The numbers leave little room for interpretation. Business-to-business stablecoin payments now account for roughly 60% of identifiable real-economy stablecoin volume, with monthly flows exceeding $6 billion by mid-2025. A joint analysis by McKinsey and Artemis Analytics puts the 2025 total at $390 billion in adjusted stablecoin payments, more than double 2024 levels, with B2B transactions comprising the majority of that growth. The trajectory is structural, not speculative.
For bilateral OTC desks handling institutional crypto and FX flows, this shift creates an operational problem that cannot be solved with better reporting or faster reconciliation. When a corporate treasury executes a stablecoin-settled transaction, they increasingly expect what stablecoins promise: atomic settlement, segregated control, and cryptographic proof of delivery. What they often receive instead is exposure to a custodial intermediary, typically a pooled balance held on an exchange, where their funds are commingled with other client assets and subject to the solvency of a third party.
This is not a hypothetical concern. The collapse of FTX in 2022 exposed what happens when custodial balances become unsegregated claims in bankruptcy. An $8 billion shortfall emerged because customer deposits had been commingled with proprietary trading operations. The bankruptcy proceedings revealed, in the words of restructuring expert John Ray III, "no record-keeping whatsoever" and a complete failure to segregate client assets. Post-FTX surveys found that 47% of institutional crypto derivatives participants cited counterparty risk as their primary concern, more than operational, liquidity, or market risk combined.
The industry response has been to demand separation. More than three-quarters of surveyed institutional participants now expect a permanent separation of exchange and custody functions. In the United States, the GENIUS Act, signed into law in July 2025, codifies requirements that stablecoin issuers maintain 1:1 reserve backing with liquid assets and prohibits rehypothecation of reserves. The law requires reserves to be "segregated and not commingled with the issuer's operational funds." These provisions apply to issuers, but they set the institutional expectation: segregation is the standard.
Yet for OTC brokerages, the operational reality often diverges from this expectation. Client flows still route through exchange accounts where the brokerage maintains a pooled balance. Settlement happens on ledger, an internal credit, not an on-chain transfer. When a client asks for physical delivery of stablecoins to their own wallet, the brokerage must unwind its position from the exchange, execute the on-chain transfer, and demonstrate that the assets in question belonged to that client all along. If the exchange fails between instruction and settlement, the client's claim becomes an unsecured creditor position in bankruptcy, not a proprietary right to segregated assets.
The mismatch becomes particularly acute when institutional counterparties require proof of reserves or on-chain attestation. Qualified custodians in traditional finance provide segregated accounts, bankruptcy remoteness, and regular attestations precisely because these protections are what make assets "held" rather than "owed." In digital asset custody, this means on-chain segregation, client holdings visible on a public ledger, cryptographically distinct from the custodian's own assets. Pooled exchange balances cannot provide this. The assets exist, but they exist as a claim against the exchange, not as a segregated position the client can verify independently.
The competitive dimension is straightforward. As B2B adoption accelerates, the corporate treasuries and asset managers entering stablecoin markets bring expectations shaped by traditional custodial infrastructure. They expect their assets to be held in their name, verifiable on demand, and insulated from the operational or credit risk of intermediaries. The SEC's custody rule requires registered investment advisers to maintain client assets with qualified custodians who provide exactly these protections: segregation, audit, and legal clarity on ownership. When an OTC desk cannot demonstrate equivalent protections for stablecoin holdings, it becomes a counterparty risk the client may choose not to accept.
The institutional custody market is responding. State-chartered trust companies now offer digital asset custody with on-chain segregation, SOC 2 certification, and bankruptcy-remote structures. MPC-based wallet infrastructure enables segregated wallets for each client while maintaining operational efficiency. Proof-of-reserve systems provide real-time verification of asset backing without exposing sensitive wallet details. These solutions exist, the question is whether OTC desks integrate them or continue routing flows through architectures designed for a different era.
The decision facing heads of operations and risk officers is not whether to abandon exchange relationships. Exchanges provide liquidity, price discovery, and execution efficiency that remain essential. The question is whether the custody model sitting behind those execution flows can satisfy the demands of institutional counterparties who now expect their stablecoin holdings to be segregated, verifiable, and protected from intermediary insolvency. For desks that built their infrastructure when stablecoins were a settlement convenience rather than a delivery obligation, the answer may require more than incremental adjustment.
The regulatory direction is clear. The GENIUS Act's segregation requirements, the SEC's custody guidance issued in December 2025, and MiCA's mandate for on-chain client asset segregation all point toward the same standard. Stablecoin custody will increasingly look like traditional qualified custody, with the added requirement of on-chain verifiability. Brokerages that treat custody as a back-office function rather than a client-facing capability may find that institutional counterparties make the decision for them.
References
[2] U.S. Congress, S.1582 - GENIUS Act of 2025
[3] Richmond Federal Reserve, "Stablecoins and the GENIUS Act: An Overview," November 2025
[4] Bloomberg, "Stablecoin Transactions Rose to Record $33 Trillion in 2025," January 2026
