CLARITY Act Fails — GENIUS Holds

This post is not really about the bill, though. It is about the thing the bill was carrying and implications for Stablecoin

As expected, the Digital Asset Market Clarity Act failed to move through the Senate.

Yesterday, the Senate cloture motion on H.R. 3633 fell 49–50 — eleven votes short of the sixty required to advance, and one shy of even a bare majority. Multiple Republicans voted no. Senator Chris Coons did not vote. Senator Cynthia Lummis made the closing pitch on the floor: “Do not let this day be the day we handed our future to someone else because we were too afraid to finish what we started” and could not find the votes. Bitcoin slid from near $80,000; Coinbase closed down almost 9%.

Nobody who was reading the tape should be surprised. I have been writing this outcome down in stages since February. In Stablecoin Rewards’ Last Hope – Clarity Act I put the odds at roughly 70% and named the two things that would sink it: the rewards fight and the calendar. In The CLARITY Act Is Locked I flagged the remaining hurdles: Senate Agriculture jurisdiction, sixty floor votes, House reconciliation, …etc. and wrote that if the floor count fell short the bill slides to the next Congress. Prediction markets took until August to agree, collapsing from 82% to under 20%, and sat at 14% on the morning of the vote itself. Market structure legislation is not a 2026 story and it may not be a 2027 story either.

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Visa Stablecoin Platform

Exec Summary

  • Consumers never wanted stablecoins, they wanted 5% yield or a crypto off ramp, BIS data confirms retail use is under 1% of volume
  • Stablecoins are a settlement innovation, networks did not hijack them, incumbents always adopt new tech to compete
  • Visa’s value is governance, operations, and distribution, VSP is just the next network in the network of networks
  • VSP = single Visa managed environment to mint, burn, move, and manage OUSD, with wallet as a service, passkeys, maker/checker controls
  • OUSD first because compliance and trust win, banks trust banks, not Circle, 63% of corporates want stablecoin access via their bank (EY Parthenon)
  • Use cases anchor on ramps and off ramps, treasury funding, global payouts, merchant settlement, stablecoin linked cards ($7B settlement run rate, 160+ programs)
  • VSP is to stablecoin what Visa DPS is to debit, same playbook, different rails and connection points
  • Visa enables Bank Issuers without picking winners, Mastercard bought BVNK and owns a single roadmap, overlap is real but philosophies differ
  • Enablement models win, every member becomes an investor in the network’s growth
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Mastercard Explores Vocalink Sale

The Financial Times reports that Mastercard is exploring a sale of Vocalink, and is also considering a divestiture of the real-time payments unit it built from its 2019 acquisition of the Nets Group’s account-to-account assets. Taken together with April’s $1.8 billion acquisition of stablecoin infrastructure provider BVNK, this is a clean strategic pivot: Mastercard is walking away from a decade-long attempt to build a services layer on top of bank-owned A2A rails, and redirecting that capital toward digital asset infrastructure. It is the right call. It also raises a question Mastercard should be asking itself very carefully before the BVNK integration gets too far along.

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ZelleUSD — A Private Coin

Builds on: Stablecoins: A New Model of Trust | JPMorgan, Citi and TCH: Tokenized Deposits ON Chain | Open Banking, Open Payments and Trust Networks

Early Warning announced this week that Zelle is going international, starting with India — the world’s largest remittance destination. Alongside this, they unveiled ZelleUSD (ZLUSD), which they’re calling a “proprietary U.S. dollar-backed stablecoin.” Cue the analyst notes about banks “finally getting into stablecoin.”

I’m already laughing… this is Banks BEATING Stableocin and Remittance Providers at their own game with a closed network. This Is Not a competitor to USDC, and you can’t buy it on Coinbase, so Don’t Get Confused.

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Proposed Stablecoin KYC Rule

The Fed/FinCEN and OFAC just revealed their proposed Stablecoin KYC rule and consistent with the GENIUS Act it entails bank-level KYC requirements for Stablecoin Issuers (see blog: No more Stablecoin “rewards”). This combined with the 303-page FinCEN/OFAC rule on transaction monitoring and secondary uses places substantial compliance burdens on Stablecoin issuers. So much that it is said the hottest job in Fintech is in Stablecoin compliance.

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Stablecoin Strategy – Visa and Mastercard Are Taking Very Different Roads

The two dominant card networks are both committed to stablecoins. Both see digital assets as a meaningful component of their long-term growth story. Both have articulated clear strategies to their investors. But the roads they are taking could not be more different and the implications for how value-added services grow, who captures the upside, and how fast innovation moves are significant.

Mastercard is buying the infrastructure. Visa is building a network and enabling shared investment.

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JPMorgan, Citi and TCH: Tokenized Deposits ON Chain

Builds on: 101 Update: CBDCs, Stablecoins and Tokenized Deposits | Stablecoins: A New Model of Trust | Stablecoin Scenarios

The WSJ reported yesterday that JPMorgan, Citigroup, and TCH (a consortium of the largest US banks) are planning a shared tokenized deposit system. For anyone who has been following this space, this is not a surprise. It is a confirmation. I’ve been writing about this trajectory for years. The question was never whether banks would adopt blockchain infrastructure. The question was always how and the commercial construct that governs operation. Now we know. 

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FIncen / OFAC 303 Page Rule Squashes Stablecoin eCom Ambitions

Exec Summary

  • New 303 Page FINCEN/OFAC Rule, aligns to the clear language of the Genius act, but IMHO will create major friction for use of USD stablecoins in eCommerce
  • Rules for tracking parties and monitoring secondary activity create a compliance regime that burdens every party with the need to understand the provenance of a coin. Can you imagine accepting $2000 for a new TV, shipping it out, then having your stablecoins burned?
  • So not only do we have KYC but we have SAR reporting requirements as PPSIs must also comply with SAR and the “Travel Rule” (31 CFR 1010.410(f)), which involves collecting and transmitting information about the originators and beneficiaries of funds transmittal.
  • Banks and Stablecoin Issuers that jumpted into Solana’s Token-2022 model saw this coming and are well placed to move forward
  • This creates substantial advantages for banks in sweeping coins into covered accounts and freshly minting new coins when required. 
  • Great news for Big Banks and V/MA. card gain signficant advantage over stablecoins with the proposed rule
  • I see this as tailwind for stablecoins in settlement, but a big headwind for stablecoin in eCommerce (with a few exceptions). 
  • My views on Stablecoin winners and losers remain unchanged except for an update to winners for x402.
  • No wonder Jamie Dimon remains confident that the banks will win, it will take years for stablecoin startups to build the regulatory muscle required to manage 303 pages of FinCEN mandates. By the time they do, the banks will already be running their own stablecoin subsidiaries under the very same rules.

The Rule

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) and OFAC issued a 303-page proposed rule implementing the GENIUS Act, reclassifying permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act. Requirements include bank-grade KYC, suspicious activity reporting, transaction blocking/freezing capabilities, and appointment of a U.S.-based compliance officer. Enforcement begins January 2027. A 60-day comment period opens now.

The NPRM (Notice of Proposed Rulemaking) introduces 31 CFR Part 1033, which specifically outlines the obligations of PPSIs. The density of this document reflects the complexity of applying traditional banking rules to a distributed ledger environment.

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MPP Phase 2 Live – Ask Tom Goes Agentic

Long blog – First 2 Pages are economic implications, last 6 pages are tech deep dive

MPP is a big deal because value exchange enables specialization and market forces to operate (as discussed in last week’s MPP – Addressing the Internet’s “Original Sin”.MPP and X402 are BIG.. really big. A whole new market. This isn’t about cash replacement or taking share from xx this is about enabling a new Economy. Today’s blog is 4 paragraphs of the economic implications (for investors and CEOs), followed by 4 pages on tech detail covering what I built. Please note “Ask-Tom” is just a model of an x402 service…. of course it won’t generate much demand (service ID is at bottom).

First, let me try to explain why this is such a big deal from an economic perspective. The foundational driver for MPP’s success is the radical reduction of transaction costs through standardized commercial terms. As outlined in my 2016 blog Small Wins, the forces that once drove asset-heavy, integrated organizations are atrophying in favor of “refragmentation” and specialized networks. Historically, the economic cost of inking a bilateral contract for every micro-interaction was prohibitive (ex “Account Creation” bottleneck that stifled agentic autonomy). Following the principles of Ronald Coase’s Transaction Cost Economics, MPP and x402 provide the multilateral governance and common commercial rules necessary to bypass these friction points. By establishing trust and speed through a common interface, these protocols allow for the “Small Win” of a single transaction to scale into a global network effect, where the cost of connection approaches zero.

This standardization enables the “Value Assembly” of “super-specialists” who can target previously unreachable “shale deposits” of niche market demand (see Network Effects and Value Assembly). A successful network enables specialists like “Ask-Tom” to provide high-value, grounded intelligence without the overhead of building independent settlement or reconciliation infrastructure. This is far beyond mere “agentic commerce”; it is an evolution in how software and hardware interact with EVERYTHING ECONOMICALLY. For example, MPP’s session-based economics provides a virtual “bar tab” for agents to execute tasks within human-granted budgets, paying only for precise resource consumption. This creates a sustainable commercial model where the incentives for specialization and market forces to operate on software service at a hyper granular level. Market forces in turn encourage specialists to solve increasingly granular problems across diverse domains, and unlocks the “shale deposits” of data that doesn’t play. I’ll discuss what this could look like next week as a follow up to Value Assembly.

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MPP (and X402) – Solving the Internet’s “Original Sin”

Yes another agentic payment acronym. This one is important enough to remember. Where AP2 and ACP address agents acting on behalf of humans, X402 and MPP are about agents paying agents. My friend Simon Taylor just put together one of his all-time best posts on MPP and The Intention Layer. Today’s blog is a follow-up with a bit more of a comparison, and why this is a big deal from a payment and economic perspective. My key takeaways from Simon’s post

  • The “Skinny Master Account”: Taylor suggests that humans will grant “intent” (a budget and a goal) to an agent. MPP’s Session model perfectly mirrors this: a human “locks” $50 into a session (the intention), and the agent autonomously spends it in sub-cent increments (the execution).
  • The Substrate of AI: Taylor points out that AI thrives on Structured Text (Markdown). Ironically, legacy finance (ISO 8583, NACHA files) is essentially structured text. MPP acts as the “translator” between the agent’s markdown-based intentions and the rigid requirements of the global banking system.
  • The Outcome: The winner won’t be the protocol that is “most decentralized,” but the one that most effectively manages Trust and Permissioning. Stripe and Visa, as the incumbent trust-layers of the internet, are better positioned to solve the “Agentic Spend” problem than a pure-crypto protocol.

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