Beyond Banks: GENIUS Act Spurs Nonbank Stablecoins, From Cloudflare to Agentic Payments
As issuers beyond the traditional financial sector wade into stablecoins, a growing share of products and services long dominated by banks could migrate to retailers, platforms and other commercial players. That’s the direction of travel highlighted by Noelle Acheson, and the trend is accelerating now that the GENIUS Act has become law.
Since enactment, banks and a wide variety of fintechs have moved quickly to scope out issuance and related services. What has drawn far less notice is the prospect of stablecoins minted by companies that are not banks. Many observers assumed nonbanks were effectively sidelined during the legislative wrangling — especially after pointed objections to letting social networks turn their user bases into payments ecosystems and amass even richer data troves. The lingering legacy of Facebook’s (now Meta’s) Libra effort still casts a long shadow.
Even so, the GENIUS Act does not bar nonbanks; it simply makes their route steeper. One path is to apply to the Office of the Comptroller of the Currency (OCC) for approval. Another option exists for those content to remain under a $10 billion market capitalization cap: obtain a charter from a state regime that has received federal blessing.
Publicly traded issuers face an extra gate. They must secure unanimous approval from the Stablecoin Certification Review Committee (SCRC), an oversight panel comprising the chair of the Federal Reserve (or the vice chair for supervision), the chair of the Federal Deposit Insurance Corporation (FDIC), and the secretary of the Treasury. Historically, both the Fed and FDIC have been seen as skeptical of crypto innovation, so the hurdle is nontrivial — though the regulatory mood, and the personnel guiding it, are evolving.
There are also strict data-use constraints. Nonbank issuers must pledge not to leverage stablecoin activity data to push content or services, not to sell that information to third parties, and not to share it with non-affiliated entities without explicit user consent. These limits may feel particularly constraining for social media businesses, but they are unlikely to impede other technology and consumer brands from offering stablecoins for a wide array of practical purposes.
Case in point: Cloudflare — the web security and internet performance company known for DNS and optimization services — recently introduced the NET Dollar, a stablecoin backed 1:1 by U.S. dollar assets. Several details remain to be disclosed. We do not yet know which blockchains will host the token, beyond a statement that it will work “across networks and ecosystems.” Launch timing is described only as “soon.” We also don’t have clarity on whether Cloudflare itself will be the issuer — which, as a public company, would require both OCC approval and SCRC sign-off — or whether it will rely on a licensed partner. The GENIUS Act leaves open questions around “white-label” issuance structures.
We do know the initial purpose: enabling transactions between algorithms. Cloudflare’s reveal followed, by two days, the announcement of a collaboration with Coinbase to establish the x402 Foundation, an initiative to set standards for agentic payments and to build deferred settlement capabilities for autonomous agents.
This underscores that “payment stablecoins” — the category governed by the GENIUS Act — are not limited to on-chain settlement or international transfers. The long-standing absence of a seamless solution for online micropayments has hampered content monetization and broader web services for years. The rise of AI agents makes small, automated transactions not just attractive but essential, heightening the need for scale, flexibility and programmability. Stablecoins running on public networks look like a natural fit.
Looking beyond agentic commerce, where else might nonbanks deploy stablecoins? In June, the Wall Street Journal reported that Amazon and Walmart have explored the idea of launching their own. It remains uncertain whether they would issue directly or rely on an authorized partner, and how regulators would view either path. The strategic logic is compelling, though. Interchange, assessments and processor fees impose a meaningful tax on retail margins; shaving off even a few basis points at Amazon’s and Walmart’s volumes would add up quickly. Stablecoins also enable faster settlement than card
