
While bank boards in 2026 are rightfully obsessed with the regulatory hurdles of stablecoin integration and AI-driven compliance, as the GENIUS act finds its foothold within the U.S., a more quiet and efficient revolution is occurring in the shadow economy. It is time we stop viewing
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Traditional banking compliance is currently ill-equipped to handle this level of speed and scale. I have deep respect for how regulations diverge across jurisdictions, having delivered products under the divergent rules of the U.S., Canada, Brazil and the EU. Yet, these regulatory frameworks move at a human pace, while DaaS platforms operate in real time. By the time a suspicious wallet address is flagged and blacklisted, the DaaS franchisee has already moved the assets through a decentralized mixer and spun up ten new domains.
To counter this, the banking industry must move beyond reactive compliance and toward architectural resilience. Instead of relying solely on static blacklists, we must treat fraud detection as a versioned, observable service in our architecture, utilizing machine learning to detect behavioral patterns such as the reuse of specific device fingerprints or anomalous settlement profiles.
In a new interpretive letter, the Office of the Comptroller of the Currency will allow banks to serve as middlemen for "riskless" crypto trades, extending existing brokerage authority for securities to digital assets.
We also need to implement technical patterns that protect consumers at the protocol level. For example, we should use "circuit breaker" patterns to gracefully prevent cascading issues across every critical flow in the payments ecosystem. A similar philosophy should be applied to wallet interactions. If a transaction signature deviates from a user's typical behavior — much like how we monitor for rent payment anomalies — the system should trigger an architectural circuit breaker that pauses the transaction before the funds leave the institutional custody.
As we plan for new rails, such as the stablecoin settlement projects, we cannot ignore the massive risk of DaaS. The goal is to improve settlement economics and shift costs, but doing so without a robust defensive platform is an invitation to disaster. We must co-create product road maps with risk and compliance teams, ensuring that engineering is a co-owner of the outcome.
The competition is no longer between banks; it is between platforms. The DaaS operators have built high-scale, real-time organizations that partner closely with their own versions of product and risk management. If we are to survive this shift, we must stop treating security as a checkbox and start treating it as a core architectural competency. We must build high-performing, resilient systems that can out-scale the industrialization of theft. Only by adopting an ownership mindset and applying first-principles thinking to our infrastructure can we hope to protect the future of the global payments value chain.






