The US Treasury published its notice of proposed rulemaking under the GENIUS Act on 17 August 2026, setting out which stablecoin issuers may operate in the American market and on what timetable. Public comments are open until 19 October 2026.
Will Harborne,founder and CEO of Rhino.fi
Most of the early commentary has treated the proposal as a compliance question for issuers. The contributed piece below argues that it is also a treasury question for any company that accepts stablecoins from customers: what a counterparty is allowed to send, and what the finance team is prepared to hold, are two decisions that most businesses have not yet separated.
Will Harborne is founder and chief executive of Rhino.fi, a cross-chain liquidity and settlement infrastructure company that moves stablecoin payments across multiple blockchain networks. The article that follows sets out his opinion.
The US Treasury’s latest notice of proposed rulemaking under the GENIUS Act sets out how stablecoin issuers and platforms can qualify to operate in the US market. Licensing requirements would start in January 2027, with the broader restrictions on stablecoins sold to US persons from mid-2028. The proposal is open to public comment, but finance teams already have to think more deliberately about issuer eligibility and what they are prepared to hold.
The era of ‘just send USDC’ was already ending, regardless. Banks and fintechs are launching their own stablecoins. Consortium models are adding issuers, while euro-denominated stablecoins have moved past their cold start, with market capitalisation up 128 per cent year over year. As stablecoins become part of mainstream fintech infrastructure, payment teams need room to accept what customers already use, while treasury still has to control what reaches the balance sheet. Without a defined boundary, ordinary customer requests can keep landing on the CFO’s desk.
Customer flexibility needs treasury boundaries
In the client base I work with, the median business settles into a single asset, and more than 90 per cent of them choose USDC or USDT, even when counterparties can pay in 10 supported assets, with more being added. Treasury policy can stay narrow even when acceptance expands.
Traditional payments separated those decisions years ago. Merchants can accept several payment methods without allowing each one to dictate how funds end up in the treasury; the same separation matters for stablecoins as issuers and currency choices expand.
When acceptance grows asset by asset, routine commercial requests can pull finance into questions about liquidity, accounting treatment, concentration exposure, and internal controls. A settled policy keeps individual payment preferences out of executive decision-making.
Set the settlement policy before the payment arrives
Treasury can set the destination first by defining a single settlement asset, or a tightly controlled set, aligned with the company’s liquidity needs and accounting framework. The policy can also account for risk limits and banking relationships, which gives customer-facing teams room to accommodate more payment preferences without reopening the balance-sheet decision each time.
Onchain FX built into the deposit lets the transaction follow that policy. A counterparty sends a supported asset, and the deposit converts it in accordance with the company’s rules, so that treasury receives the approved settlement asset. Conversion can occur one to one within one currency. Cross-currency transactions use market FX. Sales and payments teams can support more customer preferences under a policy finance has already approved.
Exceptions become process debt
Clients are still in the process of formalising a settlement policy, often because the decision sits with finance stakeholders who are still evaluating options as their stablecoin acceptance grows. That gap is the problem: without a policy in place, one-off exceptions stop being exceptions and start becoming how things are handled by default.
One MENA prospect received 4,000 BNB on an unsupported chain and needed roughly 30 days of manual work to reverse the transaction. Another client built a dedicated Slack channel for wrong-asset refunds. Thirty days of manual work and a dedicated refund channel are finance overhead, regardless of how unusual the original payment was.
Settlement policy belongs alongside the other rules that govern corporate cash. It should define which assets the treasury may hold, what currency exposure is acceptable, who can amend the approved set, and how exceptions get handled. Ad hoc decisions then have a defined path instead of reopening policy case by case.
As local-currency stablecoins gain adoption and regulators draw their own lines around eligible users, finance teams will see a wider range of assets at the point of payment. Treasury still needs a deliberate settlement destination.
Your counterparties choose what they send. You choose what you receive. Those were never supposed to be the same decision.
