Eric Kuvykin

By Eric Kuvykin. Substantially revised October 17, 2026. The original publication date and URL are retained.

Specify the business problem first

A merchant considering stablecoin payments should begin with a concrete need: a particular customer request, a cross-border collection problem or another documented friction in the existing workflow. A new payment option should be evaluated against that need rather than against a general promise that digital assets make every transaction cheaper or faster.

Identify what the merchant would receive, who converts it and which party bears any delay or loss between customer payment and usable business funds. This article supplies due-diligence questions, not an endorsement of a token, issuer, investment or provider.

Map the parties and the asset

Ask the provider to identify the token, issuer, network, custody arrangement and conversion service. Determine whether the merchant ever controls a wallet or receives only conventional currency through an intermediary. Those are materially different operating arrangements and should not share an unexplained product label.

Request a description of redemption, liquidity and service-interruption scenarios. What happens if the asset cannot be converted when expected, a transfer goes to an incorrect destination or the provider freezes an account for review? A pilot plan should identify the escalation route before a customer payment is accepted.

Review obligations with qualified specialists

FinCEN’s guidance illustrates why the actual virtual-currency business model matters to the regulatory analysis. It should not be read as a universal permission slip for a merchant or service provider. Have qualified advisers assess the proposed activity, the parties involved and the current federal and applicable state requirements.

Ask the provider for its legal entity, contractual role and relevant licensing or registration explanation. Independently verify material claims through the appropriate official resources. A logo or statement that a company is “compliant” is not a substitute for understanding what activity a claimed authorization covers.

Design refunds, accounting and failure handling

Describe the customer-facing price, conversion method, fees and refund approach in the proposed operating policy. Ask the accountant which records are needed for recognition, valuation and reconciliation. Do not assume the customer’s original asset amount and the merchant’s eventual proceeds will be interchangeable.

A business with Florida, New York or New Jersey customers should identify which entity accepts the payment and which jurisdictions its advisers need to consider. Avoid copying a generic online policy into a multi-state operation without examining the actual transaction flow.

If a pilot proceeds after review, use a deliberately limited scope with documented approval and a stopping condition. Test a purchase and the provider-supported refund process before offering the option broadly. Keep credentials, wallet access and destination changes under controlled permissions.

Compare the result with the original business need using complete costs and unresolved exceptions. If conventional payment methods solve the problem more simply, that is a useful conclusion. A sound evaluation explains the operational tradeoff and leaves a clear record of the decision rather than relying on enthusiasm for a technology category.

Sources and next steps

Primary reference: FinCEN’s virtual-currency business-model guidance. Use the current resource and confirm implementation details with the provider or appropriate adviser.

Related reading: B2B Payments: Connect the Invoice, Remittance and Bank Record; Instant Funding: Compare Availability, Fees and Reconciliation.

For the wider operating context, continue to the Florida, New York and New Jersey business guides on All State Merchants. Its state and local resources complement the payment workflow discussed here.

Eric Kuvykin writes about payments, fintech and business operations. Browse the article library for additional practical guides.