when the wallet shows the same name; Stripe's docs name a bridged form of USDC on Tempo. I'd accept only the issuer's native token on the chain named in the payment instructions. And no standard exists for telling a holder its coins were frozen: holders find out when a transfer fails.

Any of these can stop or change a payment.

The networks themselves are moving into the stack. Visa and Mastercard both validate on Arc, Visa also on Tempo, and both are founding partners of Open USD, a coin Bridge issues that went live on September 30, 2026.

The counterparty I'd watch most closely is the off-ramp: it holds the local licence and the pesos, and the payer usually never signs anything with it.

A single US-to-Brazil payment can touch the GENIUS Act (the issuer), US anti-money-laundering and sanctions law (the US ramp), MiCA (if it routes through an EU firm), Brazil's FX rules (the Brazilian ramp) and the Travel Rule on both legs.

A company paying or receiving for its own invoices usually needs no licence, because its provider holds them. Holding, converting or paying out for others can make it a money transmitter, and I'd get counsel on each flow. Charters have become a business asset: the OCC conditionally approved five crypto trust charters, Circle's and Paxos's among them, in December 2025, and reportedly one for Bridge in February 2026.

Most exceptions end in someone's discretion rather than a rule.

Issuers freeze on orders and on their own judgment, and they don't freeze on request. When Drift, a crypto trading protocol, was drained in April 2026, about $232 million of the stolen USDC moved from Solana to Ethereum through Circle's own transfer protocol over about six hours, and Circle didn't freeze it. Issuers make mistakes too: on October 15, 2025 Paxos minted 300 trillion PYUSD by error and burned it about 20 minutes later.

Refunds are new payments in the other direction. The design work is in what the chain doesn't handle: an expired quote, an off-ramp that fails after the coins arrive, a frozen inbound payment, a bank-rail fallback when a chain is down.

The contract decides most of it, then statute, then general law. Issuer terms disclaim almost everything: Tether's say holdings "are not segregated assets held in your name or for your benefit", and Circle's say a holder without a Mint account has one remedy, to stop holding USDC. Statute adds the GENIUS Act's priority on reserves for every holder, business or consumer. General law adds UCC Article 12, which lets a good-faith buyer who takes control of a digital asset keep it free of others' claims; 24 states and Washington DC had adopted it by July 2024, and New York signed it in December 2025.

Businesses get no Reg E, whose error rights cover consumers only; the CFPB withdrew its 2025 attempt to stretch them to stablecoins. Who pays for a freeze or a fraud is mostly decided by who holds the coin when it happens.