The Banks Are Coming: What the Joint Stablecoin Initiative Means for Every Institution That Isn’t Ready
The Signal That Changes Everything
In May 2025, the Wall Street Journal broke the story: JPMorgan Chase, Bank of America, Citigroup, and Wells Fargo were in active discussions about launching a jointly issued stablecoin. The infrastructure partners in the room weren’t crypto startups — they were Early Warning Services, the parent company behind Zelle, and The Clearing House, the payments network owned by two dozen of the world’s largest banks.
By September, the picture sharpened. EWS began exploring a stablecoin product aimed at retail bank customers — a small-scale test project that would give customers at some of the country’s biggest banks a way to use stablecoins in everyday payments. The Clearing House confirmed parallel discussions of its own.
Then in October, the story went global. Goldman Sachs, Deutsche Bank, Bank of America, Banco Santander, BNP Paribas, Citigroup, MUFG, TD Bank, and UBS announced a nine-bank consortium to explore a jointly backed digital currency pegged to G7 currencies, operating on public blockchains. Bloomberg reported the group was already engaging regulators across multiple jurisdictions.
And in January 2026, Bank of America CEO Brian Moynihan put a number on the stakes. Speaking to analysts on an earnings call, he warned that as much as $6 trillion in U.S. bank deposits — roughly a third of all commercial bank deposits — could migrate to stablecoins if yield-bearing tokens are permitted. That’s not speculation from a crypto evangelist. That’s the CEO of the second-largest U.S. bank telling the market that stablecoins have become an existential strategic consideration.
Let me be direct about what this means: the largest financial institutions on the planet have decided that stablecoins are not an experiment. They are infrastructure. And the institutions that built compliance-first are about to have the most valuable seat at the table.
Why This Validates the Compliance-First Thesis
Every conversation we have at 7T World with prospective clients eventually lands on the same question: do I really need to invest in compliance infrastructure now, or can I wait until the regulations are final?
The joint bank stablecoin initiative is the answer. And the answer is: the institutions that waited are already behind.
Here’s why. The GENIUS Act was signed into law on July 18, 2025 — the first comprehensive federal framework for payment stablecoins. It creates three regulatory pathways for permitted payment stablecoin issuers: through FDIC-supervised banks, through the OCC for nonbank entities and uninsured national banks, and through state-level frameworks. The FDIC published its first proposed implementing rules in December 2025. The NCUA followed in February 2026. Treasury is targeting final regulations by July 2026 — ahead of the January 2027 effective date.
But here’s the critical detail that most people miss: the FDIC will not accept applications until final rules become effective. That means the window between final rules and the effective date — potentially as little as 120 days — is when every institution seeking to issue or participate in stablecoin payment networks must demonstrate compliance readiness. Not begin building compliance programs. Demonstrate them.
JPMorgan already has JPM Coin. Wells Fargo piloted Wells Fargo Digital Cash. Bank of America’s CEO has publicly stated the bank is ready to issue a fully dollar-backed stablecoin. These institutions aren’t starting from zero. They’ve been building compliance infrastructure for years.
The question for every other financial institution, fintech, and payment processor is: when the application window opens, will you be ready?
The Compliance Gap No One Is Talking About
The GENIUS Act’s requirements are comprehensive. Permitted issuers are classified as “financial institutions” under the Bank Secrecy Act, subjecting them to full AML/CFT requirements — compliance programs, customer due diligence, suspicious activity reporting, and sanctions screening. Reserves must be backed one-to-one with high-quality assets: U.S. dollars, insured bank deposits, and short-term Treasuries with maximum 93-day maturity. No rehypothecation. No commingling. Monthly public disclosures. Annual audited financials for large issuers. The ability to freeze tokens on legal order.
That’s the floor. Not the ceiling.
What the rulemaking will add — and what the FDIC’s proposed rules already signal — includes capital requirements, liquidity requirements, reserve asset diversification standards, operational risk management frameworks, IT security requirements, and governance standards. Each of these must be operational, tested, and documented before an application can succeed.
For institutions accustomed to traditional BSA/AML programs, the stablecoin-specific requirements introduce capabilities most have never built: blockchain-specific transaction monitoring, wallet-level sanctions screening across multiple chains, real-time monitoring of 24/7 settlement (not business-hours batch review), Travel Rule compliance for on-chain transactions, and secondary market monitoring beyond direct customers.
This is not a gap analysis problem. This is an architecture problem. And you cannot solve an architecture problem in 120 days.
What EWS and The Clearing House Tell Us About the Future
The involvement of Early Warning Services and The Clearing House is the most significant signal in this entire story — more significant than any individual bank’s participation.
EWS operates Zelle, which processed 3.6 billion transactions totaling $1 trillion in 2024. The Clearing House operates RTP (Real-Time Payments), which handles interbank settlement for the majority of U.S. banks. These are not crypto companies exploring traditional finance. These are the backbone of the U.S. payment system exploring stablecoins.
What this means in practice: stablecoin payment infrastructure is going to be layered onto existing bank rails. It will operate through the same clearing and settlement networks that banks already use. It will require the same governance frameworks, the same examination readiness, and the same operational controls that regulators expect from core payment systems — plus the blockchain-specific requirements that come with stablecoins.
For institutions that have been building compliance programs designed for examination pressure, this is the moment everything clicks. The compliance framework you built for your BSA/AML program, your payment processing operations, your cross-border settlement capabilities — all of that becomes the foundation for stablecoin participation. But only if it was built right. Only if it’s operational, not just documented.
The Nine-Bank Consortium and the Global Dimension
The Goldman-led nine-bank consortium adds another layer. Their initiative — reserve-backed digital money pegged to G7 currencies, operating on public blockchains — represents the convergence of institutional banking with decentralized infrastructure. Bloomberg reported the group is already engaging regulators across multiple jurisdictions.
For any institution with cross-border operations, this means multi-jurisdictional compliance is no longer optional. The GENIUS Act governs U.S. issuers. MiCA governs European operations and has been fully in effect since 2024. The nine European banks launching a MiCAR-compliant euro-denominated stablecoin — ING, UniCredit, Danske Bank, and six others — are targeting the second half of 2026.
Singapore’s Payment Services Act, Hong Kong’s licensing framework, the UK’s incoming stablecoin regulations, Japan’s revised Payment Services Act — these are all live or imminent. The Financial Stability Board has flagged that even where stablecoin regulation has been implemented, “critical gaps include insufficient requirements for robust risk management practices, capital buffers, and recovery and resolution planning.”
An institution that builds compliance for one jurisdiction and hopes to extend it globally will fail. The compliance architecture must be designed for multi-jurisdictional operation from the beginning. That’s an infrastructure decision, not a policy decision.
Visa’s $3.5 Billion Signal
While banks were discussing joint stablecoins, Visa was already settling in them. As of November 2025, Visa’s monthly stablecoin settlement volume passed a $3.5 billion annualized run rate. In December, Visa launched USDC settlement in the United States through Cross River Bank and Lead Bank on the Solana blockchain — the first time U.S. issuer and acquirer partners could settle with Visa in a stablecoin.
Visa now has more than 130 stablecoin-linked card issuing programs in over 40 countries. And they’re deepening: Visa is a lead design partner for Circle’s Arc blockchain, a new Layer 1 built specifically for stablecoin payments, with participation from BlackRock and Goldman Sachs.
This isn’t a pilot anymore. This is production infrastructure at scale. And every institution participating in Visa’s stablecoin settlement programs needed compliance infrastructure ready before they could begin — not after.
What 7T World Is Building For
I started 7T World because I spent years on the enforcement side watching institutions fail — not because they lacked good intentions, but because they treated compliance as a document rather than an operating system. They hired consultants who delivered gap analyses and left. They built policies that looked impressive in a binder but couldn’t survive a single examiner question.
The joint bank stablecoin initiative is about to make that distinction existential.
The institutions that will participate in stablecoin payment networks — whether as issuers, as participants in EWS or Clearing House infrastructure, as Visa settlement partners, or as members of global consortia — will need to demonstrate operational compliance programs that satisfy both traditional banking examination standards and the new blockchain-specific requirements of the GENIUS Act.
That is exactly what we build. Not policy documents. Operating systems. Compliance programs that are tested against examination scenarios, staffed by people who have sat on both sides of the examination table, and designed to hold up when the regulators — or the banking partners — come looking.
We call our technology approach “injectable” for a reason. It’s designed to integrate into existing bank infrastructure — not replace it. When EWS layers stablecoin capabilities onto Zelle’s rails, the compliance technology needs to be injectable too. When a regional bank wants to participate in The Clearing House’s stablecoin network, the compliance framework needs to slot into their existing operations without a two-year rebuild.
The GENIUS Act’s final rulemaking deadline is July 2026. The application window will open shortly after. The institutions that start building now will be ready. The ones that wait for final rules will be applying for permission to compete while their rivals are already live.
The banks are coming. The question is whether you’ll be ready to meet them at the table.
Sources: Wall Street Journal (May 2025), Bloomberg (October 2025), The Block, CoinDesk, FDIC Federal Register (December 2025), NCUA (February 2026), Visa Investor Relations (December 2025), PYMNTS, Yahoo Finance.