Overview

A stablecoin product can be ready to build long before the company is ready to launch it legally. The licensing path determines how quickly a team can enter a market, which activities it can offer, and how much of the customer and compliance workflow it can control. Choosing the wrong structure can mean redesigning the product later or spending months, sometimes years, pursuing a license that does not match the original launch plan.

The panel's view: for most fintechs, a licensed partner is the faster route to market, and your own license makes sense once the business model is stable. Episode 14 of the Stablecoin Builder Series focuses on how to make that decision earlier. Shahar Friedman, Head of Payments at Utila, is joined by Patrick Murck of Surus, Bertrand Godin of Fipto, Vilius Semenas of CoinGate, and George Bordianu of Balance. The four companies are launch partners of Utila's Licensed Partner Network, and the discussion covers when to get your own license, when to launch through a licensed provider, and how those choices affect the product you can actually put in market.

Key Takeaways

Stablecoin licensing strategy needs to come before the build

The regulated activity matters more than the label attached to the product. A team needs to understand which role it will perform, which licenses that role requires, and where it intends to operate before committing to a licensing path. George Bordianu's first questions: are you an issuer, which kind, which exemptions do you qualify for, and which registrations can you not avoid? Bertrand Godin warned that choosing the wrong jurisdiction or structure can cost a company one or two years before it gets back on the right track.

A licensed partner can shorten the path to market while your MiCA application is pending

Building your own regulatory capability takes time, capital, and an operating team capable of maintaining it after approval. MiCA is harmonized on paper, but Vilius Semenas pointed out that getting licensed in Lithuania, France, the Netherlands or Germany are very different experiences in practice. For products where stablecoins are one part of a broader offering, he argued that launching through a partner can be a valid route while the company develops its longer-term regulatory strategy. The two paths can also run in parallel rather than being treated as a permanent either-or decision.

What a licensed partner covers, and what stays with you

A licensed provider remains responsible for the regulated activity it performs. That can include customer onboarding, transaction monitoring, screening, and other controls required under its authorization. The product company still has work of its own: Bertrand Godin noted that in France, a one-time code is not enough to authenticate a customer, and the customer has to get a notification showing what they are approving each time. The product company therefore needs to understand exactly where responsibility sits before designing the customer journey around the partnership.

Full white-label models have regulatory limits

A fintech may want the licensed provider to remain invisible to the end customer, but that is not always compatible with the regulatory structure. George Bordianu noted that a licensed entity needs visibility into activity carried out under its authorization. Customer agreements, disclosures, onboarding steps, or information-sharing requirements can therefore become part of the product design rather than something that can simply be removed for UX reasons.

Regulation can change the payment flow itself

Licensing affects more than legal documents. Vilius Semenas used the European Travel Rule as an example of a requirement that can change how a fintech designs on-ramping, off-ramping, transfers, and the exchange of customer information. Teams that define the user flow before understanding those requirements can end up rebuilding important parts of the product.

Partner infrastructure can be modular

Working with a regulated provider does not necessarily mean handing over the entire product. Patrick Murck described a model where clients can use a complete regulated stack or select only the capabilities they need. That allows a company to retain parts of the operating model it wants to own while using a partner for regulated functions that would otherwise delay launch.

Licensed partners across the EU, US and Canada

Together, the four launch partners of the Licensed Partner Network cover the EU, the US and Canada:

The GENIUS Act opens a state path for US stablecoin issuers

Money transmission in the US means a separate license in roughly 47 states and territories, and Patrick Murck said the bigger cost comes after approval: managing that many regulators every year. The GENIUS Act gives stablecoin payments a clearer national path. Patrick described Surus, a North Carolina chartered trust company, as a state-path issuer under the Act. Patrick's point for product teams was that you no longer need your own charter to issue: working with a GENIUS Act issuer lets you bring your token to market and keep most of the economics.

Expanding into a new market needs its own business case

A license in one jurisdiction does not automatically create a workable model somewhere else. Regulatory expectations, banking relationships, compliance requirements, and licensing economics change between markets. George Bordianu argued that an expansion should be funded like a separate startup, with its own P&L and three to four years of runway, rather than depend on favorable market conditions to justify its cost. Patrick Murck added the counterexample: Remitly started with one money transmitter license covering Washington, Oregon and Idaho and one corridor, then grew state by state.

Maintaining a license is part of the decision

Getting the license is only the beginning. Vilius Semenas pointed to the growing staffing and compliance burden associated with maintaining regulated operations in Europe. Ten years ago a Lithuanian e-money license could be run by four or five people. Today it is hard to get one with twenty. Teams deciding whether to own a license need to account for the ongoing organization required to run it, not only the application timeline.

Plan the move to your own license from day one

Launching through a partner and later getting your own license is a common path, and the panel agreed it should be planned for from the start. Bertrand Godin's advice was technical: build with modular services rather than a monolith, so the partner can be unplugged and replaced without rebuilding the product. Patrick Murck's advice was about the regulator: start your compliance program early, integrate KYC, staff it, and be ready to show exactly how the business makes money. A company that can show a working business and a working compliance program has a much easier application. George Bordianu said Balance has no interest in locking clients in, and the network is set up so a client can move activities in-house when its model is stable.

Frequently Asked Questions

How long does it take to get a stablecoin license?

It depends on the activity and the jurisdiction. George Bordianu put money transmission, payment services and regulated custody licensing at [CONFIRM: four / fourteen] months at the fastest, and has seen companies spend $10 to 20 million and one to two years on trust charters before launching any product.

Does a state-qualified issuer license give permitted status before Treasury certifies the state?

Not on its own. Under the GENIUS Act, Treasury has to certify that a state's regime closely mirrors the federal standard, and Patrick Murck said those criteria were still in the comment and review period at the time of the session. Some states, North Carolina among them, have already passed legislation, often grandfathering existing trust banks and banks. Once a state is certified, issuers there are supervised by their state regulator rather than the Federal Reserve or the OCC, which usually means lower costs for clients.

Can a licensed partner collect card payments and settle in stablecoins for remittances?

Usually yes, but the hard part is not the remittance. George Bordianu said sending stablecoins to a corridor such as the Philippines or Africa mostly involves diligence, Travel Rule data and record keeping. The harder piece is collecting third-party card payments and moving them into an FBO account to convert into stablecoins, because that depends on the partner's banking providers being comfortable with the flow. Expect a case-by-case review of your business model.

Does MiCA's "reception and transmission of orders" rule limit what financial institutions can offer with a CASP?

It can. Bertrand Godin called it the main issue Fipto faces when selling to financial institutions: in France, a payment institution that asks a CASP to buy stablecoins for its own client is likely to fall under this MiFID-derived service. Claiming to be a technical provider is hard to defend if the institution takes a revenue share. Vilius Semenas said CoinGate designed its product so financial institutions do not intermediate orders, and that plain stablecoin transfers are easier to structure than on and off-ramping or relaying end-user instructions.

Key Speaker Insights

Patrick Murck, CEO, Surus

“It’s not just time to market, it’s complexity to market.”

Explaining why the licensing decision involves the ongoing cost of operating across regulators as well as the time required to get approval.

Vilius Semenas, CEO, CoinGate

“I think the partner path is very valid.”

Discussing why companies can launch through regulated infrastructure while developing their own licensing capability, particularly when stablecoins are a feature rather than the core product.

Bertrand Godin, Co-founder & COO, Fipto

“If you go to the wrong country, to the wrong strategy, you’re going to lose one, two years.”

Warning teams to work through their licensing strategy before committing capital and product development to a particular jurisdiction.

Patrick Murck, CEO, Surus

“We have the entire stack available for them. And then it’s also modular.”

Explaining how companies can use a licensed provider for selected parts of the regulated stack rather than treating the partnership as an all-or-nothing model.

George Bordianu, Co-founder & CEO, Balance

“There’s no universe in which the entity with the licensing doesn’t have visibility over the activities if you’re dealing with regulated services.”

Addressing the tension between a completely white-labeled customer experience and the oversight a licensed provider needs to retain.

Vilius Semenas, CEO, CoinGate

“Do you have the team to run that license and to maintain it?”

Highlighting the operating commitment that comes after a company receives regulatory approval.

Bertrand Godin, Co-founder & COO, Fipto

“It’s always better to lose one month at the beginning than making a wrong step.”

Summarizing why the licensing model should be worked out before the company commits to a market, regulatory structure, or product flow.