By Eric Kuvykin. Substantially revised October 17, 2026. The original publication date and URL are retained.
Describe the transaction in ordinary business terms
Before a merchant tests a stablecoin payment option, it should be able to explain what the customer owes, what the business receives and which company performs any conversion. The record should distinguish the customer’s asset transfer from the merchant’s eventual proceeds.
This is a pilot-record checklist, not a recommendation to accept a token or use a particular provider. Current legal, tax and accounting questions require qualified advice based on the actual arrangement. A product’s marketing label should not substitute for that review.
Define the price and conversion record
Ask the provider which currency denominates the sale, when any conversion is calculated and which fees appear separately. Preserve the quotation or rate reference used for the transaction where appropriate. Determine how the order record links to the provider’s transfer and payout references.
Test a case in which the customer pays less or more than expected. Ask how the system detects the difference, who contacts the customer and how the order is held while it is unresolved. Avoid having staff improvise a second payment request without checking the first transfer’s status.
Write the refund questions before the policy
Ask whether a supported refund returns the original asset, an amount based on another denomination or conventional currency through a separate process. Have advisers review the customer-facing policy and the provider demonstrate the actual behavior. Do not assume a refund can simply reverse every earlier technical step.
Record who can approve a refund destination and how a customer request to change it is verified. Preserve the original request and approval. Destination changes deserve controlled handling rather than an instruction copied from an unexpected message.
Test the full record chain
FinCEN’s business-model guidance is a primary resource for understanding why the proposed activity matters to regulatory analysis. It does not establish that a particular merchant pilot is permitted or that a provider’s claimed status covers every service. Verify material provider claims through appropriate official sources and advisers.
For an operation serving Florida, New York and New Jersey, identify the accepting entity and the jurisdictions advisers need to examine. Keep the contractual parties and responsibilities explicit before expanding the pilot.
Have the accountant reconcile a sample purchase, fee, payout and refund using the proposed reports. If the records cannot explain the completed cycle, resolve that gap before accepting real customer transactions. A useful pilot produces evidence about the operating workflow, including the reasons not to proceed.
References and related reading
Primary resource checked for this review: FinCEN’s virtual-currency business-model guidance. Confirm the current requirements and implementation with the responsible provider or appropriate adviser.
Continue with Stablecoin Payments: Due-Diligence Questions Before a Merchant Pilot and B2B Payments: Connect the Invoice, Remittance and Bank Record.
For state and local business resources alongside this operating checklist, use the Florida, New York and New Jersey reading paths on All State Merchants.
