We’ve launched a new way to turn any invoice into a stablecoin payment link via Notabene Flow.

No integration required. Just upload a PDF invoice, generate a payment link, and let your customer pay with stablecoins — settled instantly to the asset of your choice.

Our new payment link generator can be found at flow.link

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Let's take a look at how it works:

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Notabene Flow is the open stablecoin payment network that authorizes every B2B invoice before it settles and reconciles it as it arrives — across any wallet, network, or jurisdiction.

It’s built on the Notabene network, the largest global network of regulated institutions, and completely open to build on thanks to the Transaction Authorization Protocol (or, TAP) which is an open-source, fully interoperable messaging protocol that allows Notabene customers, and their customers, to reach the counterparties they need to in a scalable, compliant, and trusted way.

Finance teams are going to love the way we’re enabling payments in the stablecoin of your choice, and transforming what used to be a cryptic transaction hash into a fully reconcilable payment record that includes all of the rich metadata and context needed to reconcile your transactions with whatever accounting systems you already use.

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We’d love for you to try it out for yourselves — grab the next invoice that you’re about to send out for payment and and upload it to flow.link and let us know what you think.

And if you’re a payment service provider, wallet provider, custodian, bank, or any platform that facilitates stablecoin payment flows, we’re able to bring the power of Notabene Flow directly to where your customers already live with a direct integration on your platform.

You can get in touch with our team at [email protected] or learn more and sign up to join the network at notabene.id/flow

On 11 June, Notabene hosted a panel of leading policy and compliance experts to take stock of MiCA's implementation journey and look ahead to what comes next. Here's what we heard.

The EU's crypto regulatory experiment has entered its final chapter. On 1 July 2026, MiCA's transitional period ends across all member states. From that date, crypto asset service providers operating in the EU must operate under full MiCA authorization — no exceptions.

At the same time, the European Commission has opened a targeted consultation asking a pointed question: is MiCA, as written today, still fit for purpose? The consultation covers stablecoins, DeFi, offshore CASPs, tokenization, and the relationship between MiCA and broader EU financial regulation — opening the door to MiCA 2.0, even before MiCA 1.0 has been fully implemented.

To make sense of this pivotal moment, Notabene's Director of Regulatory & Compliance, Catarina Veloso, ‍hosted a panel of senior experts from Bitpanda, VASPnet, Chainalysis, and Fireblocks for an honest assessment of where we are and where we're going.

What MiCA Got Right

The panel kicked off on a positive note. Acknowledging that despite implementation friction, the framework itself has delivered something meaningful: a harmonized regulatory perimeter that replaced a fragmented patchwork of national regimes.

Neil Samtani, CEO of VASPnet, put it directly: before MiCA, firms operated across 27 different national registers, with wildly uneven supervisory maturity — "silver and gold plating" practices that prevented a level playing field . MiCA replaced that with a single standard, a clear route to market, and genuine access to the EU single market via passporting.

"Today we have a mature, harmonized regulatory perimeter that's been drawn out — and that's especially valuable when you compare it to what things looked like pre-MiCA. There is a clearer route to market, and especially access to the single market, which is so important." — Neil Samtani CEO, VASPnet

Michał Truszczyński from Bitpanda made the operational stakes concrete: before MiCA, Bitpanda held 17 separate licenses and registrations across EU member states. One MiCA license now replaces that entire stack.

Matthias Bauer-Langgartner from Chainalysis highlighted a less-discussed benefit: MiCA has forced traditional financial services firms to engage seriously with crypto for the first time. He sees banks, MiFID firms, and EMIs now exploring stablecoin arrangements, custody, and trading platforms — participation that simply didn't exist before the regulatory legitimacy MiCA provided. Beyond its impact on market participation within Europe, Bauer-Langgartner also emphasized MiCA's growing role as a reference point for crypto regulation globally.

"MiCA has provided a global standard that is the baseline of discussions for other jurisdictions — which is extremely important, particularly around crypto assets, which are inherently global. It's not only a common standard for Europe, it actually sets the baseline for the international community, particularly the US and other jurisdictions now." — Matthias Bauer-Langgartner Head of Policy Europe, Chainalysis

Dea Markova from Fireblocks pointed to evidence of this institutional adoption in the licensing data. In some EU markets, roughly half of all CASP and issuance licenses have gone to banks or bank-affiliated entities, underscoring how traditional financial institutions are embracing the opportunities created by MiCA. Markova also observed that MiCA has attracted significant non-European players who are choosing Europe precisely because of the regulatory certainty it provides. Large global crypto firms are increasingly selecting EU member states as their MiCA domicile — a vote of confidence in the framework despite the compliance burden.

The Numbers Behind the Transition

Drawing on VASPnet's tracking of crypto businesses' regulatory footprints across Europe, Neil painted a striking picture of consolidation. Pre-MiCA, there were approximately 3,500 active VASP registrations EU-wide. Today, 1,700 transitional registrations remain active across member states still inside the grandfathering window — and just over 220 full MiCA licenses have been issued. His projection: roughly 400 CASPs will hold MiCA licenses once the dust settles.

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But Neil stressed that this should not be viewed simply as a shrinking market. While some businesses exited the market amid more challenging regulatory and commercial conditions, much of the reduction reflects regulatory consolidation enabled by passporting: firms that previously maintained multiple registrations across Europe can now serve the entire EU under a single MiCA license. The numbers have also been shaped by M&A activity, as larger firms acquire smaller operators.

With around 60% of CASP authorizations concentrated in just five jurisdictions — Germany, the Netherlands, France, Malta, and Cyprus — some observers have questioned whether MiCA is encouraging regulatory arbitrage or a race among member states to attract crypto firms. Matthias pushed back on any reading of this as a regulatory race to the bottom. The concentration in Germany, the Netherlands, France, Malta, and Cyprus — roughly 60% of CASP authorizations — is, in his view, a direct product of pre-MiCA history. Germany required banking licenses for crypto custody before MiCA existed; France ran a full DASP regime. Firms that were already operating inside a proper prudential framework had a materially easier path to MiCA authorization than firms accustomed to AML-only registration. The licensing map, in other words, largely reflects where regulatory infrastructure was already built. He also drew an important distinction between where firms are licensed and where crypto activity actually takes place.. Spain and Italy — countries with far fewer licensees — rank alongside the Netherlands in the top five for on-chain transactional inflows.

That gap is passporting working as intended, but it is also, as Matthias put it, precisely why supervisory convergence across member states matters. A firm can be domiciled in one jurisdiction and serve customers across the bloc. If the NCA in that jurisdiction is under-resourced or slower to act, the entire EU's consumer base carries the risk.

The Offshore CASP Problem

With full MiCA supervision beginning, one of the most urgent enforcement questions becomes: what happens to crypto firms that are not authorized and continue to serve EU customers?

Neil walked through research VASPnet conducted on the top 78 centralized exchanges:

• 8 held a MiCA license
• 20 were operating under at least one legacy member state registration
• 50 had no EU regulatory presence — but their terms of service didn't restrict European business

That last figure is the enforcement challenge. MiCA's reverse solicitation provisions are tight — Michał noted that even making a product available in EU app stores, in EU languages, or at EU-targeted conferences could constitute solicitation. But enforcement requires NCA capacity that varies significantly across member states.

Neil's read on Article 19B of the Transfer of Funds Regulation is particularly significant in this context: if an EU-licensed CASP is transferring value to an offshore firm, that relationship carries correspondent-level due diligence obligations. In other words, the Travel Rule isn't just a compliance checkbox — it's becoming a mechanism to map and contain the offshore CASP problem from within the authorized perimeter.

The MiCA Review: Fine-Tuning or Major Overhaul?

Here the panel's views were nuanced — and the audience's poll result was revealing.

When asked whether MiCA 2 is on the horizon, a clear majority of the audience expected a legislative follow-on.

Michał's reaction: Bitpanda would vote no on a major MiCA 2.0 overhaul.

"MiCA itself has 150 pages. The 47 implementing acts beneath it run to 2,000–3,000 pages. Add TFR and DORA, and you're looking at 5,000 to 10,000 pages of compliance reading in an industry that moves at pace. The ask from industry isn't a new framework — it's simplification and supervisory convergence."— Michał Truszczyński Senior Specialist Public Affairs, Bitpanda

The panel broadly agreed that the priority should be fine-tuning at levels 2 and 3. There are 47 implementing acts beneath MiCA's level 1 text — and beyond MiCA, firms must also contend with TFR and DORA running in parallel. The ask from industry isn't a new framework — it's simplification, coherence, and supervisory convergence across member states.

With firms and regulators still adapting to MiCA, launching a new legislative process too soon could create uncertainty, divert resources from implementation, and risk disrupting a framework that is only beginning to deliver the benefits of regulatory harmonization. The consensus was that Europe should focus first on making MiCA 1 work as intended before considering a more ambitious second phase of reform.

The Stablecoin Question

Euro-denominated stablecoins were a key discussion topic for the panel — and to ground the conversation in live audience sentiment, we put a question drawn directly from the Commission's consultation to the room:

The results didn't go unchallenged. Dea pushed back on the skeptical reading. While acknowledging that domestic payments within the Eurozone don't have much friction, with SEPA and instant payments regulation having done significant work,  the case for euro stablecoins, she argued, is strongest elsewhere: cross-border and programmable payment contexts, intraday yield, AI-native payment flows, and tokenized money market fund access all become meaningfully easier with a euro-denominated on-chain asset.

By creating efficient, regulated payment rails between Europe and key international corridors, euro stablecoins could allow more value to move directly in euros rather than requiring conversion into dollars or local currencies at multiple points in a transaction. In that sense, stablecoins could strengthen the international role of the euro by embedding it more deeply into digital payment infrastructure.

Matthias agreed with the direction but noted the scale reality: less than 0.5% of on-chain crypto activity is currently denominated in euros. The deepest, most liquid pools remain dollar-denominated.  The opportunity for euro stablecoins is real, but demand and liquidity still have a long way to go before they can rival the dollar's dominance.

The Multi-Issuance Debate

Closely related is the multi-issuance question: can the same stablecoin be issued through separate legal entities in different jurisdictions, and how does that interact with MiCA's reserve, redemption, and supervision requirements?

Matthias framed the multi-issuance debate as one of MiCA's most difficult unresolved questions: how to preserve the global utility and fungibility of stablecoins while maintaining European supervisory standards and consumer protections. He noted that stablecoins are inherently global instruments, with cross-border payments among their clearest use cases, yet MiCA must also account for concerns around monetary sovereignty, reserve location, and redemption rights for EU holders. Splitting a stablecoin into separate EU and non-EU versions may look attractive from a supervisory perspective, but in practice it risks fragmenting liquidity, duplicating smart contract infrastructure, and making the token less useful across both DeFi and centralized markets. For Matthias, the challenge is supervising global stablecoins without undermining the very cross-border functionality that makes them valuable. Enhanced supervisory cooperation, such as the recent EBA–NYDFS memorandum of understanding, may be an important step toward that balance, but the path to globally usable, well-supervised stablecoins remains complex.

What Comes Next

Two important milestones now sit directly ahead of the industry. On July 1, MiCA's grandfathering period comes to an end across the EU, closing the transition window that allowed firms to continue operating under pre-MiCA national registrations. At the same time, the European Commission's consultation on the future evolution of MiCA remains open until 31 August, inviting industry feedback on everything from stablecoins and global issuance models to DeFi, staking, and tokenized deposits.

As Michał explained, the expiry of the grandfathering period should bring the market closer to a true level playing field. Firms operating in the EU are expected to be authorized under MiCA, reducing the inconsistencies that existed under the previous patchwork of national regimes.

The next test is supervision. Michał emphasized that tighter enforcement will be essential, but also acknowledged that this remains new territory for national competent authorities. NCAs differ in resources, risk appetite, and supervisory focus, and the interaction between home and host member states — and with ESMA — will become increasingly important.

The consultation raises a different but connected question: how much MiCA should now evolve. Dea's view is  MiCA should be improved, not reinvented. The first draft was written roughly six years ago, in response to a very different market environment. Since then, particularly in payments, use cases for stablecoins have become far more concrete. For Dea, that makes the consultation a timely opportunity to be somewhat bolder in revisiting the payments titles, while preserving MiCA's broader architecture.

The panel's message was consistent: the priority is to make MiCA work in practice, while using the consultation to identify targeted improvements where experience has exposed genuine gaps.

Watch the full webinar on demand →  https://notabene.id/webinars/from-transition-to-transformation-mica-grandfathering-ends

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Meet Alex, VP of Finance at Notabene.

Every month, a customer asks Alex the same question: "Can we pay you in stablecoins?" And every month, Alex understands exactly why they're asking. Stablecoins are faster than a wire, cheaper than a card, and they don't care that it's a Saturday or a bank holiday in another timezone. For a finance team trying to close the books and keep cash moving, that's genuinely appealing.

For a long time, though, Alex's honest answer was closer to "yes, but."

The "but" wasn't for lack of interest, but rather an operational hurdle. When a stablecoin payment landed, it arrived as a transaction hash. No business name, no invoice number, nothing tying the money to the customer who sent it. Before any of it could touch the books, someone on Alex's team had to play detective: whose payment is this, which invoice does it close, is the amount even right? Multiply that across a month of payments and you've turned a faster rail into slower accounting.

Then there was the chain problem. One customer wanted to pay USDC on Base. Another only held funds on Ethereum. A third was set up on Solana. Each one kicked off the same tedious negotiation about which network everyone could live with, a back-and-forth that ate hours nobody wanted to spend when there was real work waiting.

So the friction was never the stablecoins themselves. It was that the payment systems around them hadn't been built for the way a finance team actually operates.

Notabene CEO Pelle Braendgaard and Sam Broner (Founder and CEO of The Better Money Company) explain on an episode of Stack Chats:

‍"You talk to the accounting guy and they're like, wait, so you're saying I can finally bill someone seven hundred and eighty-nine dollars and eighty-seven cents? Thank you, that is exactly what I needed."

(Watch the full episode of Stack Chats with Pelle and Sam)

What changed

Notabene Flow was built for Alex's side of the table. It's the payment network that authorizes every B2B invoice before it settles and reconciles it as it arrives. The invoice reference, the counterparty's verified identity, and the payment context travel with the money, so finance teams reconcile as they receive instead of investigating after the fact. The transaction hash stops being a mystery to solve.

Alex also gets to set the rules. Flow lets him specify exactly which stablecoins and which chains he's willing to accept, the way he'd set any other treasury policy. His customer sends a payment link, pays through their own provider, and Alex receives a clean, reconciliation-ready record on the other end. No chasing references. No crypto expertise required on either side.‍

"How does plumbing work? You just turn the sink on, but there's 200 years of infrastructure under these streets... the simple thing is you get to flip the tap."

(See how you can turn any invoice into a stablecoin payment link with Notabene Flow)

The part that makes the answer a clean "yes"

There was still one gap: what happens when Alex wants to settle in his preferred stablecoin, but the customer holds a different one? That's where our partnership with The Better Money Company comes in.

Better Money runs a stablecoin clearinghouse. Instead of trading one stablecoin for another on the open market and eating the slippage, it clears at par, going directly to the issuers the way banks settle between themselves. Integrated into Flow, it means the payer can send whatever stablecoin they hold, on whatever chain, and Alex receives exactly what he asked for, in his preferred stablecoin, down to the cent.

For Alex, all of that machinery disappears. The question comes in, and the answer is just "yes."

Interested in giving your finance team the same convenience that Alex now has? Schedule a quick conversation and we'll show you all you need to know to get started with Notabene Flow.

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In a recent appearance on Utila's podcast, Notabene CEO Pelle Brændgaard made a point that runs against one of crypto's founding assumptions: that once a transaction settles, there is nothing anyone can do about it.

He explained why that assumption is starting to give way, and what opens up when regulated institutions can actually communicate with one another.

"For a lot of different fraud use cases, having a messaging system between trusted institutions allows you to do things that the crypto industry thought was impossible." — Pelle Brændgaard, CEO, Notabene

The missing response to fraud and error

Every payments system has to deal with fraud, theft, and honest mistakes.

Traditional finance built its answers over decades: returns, recalls, and coordinated processes between banks that trust each other enough to make them work. Crypto inherited none of that.

The moment funds land in the wrong place, whether because of a scam, a compromised account, or a payment sent in error, the sending side has had little real recourse. Recovery has often meant an email, a message to whoever might be on the other end, and hope that the counterparty cooperates.

That does not scale. And when it matters most, it leaves institutions without a consistent workflow or audit trail.

A trust layer changes the equation

The shift Pelle describes is not a change to how blockchains work. Settlement stays final, exactly as it was designed to be.

What changes is the layer above it.

When two regulated institutions speak a common language, they can do more than watch a transaction move one way. Either side of a transaction can request a return, attach the reason, and coordinate the return to a wallet address that has been verified before any funds move.

This is where the industry conversation needs to move beyond finality alone. Final settlement is important, but it is not the same as a complete payments operating model. If digital assets are going to support mainstream financial activity, institutions need the ability to manage exceptions, document decisions, and coordinate with counterparties when a transaction is technically complete but operationally unresolved.

That is the practical problem Revert  is designed to address: giving institutions a way to coordinate after settlement, for the fraud and error cases where both sides of the transaction are trusted parties in a shared network.

It is a response to the the unilateral transaction problem that has defined crypto since the beginning. Not by undoing settlement on-chain, but by creating a trusted communication layer around it.

Built for the real world

Revert is not a magic recovery tool for funds that have already left the regulated perimeter. It works for fraud and error cases that move between institutions who have chosen to participate in a shared network.

And that participation is the whole point.

These flows work because the parties involved are regulated, want to be trusted, and have an interest in being trustworthy. Trust is not a nice-to-have layered on top of the technology. It is the mechanism that makes coordinated recovery possible at all.

As crypto matures into infrastructure that businesses depend on, the constructs that traditional payments take for granted are finally arriving. Not by changing the chain, but by building coordination on top of it.

Crypto settlement can stay final. But finality does not have to mean silence.

Learn more about Notabene Revert

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Stack Chats Episode 4: Making Stablecoins Work Like Money with Sam Broner

Guest: Sam Broner, Founder & CEO, Better Money Company

Host: Pelle Braendgaard, CEO & Co-Founder, Notabene

Topics: Stablecoins, Payments Infrastructure, Stablecoin Clearing, Digital Money, Compliance, Interoperability

In this episode of Stack Chats, Notabene CEO Pelle Braendgaard sits down with Sam Broner, Founder and CEO of Better Money Company and former Andreessen Horowitz investor, to discuss stablecoin clearing, payment interoperability, and the infrastructure required to make stablecoins work at global scale.

Sam shares lessons from his career spanning Microsoft, MIT, the Boston Fed, and venture investing, and explains why the next phase of stablecoin adoption depends less on trading infrastructure and more on payment infrastructure.

Watch the full episode below:

Watch on YouTube →

Stablecoins are already faster, cheaper, and more global than traditional payment systems. Yet businesses still face operational challenges when using them for invoicing, treasury management, and cross-border payments. Pelle and Sam explore how Better Money Company is building the clearing infrastructure needed to make stablecoins behave more like traditional money while preserving the benefits of blockchain-based settlement.

📌 Topics include:

• Why stablecoins need clearing, not trading
• The hidden accounting challenges of stablecoin payments
• Stablecoin interoperability across chains and issuers
• Building payment-grade infrastructure for businesses
• The future of global stablecoin clearing networks

Pelle and Sam begin by discussing Sam's path from distributed systems engineering to stablecoin infrastructure. Their conversation quickly turns to one of the industry's biggest bottlenecks: businesses need certainty, predictability, and reconciliation tools before they can fully adopt stablecoin payments.

What follows is a look at the key themes they explored and why they matter for the future of financial infrastructure.

Key Takeaways

• Stablecoins have solved many money movement challenges but still lack payment-grade clearing infrastructure.
• Businesses require exact settlement amounts for accounting and reconciliation.
• Stablecoin interoperability is becoming increasingly important as more issuers and networks emerge.
• Clearing infrastructure can simplify payments while preserving compliance requirements.
• Better Money Company and Notabene are working to reduce friction in stablecoin payment workflows.

Stablecoins are better money, but payments are still too complicated

One of Sam's core arguments is simple: stablecoins have already solved many of the problems associated with moving money.

They are:

• Faster than traditional payment rails
• Available globally
• Programmable
• Available 24/7
• Lower cost than many existing systems

Yet despite these advantages, businesses still struggle to use stablecoins as a payment mechanism.

The reason is that moving between stablecoins often requires trading rather than payment processing.

Today, if a business wants to receive a specific stablecoin on a specific chain, the sender may need to swap assets through an exchange, liquidity provider, or trading venue. While this works for crypto-native users, it introduces unnecessary complexity for finance teams and payment operations.

As Sam explains, people do not exchange Wells Fargo dollars for Bank of America dollars before making a payment. The financial system already provides clearing infrastructure that abstracts away those differences.

Stablecoins need the same capability.

The missing layer: stablecoin clearing

Better Money Company's core product is a stablecoin clearinghouse.

Rather than forcing businesses to manage multiple chains, stablecoins, and liquidity venues, the clearinghouse allows participants to send one supported stablecoin and have the recipient receive exactly what they requested.

This creates a payment experience rather than a trading experience.

The model introduces several benefits:

• Predictable settlement
• Fixed-fee transactions
• Simplified reconciliation
• Reduced operational complexity
• Greater flexibility for senders and recipients

Instead of worrying about how funds move between assets behind the scenes, businesses can focus on the payment itself.

For finance teams, this distinction is critical.

Why finance teams care about exact amounts

One of the most practical parts of the conversation focuses on accounting and reconciliation.

Crypto-native users often focus on liquidity, swaps, and settlement speed. Finance teams care about something different: receiving the exact amount expected.

For invoicing, treasury operations, and accounting workflows, "close enough" is not good enough.

A business invoicing $789.87 needs to receive exactly $789.87.

Small variations caused by slippage, trading spreads, or liquidity fragmentation create operational headaches for finance teams that must reconcile every transaction.

This is where stablecoin clearing becomes particularly valuable.

By guaranteeing that recipients receive the exact amount specified, businesses can integrate stablecoin payments into existing accounting workflows without introducing additional reconciliation burdens.

Building the bridge between crypto and traditional finance

Sam's experience spans several worlds.

Before founding Better Money Company, he worked:

• As a distributed systems engineer at Microsoft
• On digital money research initiatives connected to the Boston Fed
• As an investor at Andreessen Horowitz focused on payments and stablecoins

Those experiences helped him identify a recurring challenge.

Crypto infrastructure often optimizes for traders, while financial institutions need systems optimized for payments, controls, and operational certainty.

The gap between those two worlds remains one of the biggest barriers to institutional adoption.

Rather than replacing existing financial processes, Better Money Company focuses on providing the payment guarantees businesses already expect.

Stablecoin interoperability will drive adoption

Another major theme is interoperability.

The stablecoin ecosystem is becoming increasingly fragmented.

New issuers, chains, and payment networks continue to emerge. While this innovation is healthy, it also creates complexity for businesses trying to accept payments.

Companies do not want to support dozens of different payment paths individually.

Instead, they want a simple way to:

• Send the stablecoin they hold
• Receive the stablecoin they prefer
• Maintain compliance requirements
• Reduce operational overhead

Sam argues that clearing infrastructure can serve as the connective tissue that enables this interoperability without requiring every participant to manage countless integrations.

Why compliance still matters

Throughout the discussion, both Pelle and Sam emphasize that stablecoin adoption requires trust.

Businesses need confidence that incoming funds originate from compliant sources and that payment flows meet regulatory expectations.

This is one reason the integration between Notabene Flow and Better Money Company is significant.

By combining:

• Better Money Company's stablecoin clearing infrastructure
• Notabene Flow's compliance and payment orchestration capabilities

businesses gain a payment experience that is both operationally simple and compliance-ready.

For regulated businesses, both pieces are necessary.

Bringing stablecoin clearing into Notabene Flow

Toward the end of the conversation, Pelle and Sam discuss the upcoming integration between Better Money Company and Notabene Flow.

The goal is straightforward:

A business can issue an invoice requesting payment in a specific stablecoin, while the payer can send a different supported stablecoin.

For example:

• An invoice requests RLUSD
• The payer holds USDC or USDG
• Better Money Company's clearing infrastructure handles the conversion and settlement
• The recipient receives the exact asset and amount requested

This reduces friction for both sides while preserving accurate reconciliation and compliance workflows.

The result is a simpler stablecoin payment experience that feels more like traditional financial infrastructure.

What comes next

As stablecoin adoption accelerates, infrastructure providers are increasingly focused on making digital asset payments easier to use rather than simply faster to settle.

The next phase of growth will depend on solving practical business challenges:

• Reconciliation
• Accounting
• Interoperability
• Compliance
• Operational efficiency

Sam believes stablecoins have already won on technology.

The next challenge is making them work seamlessly within the systems businesses already use every day.

If successful, stablecoin clearing could become one of the foundational layers that enables broader adoption across payments, treasury, fintech, and global commerce.

Episode breakdown

Here is a quick minute-by-minute guide to the conversation:

00:00 - 04:00

Sam's background from Microsoft and MIT to Andreessen Horowitz and the founding of Better Money Company.

04:00 - 08:00

Why stablecoins are already better money and the limitations of today's payment infrastructure.

08:00 - 13:00

The difference between trading and clearing and why payment flows need a new model.

13:00 - 18:00

Accounting, reconciliation, and the operational challenges businesses face when using stablecoins.

18:00 - 24:00

Interoperability across stablecoins, chains, and payment networks.

24:00 - 30:00

Building payment-grade infrastructure for financial institutions and enterprises.

30:00 - End

The Better Money Company and Notabene Flow integration and the future of stablecoin payments.

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🎙️ Stack Chats is Notabene's video series for product leaders, fintech builders, and infrastructure innovators shaping the next generation of blockchain-based payments.

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For the first time in OFAC's history, U.S. regulators are codifying an explicit sanctions compliance program requirement in regulation. For the first time, FinCEN is treating stablecoin issuers as a distinct financial institution category under the Bank Secrecy Act rather than as money services businesses with a crypto wrapper.

The joint proposed rule FinCEN and OFAC issued in April implementing the Permitted Payment Stablecoin Issuer (PPSI) framework under the GENIUS Act is the most consequential digital asset rulemaking the U.S. has embarked on in a decade.

Notabene filed our response to the notice of proposed rulemaking (NPRM), answering eleven substantive questions across the AML/CFT and sanctions program sections.

Three positions anchor what we filed, and the choices regulators make in finalizing this rule will shape the next decade of stablecoin payments.

Travel Rule codification has to be designed for cross-border use

The Travel Rule already applies to stablecoin transfers under existing 31 CFR 1010.410(e) and (f), as FinCEN's 2019 guidance made clear. Codifying it in a dedicated Part 1033 for PPSIs removes the ambiguity slowing U.S. implementation and gives institutions a clean foundation to build compliance programs on.

The codification has to be designed for international interoperability from day one. We recommended FinCEN endorse IVMS 101 as the data standard for transmittal-level identifying information, and require the messaging layer carrying it to operate on open and interoperable standards.

Read more about our commitment to open standards here

We also asked FinCEN to align the U.S. threshold with the FATF Recommendation 16 as Travel Rule compliance is collaborative by design. One institution's ability to comply depends on its counterparty's ability to receive and process the data, and the U.S. threshold of $3,000 is now the highest among peer jurisdictions with active enforcement. The EU and UK, for example, enforce at zero threshold.

Threshold and data-set divergence is not abstract and it causes operational headaches. When a U.S. institution sends a stablecoin transfer to an EU counterparty with only the U.S. data set, the receiving EU CASP is required by the EU Transfer of Funds Regulation and the EBA Travel Rule Guidelines to detect the missing fields and decide whether to execute, request the missing data, reject, return, or suspend the transfer. When the EU CASP requests missing data from a non-EU sender, the EBA Guidelines give the sender a five working day window to supply it. The transfer is treated as suspended in the meantime. Repeated sub-standard transmissions can show up as a counterparty-risk flag on the EU side and trigger reporting to the EU CASP's competent authority under Article 17 of the TFR.

The result is that U.S. PPSIs and their global counterparties end up at a disadvantage relative to actors operating outside regulated channels, where no such friction applies. Threshold and data-set alignment with the FATF Recommendation 16 trajectory is what closes that gap.

Block, freeze, and reject only work before settlement

Public blockchains have no built-in mechanism for evaluating a transaction before settlement. Once a transfer is initiated on-chain, it settles. A PPSI without pre-transaction authorization infrastructure is limited to reactive measures, freezing assets after they arrive rather than preventing transfers from occurring.

The GENIUS Act's block, freeze, and reject obligations under proposed 31 CFR 502.201(b)(3) are therefore architectural requirements, not just programmatic ones. Pre-transaction authorization is the mechanism that meets them.

Authorization-before-settlement models work through a private messaging layer operating alongside the blockchain. The two institutions party to a transfer exchange Travel Rule data, perform sanctions screening, assess counterparty risk, and make an explicit authorize-or-reject decision before on-chain settlement. The Transaction Authorization Protocol (TAP) is one open standard implementation of this approach.

We asked OFAC to recognize pre-transaction authorization architectures as a compliant technical implementation, without mandating any specific protocol.

The recognition matters because pre-transaction authorization pairs with, rather than replaces, the freeze, burn, and reissue capabilities GENIUS Act Section 5(a)(2) grounds. Proactive authorization at the transaction level and reactive freeze at the asset level form a complete sanctions architecture no traditional financial institution has access to.

The primary and secondary market distinction is operationally correct

FinCEN's proposed framework draws a clean line between activity where the PPSI is a direct party (primary market, where full programmatic obligations apply) and activity where the PPSI is observing smart contract operation as an issuer rather than as a transacting party (secondary market, where contract-layer interventions are narrowly scoped). We agree with how the line is drawn and think the rule should preserve it.

Any secondary market intervention authority outside lawful orders should be narrow, explicit, tied to defined triggers, and paired with an express liability safe harbor. Institutions holding the customer relationship and the Travel Rule channel are best positioned to enforce sanctions and AML controls in secondary market activity. The PPSI is best positioned to execute targeted contract-layer interventions when an objective trigger is met.

A narrow scope here protects the predictability making payment stablecoins viable as payment infrastructure. A broad or discretionary one shifts effective authorization control to an actor not party to the transfer and not participating in pre-transaction review. That breaks the architecture, and the institutions party to the transfer end up with no certainty about whether an authorized transfer will settle.

What's at stake

This rulemaking will decide whether the U.S. ends up with a stablecoin payment system designed for cross-border interoperability or one engineered around U.S.-specific architectures the rest of the world has already moved past.

The full Notabene submission can be found here, and is on regulations.gov under Docket FINCEN-2026-0100.

Additional analysis will follow over the coming weeks on OFAC sanctions architecture, the special standards of diligence framework for cross-border PPSI counterparty relationships, and the foreign payment stablecoin issuer equivalence question.

Questions? Contact our Regulatory & Compliance team here.

Any payer holding funds at an institution on the Notabene Network can now complete a Notabene Flow payment with no additional integration required

NEW YORK, June 4: Notabene, the trust layer for global money movement, today announced that customers of hundreds of regulated digital asset institutions can now complete Notabene Flow payments directly from accounts they already use. The milestone extends Notabene Flow's reach to the customers of every institution integrated on the Notabene Network — the largest global network of regulated digital asset institutions, spanning 2,000+ entities across 100+ jurisdictions and processing trillions of dollars of transaction volume annually.

The activation follows a network-wide rollout of Notabene Flow responder capabilities to Notabene's existing customer base — the exchanges, custodians, payment providers, and banks already running Travel Rule-compliant multi-party flows on the Notabene Network. Any business that issues a Notabene Flow payment link today can expect the recipient to complete the transaction directly from their hosted wallet at one of these institutions, with no separate onboarding required on their end. Payers can also complete Notabene Flow payments using a self-hosted wallet through the Notabene platform.

"The value of a payment network comes down to reach — whether the person you're trying to pay can actually receive it from wherever their funds are held," said Pelle Braendgaard, CEO of Notabene. "Hundreds of live responders means that when a business sends a Notabene Flow payment link today, the recipient can pay from their existing account at an institution already on the network. Building that kind of reach on an open network, rather than a closed one, is what makes it genuinely useful at scale."

Notabene Flow launched in September 2025 as the first open stablecoin payments network that authorizes every B2B invoice before it settles and reconciles it as it arrives — across any wallet, network, or jurisdiction. The network is built on the Transaction Authorization Protocol (TAP), an open messaging standard that any regulated institution can implement regardless of which custody or infrastructure provider, assets or blockchain they use.

Businesses can join the Notabene Flow network today to enable high-value cross-border B2B payments, using pull payments, structured invoicing, and Travel Rule-compliant multi-party payment flows at notabene.id/join-flow.

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About Notabene

Notabene is the trust layer for global money movement. The Notabene network connects thousands of trusted counterparties, facilitating trillions of dollars in transaction volume annually across over 100 jurisdictions. Notabene provides industry-leading tools for stablecoin payment coordination, real-time transaction authorization, counterparty verification, and self-hosted wallet identification—helping institutions build trust into every transaction.

Learn more at notabene.id

Media Contact:
Clay Fain
VP Marketing
[email protected]

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According to the Chainalysis 2026 Crypto Crime Report, in 2025, illicit crypto addresses received over $154 billion which is a 162%increase year over year. Further, 84% of all illicit volume moved through stablecoins, which is up from 63% the year before. Sanctions evasion alone grew 694%.^[1] The numbers should reframe how every compliance team in the United States is reading the GENIUS Act.

Now read the GENIUS Act and ask yourself: does this law address where the risk lives?

The Architecture Is Pointed at the Wrong Thing

The GENIUS Act is a serious piece of legislation. The first federal statute to define payment stablecoins as a distinct asset class. Reserve requirements. Redemption mechanics. Issuer governance. Bank-level AML obligations for permitted issuers. All necessary.

But here is the thing nobody is saying out loud. The entire architecture of GENIUS is built around regulating the issuer. The act defines who is permitted to issue. Who must hold reserves. Who must attest monthly. Issuer, issuer, issuer.

The problem is the risk does not live with the issuer.

Risk in stablecoin payments lives in the network. Wallets. Exchanges. Intermediaries. Cross-chain flows. Counterparty institutions in jurisdictions with weak or nonexistent supervision. 

Regulate a stablecoin issuer perfectly and the 84% still flows right through. Require pristine reserves, monthly attestations, full BSA compliance at the issuance point. None of these addresses what happens to the tokens once they leave the issuer's custody.

The Rulemaking to Read First

One piece of GENIUS implementation is focused on the network reality. The FinCEN/OFAC joint NPRM, released for public comment in April with a June 9 deadline, amends 31 CFR 1010.100(eee). ^[2] For the first time, the U.S. is codifying the Travel Rule for digital assets into federal statute.

This matters more than the headline rulemakings most teams are tracking. The Travel Rule is the only mitigating control we have before a transaction settles. No correspondent bank holding the message in a queue. No three-day window for sanctions review. The compliance work has to happen before the transaction broadcasts.

The Travel Rule pairs two BSA obligations the U.S. has had on the books since the mid-1990s for wire transfers. Recordkeeping for what you hold. Information exchange for what you pass to the next institution in the chain. FinCEN extended these obligations to crypto in 2019. ^[3] The April NPRM is the codification.

The international picture has moved further. According to FATF, 87% of material jurisdictions have either implemented Travel Rule for crypto or are in the process. ^[4] The UK has been live since September 2023. ^[5] The EU went live under the Transfer of Funds Regulation on December 30, 2024. ^[6] The U.S. is now closing the implementation gap.

What Winners Are Doing Differently

Most firms approach a new regulatory regime by reading the rule, writing a memo, running the memo through legal, building a compliance program around the memo. Six months later they realize they have a policy and no operational capability.

The teams winning this approach the work differently. They start with their transaction flows. They map their counterparty universe. They identify decision points where data has to be collected, screened, exchanged, or held. They architect for configurability because GENIUS is one regime among several. 

Address screening alone is no longer sufficient. Identifying a counterparty institution at the time of every transfer is no longer optional. Real-time pre-transaction authorization is what counterparties and examiners now expect. The firms reading GENIUS as a checkbox on issuer reserves are going to be surprised when their counterparty diligence questionnaires double in length next quarter.

The Read

The act addresses issuer accountability, which is necessary. But the risk lives in the network. Miss the network framing and you have a beautifully regulated issuer base with bad actors flowing 84% of their illicit volume right through the rails.

From where we sit at Notabene, supporting Travel Rule and transaction authorization across more than 2,000 institutions in 100 plus jurisdictions, the firms moving fastest right now are treating GENIUS as a network problem from day one. They are not waiting for final rules. They are architecting for the operational reality the NPRMs already describe.

Bad compliance is a barrier to growth. Good compliance is infrastructure for growth. Compliance is now a feature of the platform, not a wrapper around the platform.

The winners here won't be the most compliant. They'll be the most operationally adaptable.

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Last week at Stablecon in Amsterdam, I was on a panel called "Killing the Fiat Stablecoin Sandwich" with Simon Taylor (Tempo), Tyler Sherwin (BVNK), and Tedd Huff (Fintech Confidential).

We had a good debate about the pros and cons of the current implementation of the stablecoin sandwich. But I came away thinking the whole framing, mine included, was off.

The stablecoin sandwich isn't the real problem. The word "stablecoin" is.

The day prior to the panel I had a call with the digital assets GM at a major European bank. He said something that stuck:

"From our perspective, a stablecoin is just a settlement mechanism between fiat accounts. The enterprise instructs us to move money. Whether it goes via Swift or stablecoin rails, it lands as fiat on the other side."

That's it. He's right. And once you accept that, the whole "sandwich" debate looks different.

The "stablecoin" name is doing a lot of damage

"Stablecoin" sounds like a crypto asset that happens to be price-stable. Something exotic. Something you need to convert into and out of. That framing comes from crypto, from a world where on/off ramps are real because you're genuinely leaving fiat when you buy Bitcoin.

But USDC is just dollars. EURC is just euros. When you "on-ramp" to USDC, you never left fiat. You just changed the form factor. There is no ramp. There's no sandwich. There's just fiat sitting in a different kind of account.

It's all just money

M0, M1, and M2 are all fiat. Physical cash, checking accounts, savings accounts: different properties, different forms, same underlying asset. We don't call a savings account an "M2coin." We don't build conversion infrastructure between your checking account and your money market fund and call it a sandwich.

Tokenized money market funds are basically M2. Tokenized deposits are M1 or M2 depending on the form. Stablecoins don't fit neatly into the existing categories, but they belong in the same family. They're a new form of fiat with slightly different properties that they share with their other tokenized money cousins: programmable, blockchain-settled, 24/7. Not a foreign asset.

So why does the sandwich exist?

Because we borrowed crypto infrastructure (tokenization, blockchains, wallets) for a fiat asset, but kept the crypto mental model around it. The result is two conversion events that don't need to exist, a PSP sitting in the middle taking margin, and correspondent banking rebuilt at higher cost with extra steps.

The current batch of stablecoin orchestrators (as they came to be known) built the Wise model for stablecoins. That's useful. It works. But it's a stepping stone, not the destination. This PSP model exists because banks aren't plugged into stablecoin rails natively. Once they are, the on/off ramps dissolve.

One of the things we did discuss on stage at Stablecon is that this model, just like Wise recreates all the bad parts of correspondent banking. Not because of any specific properties of stablecoins, but because they still rely on pre-funded accounts and bilateral agreements to operate (aka correspondent banking).

The end state is simpler than the sandwich

It's account-to-account transfers on open, programmable rails. The stablecoin is the settlement layer, invisible to the enterprise, just like ACH or SWIFT is invisible today. The bank's treasury team picks the right stablecoin for the corridor. The CFO sees euros leave and euros arrive.

No sandwich. Just payments.

I argued at Stablecon that the sandwich scales badly: custody concentration, treasury risk, limited reachability. That's still true. But the deeper point is that we've been debating how to improve the sandwich when we should be asking why we're making sandwiches with fiat in the first place.

Stablecoins are just fiat. The sooner we name them that way, the better the infrastructure we'll build around them.

On 20 May 2026, the European Commission’s Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) opened its targeted consultation on the review of the Markets in Crypto-Assets Regulation (MiCA). Responses are due by 31 August 2026 and must be submitted through the Commission’s online questionnaire.

The consultation has two tracks: a public consultation for individuals, and a targeted consultation for specialised stakeholders, covering more technical and legal questions. This article focuses on the targeted consultation.

This is the first formal step in the legislative review process anticipated under Article 140 of MiCA. The Commission is expected to report to the European Parliament and Council by 30 June 2027, on the application of MiCA and, where appropriate, accompany that report with a legislative proposal — what the market already refers to as “MiCA 2”.

Want to talk this through? Join us on 4 June, 2026, for a live webinar on From Transition to Transformation: MiCA Grandfathering Ends, the New Consultation, and What Comes Next - where we will unpack the consultation question by question and discuss what is at stake before the 31 August deadline.

Why this consultation matters

MiCA was designed before today’s stablecoin, tokenisation and DeFi markets had fully taken shape. It began applying in stages from 2024, but the market has continued to move quickly, and other jurisdictions have now put forward their own frameworks.

That is the backdrop to this consultation. The Commission is asking whether MiCA remains fit for purpose in a rapidly evolving global market, and whether the EU framework should be adjusted to reflect what has changed since the regulation was adopted.

The exercise is not limited to small technical corrections. It reopens core policy questions about Europe’s digital finance framework: whether MiCA can support globally relevant euro-denominated stablecoins, how the EU should position itself in a market increasingly shaped by USD denominated global stablecoins, where the regulatory perimeter should sit, and whether the current crypto-asset service providers (CASPs) framework is strong enough to protect the integrity of the EU market in practice. 

The consultation is organised into four parts:

1. Scope and definitions for crypto-assets other than asset-referenced tokens (ARTs) and e-money tokens (EMTs)
2. Requirements applying to ARTs, EMTs and their issuers
3. The legal framework for CASPs
4. Topics outside MiCA’s original scope, including decentralised finance, prediction markets, tokenised deposits and legal certainty for natively issued on-chain assets

Below are some of the key themes to watch.

Part 1: Where does MiCA’s perimeter sit?

The first part of the consultation deals with crypto-assets that are neither ARTs nor EMTs — what MiCA calls “other crypto-assets”. It opens with the architectural question at the heart of the framework: where should the boundary between MiCA and sectoral financial services legislation sit?

Today, crypto-assets that qualify as financial instruments remain outside MiCA and are instead governed by frameworks such as MiFID II, MAR and the Prospectus Regulation. That reflects the principle of “same activity, same risk, same rules”.

The challenge is that market reality is testing that boundary in both directions. Traditional financial institutions are entering the MiCA-regulated crypto-asset space. MiCA-authorised entities are expanding into products that look closer to traditional financial instruments. Tokenised fund interests, tokenised money-market instruments, wrapped assets, governance tokens, all raise difficult classification questions.

The consultation also revisits the design of Title II, including the white paper framework, marketing rules, ex ante notification model, retail withdrawal rights, civil liability and post-issuance updates. The Commission is asking whether the current model strikes the right balance between investor protection, market integrity and innovation.

Part 2: Stablecoins take centre stage

Part 2 is the longest and arguably the most politically charged section of the consultation. The Commission structures the discussion around three themes: the future role of stablecoins in the EU, the calibration of MiCA’s existing rules, and the treatment of global stablecoins.

The future role of stablecoins

The consultation begins by asking what stablecoins should become in the EU over the next five to ten years. Are they likely to become a mainstream retail payment instrument? A wholesale settlement rail? A complement to existing payment methods for cross-border payments? Or a transitional product that will eventually be displaced by CBDCs or commercial bank money innovations?

That framing is important because the answer drives the policy choices that follow. If stablecoins are treated mainly as crypto trading instruments, the focus is likely to remain on investor protection and market integrity. If they are treated as payment infrastructure, then redemption, liquidity, reserve management, operational resilience and supervisory reporting become much more central.

The consultation also asks how beneficial stablecoins could be for concrete use cases, including international payments, retail payments, wholesale payments, settlement of tokenised financial instruments, corporate treasury management and access to programmable financial services.

A clear vision of these use cases is essential for an informed policy debate. Stablecoins’ risks depend heavily on how they are used, at what scale, by whom, and in connection with which parts of the financial system.

Reopening the debate on interest-bearing stablecoins

The consultation reopens one of the most politically sensitive questions in MiCA: whether the prohibition on interest for EMTs and ARTs remains appropriate in its current form.

Under MiCA, issuers of e-money tokens are prohibited from granting interest in relation to EMTs. The prohibition also applies to CASPs providing services related to EMTs, and “interest” is defined broadly to include any remuneration or other benefit linked to the length of time a holder holds the token. 

That design reflects MiCA’s original policy choice: EMTs should function as means of payment, not as store-of-value products competing with bank deposits. But the effect is that euro EMTs are structurally non-remunerated even where the reserves backing them generate income. As the Blockchain for Europe Joint Report “Reforming MiCA for Euro Stablecoins” argues, this can weaken the competitiveness of euro-denominated stablecoins and push users either toward foreign-currency stablecoins or toward yield structures outside the regulated perimeter.

The consultation puts several questions back on the table. Should MiCA continue to prohibit all holder benefits linked to time held, even where they are funded solely from low-risk reserve income? Should the regime distinguish between issuer-paid interest, third-party rewards and regulated pass-through remuneration? And would allowing limited remuneration improve the competitiveness of euro EMTs, or would it create unacceptable risks for bank funding and monetary transmission? 

Global stablecoins and multi-issuance

A key part of the stablecoin discussion concerns global stablecoins and, in particular, multi-issuance models.

There are two questions running in parallel here. The first is a legal one: does MiCA, as currently written, allow multi-issuer models? The Commission gives a clear answer in the consultation. In its view, MiCA does not currently prohibit them.

That statement matters because EU authorities have adopted divergent stances:

• The ECB, in its 10 April 2026 non-paper on EU and third country stablecoin multi-issuance, argues for a reading of MiCA that would not permit third-country multi-issuance. Its concern is that third-country issuers are not generally required to comply with protections equivalent to MiCA, and that multi-issuance could expose EU token holders — and potentially the EU financial system as a whole — to material risk. 
• The European Systemic Risk Board reached a similar conclusion in its September 2025 recommendation. It flagged third-country multi-issuer schemes as amplifying financial stability risks that Union supervisors cannot adequately assess from outside the EU, and recommended that the Commission should not consider such schemes to be permitted under the current MiCAR framework. 

The second question is a policy one: even if multi-issuance is not prohibited under the current text, should MiCA continue to allow it, and under what conditions?

That is the debate the Commission is now reopening. It asks whether EU users and businesses benefit from access to global stablecoins, how important it is that such access is provided through EU-licensed issuers and CASPs, and what safeguards would be needed to manage the risks of multi-issuance.

Particularly, the consultation asks whether MiCA’s existing safeguards can mitigate multi-issuance risks and, more specifically, whether the EU share of a globally fungible stablecoin can be determined with sufficient accuracy and frequency, especially where tokens circulate through self-hosted wallets.

That question sits at the intersection of MiCA’s prudential framework and the compliance infrastructure needed to make that framework operational. On-chain data may show that a transfer occurred, but it does not, by itself, tell a supervisor whether the transfer changed the person legally entitled to the token, whether the holder is located in the Union, whether the holder is retail or institutional, or whether the movement was a payment or a first-party transfer.

That information cannot be inferred with supervisory confidence from on-chain data alone. It requires identity and transaction-context data held by CASPs, issuers and other reporting infrastructures.

This is where Travel Rule architecture becomes relevant beyond its AML/CFT purpose. Originator, beneficiary and wallet-control data can help attach legal and prudential meaning to otherwise pseudonymous on-chain flows. Multi-issuance safeguards — especially any mechanism that rebalances reserves between an EU issuer and a third-country issuer based on estimated EU holdings — are only as reliable as the data used to identify those EU holdings in the first place.

Effective Travel Rule implementation is therefore instrumental to unlocking properly managed multi-issuance frameworks.

Finally, the consultation also asks whether the EU should introduce an equivalence regime for global stablecoins, and how much reliance should be placed on third-country supervision.

This debate is in direct dialogue with the emerging U.S. approach. The GENIUS Act creates a controlled access route for foreign payment stablecoin issuers whose tokens are offered into the U.S. market. The foreign issuer must operate under a comparable home regime, register with the Comptroller of the Currency, and hold reserves in a U.S. financial institution sufficient to meet the liquidity demands of U.S. customers, unless a reciprocal arrangement provides otherwise.

The EU is confronting a similar policy problem. A globally transferable stablecoin may be issued, distributed or managed across several jurisdictions, but redemption pressure, liquidity risk and consumer protection concerns materialise locally. The policy question is how to preserve access to global liquidity while ensuring that EU holders are not dependent entirely on reserves, redemption arrangements and supervisory powers located outside the Union.

Part 3: The CASP perimeter after grandfathering

Part 3 examines the legal framework for CASPs. It revisits the scope of crypto-asset services under Article 3(16), the prudential regime and minimum capital requirements for different classes of CASPs, and the interaction between MiCA and the revised payments framework for transfer services involving EMTs.

One question stands out as the EU approaches the end of MiCA’s grandfathering period: are unauthorised crypto-asset service providers continuing to serve EU users?

This question goes to the credibility of the MiCA perimeter. By the end of the transitional period, the market is expected to look materially different. Around 200 CASPs are authorised according to ESMA’s Interim MiCA register, while there is an expectation that approximately 75% of the pre-MiCA VASP population will lose its registration status as national transitional periods expire.

Against that backdrop, the relevant supervisory question is not only which firms become authorised under MiCA, but also whether firms outside the EU authorisation framework continue to serve EU residents, and what tools supervisors or enforcement authorities should have to stop unauthorised service provision.

MiCA-authorised CASPs are investing in licensing, governance, safeguarding, conduct rules, operational resilience, market abuse controls and prudential requirements. If offshore or otherwise unauthorised providers can continue to serve EU residents, the result is an uneven playing field. Consumers remain exposed to providers outside the EU supervisory framework, while authorised firms carry the cost of compliance without the benefit of a protected market.

The FATF’s 2026 report on offshore VASPs is directly relevant here. It points to the risk that regulatory or enforcement developments can shift user activity toward offshore, unregistered providers. It also highlights the need for clearer criteria on what counts as active service provision into a jurisdiction, expectations for authorised VASPs to assess exposure to unlicensed counterparties, and stronger host-jurisdiction powers against offshore providers targeting local residents without authorisation.

These points map closely onto the post-grandfathering MiCA environment. The success of MiCA will depend on making sure its perimeter is meaningful in practice.

Part 4: Revisiting what MiCA left outside

The final part of the consultation looks at activities that were left outside MiCA’s original scope and asks whether the perimeter should now be redrawn.

Decentralised finance

MiCA excludes crypto-asset services provided in a fully decentralised manner without intermediaries. While that may sound straightforward, in practice decentralisation is rarely binary.

The consultation asks how to assess whether a service is truly fully decentralised and what indicators should matter: control over the protocol, governance rights, admin keys, front-end control, revenue capture, upgradeability, or the ability of identifiable persons to influence outcomes.

It also asks what role CASPs should play when connecting users to DeFi. Options range from warnings and disclosures, to CASP liability for incidents, to limiting access to certified applications or verified pools, to whitelists, blacklists or outright restrictions on CASP facilitation of DeFi access.

Prediction markets

The consultation also asks whether DLT-enabled prediction markets create opportunities or risks for EU consumers and markets, and whether they should fall under MiFID or MiCA when facilitated through smart contracts.

In the U.S., prediction markets have become a live test case for regulatory perimeter-setting. The CFTC is pursuing a clearer federal framework for prediction markets, asserting that event contracts offered to the public may fall within the Commodity Exchange Act as swaps or futures traded on regulated venues, while several states continue to challenge certain markets as gambling or contrary to public policy. 

Tokenised deposits and natively issued assets

The consultation also explores tokenised deposits, including their use cases, regulatory constraints and interaction with the CRD/CRR framework and the Deposit Guarantee Schemes Directive.

This is part of a broader question running through the consultation: how should EU law treat assets that are issued, recorded and transferred natively on-chain?

If tokenised deposits, tokenised securities, stablecoins and natively issued assets are expected to support future financial market infrastructure, participants need clarity on legal nature, transfer finality, holder rights, insolvency treatment and supervisory responsibilities.

What comes next

Responses to the consultation are due by 31 August 2026 through the online questionnaire on the Commission's website. 

Notabene will be following this consultation closely and engaging in the policy conversation.

If you want to dig into what the end of the grandfathering period and the new consultation mean in practice, join us for our upcoming webinar on June 11, 2026:

— From Transition to Transformation: MiCA Grandfathering Ends, the New Consultation, and What Comes Next. We'll walk through the policy choices on the table and what they mean for the future of Europe’s digital financial infrastructure.

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This week, two executive orders signed on the same day. While most coverage is treating them as separate stories, when read together, they are really one important compliance story.

The Fintech Integration EO

The Fintech Integration EO asks the Federal Reserve to evaluate direct access to Reserve Bank payment accounts for non-bank financial companies, naming digital asset firms in the text. For stablecoin issuers, custodians, and digital asset infrastructure, this is the master account fight finally landing on a federal clock.

This fight has been the most consequential unresolved piece of U.S. digital asset policy for years. Reserve Bank discretion is exercised on a case-by-case basis without a consistent standard. The result has been a payment system where digital asset firms could approach but not enter, dependent on sponsor banks willing to take on the relationship risk. This EO doesn't resolve the access question on its own, but it does force the Federal Reserve to put a transparent framework on paper within four months, and if the conclusion is that existing law permits expanded access, the 90-day application clock starts running.

The Restoring Integrity EO

The Restoring Integrity EO, signed the same day, gives Treasury 90 days to propose BSA changes that strengthen risk-based CDD and beneficial ownership identification, and 180 days to revisit CIP requirements. The mechanism reaches every covered institution.

How the two work together

A helpful way to think about these two EOs together is that one opens a door, while the other raises the bar for anyone walking through it.

For stablecoin issuers, the operational picture changes overnight if the Federal Reserve Bank concludes existing law permits expanded access. They will have access to direct settlement and real-time payment network participation with no sponsor bank in the middle. Settlement risk profiles, capital efficiency, and the operational architecture of a stablecoin business all look different the day after that determination lands.

The price of that access is becoming clearer too. The CDD and CIP changes pull domestic U.S. identity standards much closer to what FATF Recommendation 16 already demands cross-border. The gap between what a U.S. bank has been expected to collect on a domestic account opening and what a VASP has been expected to collect on a Travel Rule transfer has been wide for years. A U.S. bank could open an account with minimum FinCEN CDD compliance. A VASP sending the same customer's funds cross-border had to satisfy originator and beneficiary information requirements that went substantially further. These orders close that gap from the domestic side.

The firms already operating to FATF-aligned standards have been doing it because they had to, while the firms that built compliance programs to the higher standard absorbed the cost. That gap is what's closing.

Four Key Takeaways

Here are the four things compliance teams should be thinking about in the wake of these EOs.

1. Pressure-test your CIP program documentation against a tighter BSA standard. The Treasury advisory lands in 60 days and the proposed BSA changes land in 90.
2. Audit your beneficial ownership controls. If your onboarding is built to the minimum FinCEN CDD rule, the floor is moving and your program is about to look thinner than it did last week.
3. Map your counterparty due diligence to FATF R.16. The standards being raised domestically are the ones FATF has expected on the originator and beneficiary side for years. Domestic and cross-border requirements are converging.
4. If you are pursuing a Fed master account, get your application-readiness package together now. When the 90-day clock starts, firms with documented, examiner-ready programs move first.

In the end, most "good enough" compliance setups will not hold under these new rules. The firms treating May 19 as an inflection point will be the ones positioned when access expands.

How the 2026 Report Reshapes Crypto Compliance

In March 2026, the US Treasury published its report on Innovative Technologies to Counter Illicit Finance Involving Digital Assets. The report frames AI, digital identity, blockchain analytics, and APIs as the four technology pillars for modern financial crime compliance. Inside sits a sharper signal for digital asset firms: Treasury explicitly references the Travel Rule, reaffirming the Funds Transfer Rule applies to crypto transactions over $3,000 and is expected to be operationalized in practice.

While the Travel Rule has long been applicable to the US crypto market, its implementation was frequently viewed more as a policy guideline than a functional necessity. The 2026 report marks a definitive transition from theoretical interpretation to mandatory implementation.

Treasury's Stance on Travel Rule Implementation

Rather than proposing new mandates, the Treasury is reinforcing established regulations. The report reiterates that digital asset transfers fall under the Funds Transfer Rule, maintaining the $3,000 threshold and requiring the collection, verification, and transmission of originator and beneficiary data.

The significance lies in the context: this directive is central to a 2026 report on illicit finance and advanced compliance tools. The industry's focus must now shift from questioning the rule's applicability to ensuring its practical effectiveness.

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The Treasury's report is a major federal action signal in addition to the April 8, 2026 joint Notice of Proposed Rulemaking from FinCEN and OFAC detailed AML/CFT requirements for stablecoin issuers under the GENIUS Act. That is in additional to the FATF's March 2026 report identifies Travel Rule data gaps as a primary vulnerability in global crypto AML efforts.

All of these are moving towards the objective of closing the compliance gap.

Monitoring Is Not Travel Rule Execution

Many firms assume blockchain analytics coverage equals Travel Rule coverage. The assumption is wrong.

Blockchain analytics tools identify risk, monitor transactions, and trace flows across wallets and chains. They give institutions visibility into on-chain activity. Analytics tools do not fulfill Travel Rule obligations. They do not send originator and beneficiary data to counterparties. They do not standardize data across institutions. They do not enforce compliance workflows between counterparties.

Insight alone does not meet regulatory requirements. Insight has to be acted on, triggering workflows, exchanging required data, and enforcing decisions across counterparties. This is the distinction Treasury is pointing toward. The difference between monitoring and execution.

Obtaining insight is only the first step toward meeting regulatory mandates. Actionable workflows, data exchange, and cross-counterparty enforcement are necessary to bridge the gap between simple monitoring and true execution.

The Network Nature of Compliance

Because the Travel Rule relies on secure, real-time interactions between institutions, compliance cannot be achieved in isolation. Connectivity is the essential core of the rule.

Digital asset and stablecoin compliance is a network-wide challenge rather than an entity-specific one. While issuer compliance and counterparty controls are foundational, the system remains vulnerable if the broader network fails to exchange data reliably.

Structural exposures caused by network gaps are now a primary target for regulators, as evidenced by the alignment of the FATF offshore VASP report, the April 8 NPRM, and the Treasury Report.

How to Execute Travel Rule Compliance in Practice

This is the gap Notabene was built to solve. Notabene acts as the trust layer enabling institutions to execute Travel Rule compliance. The platform identifies and screens counterparties before a transaction, performs VASP due diligence, securely exchanges required Travel Rule data between institutions, and supports real-time decisions on whether a transaction should proceed. All of this happens before funds move.

Travel Rule compliance depends on reachability. Notabene addresses this through a global network of over 2,100 VASPs and over 260 financial institutions, custodians, and exchanges, spanning more than 100 jurisdictions and supporting 300+ assets and blockchains.

Compliance Infrastructure for the Next Phase of Digital Assets

For years, the Travel Rule was discussed primarily as a regulatory obligation. Treasury’s 2026 report signals a broader shift toward operational maturity, interoperability, and trusted digital asset infrastructure.

The shift is not about entirely new rules. It is about higher expectations for how compliance is embedded into real-time financial systems.

As digital assets and stablecoins become more integrated into global finance, institutions need infrastructure that enables secure connectivity, trusted counterparties, and seamless data exchange across networks. Monitoring and visibility remain important, but scalable growth increasingly depends on the ability to operationalize compliance in a way that supports speed, trust, and cross-border participation.

The opportunity for the industry is significant: institutions that can execute compliance efficiently will be better positioned to expand partnerships, access new markets, and participate confidently in the next generation of financial services.

The question is no longer simply whether firms understand the Travel Rule. It is how they use compliance infrastructure to unlock safer, faster, and more connected digital asset ecosystems.

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