How Companies like Amazon Could Issue Stablecoins Under the GENIUS Act: Corporate Digital Currency Opportunities and Blockchain Selection Guide

20. Jun 2025

The GENIUS Act of 2025 contains groundbreaking provisions that could enable major corporations like Amazon, Apple, or Google to issue their own regulated stablecoins. However, beyond regulatory compliance, these corporations face critical infrastructure decisions about which Layer 1 blockchain networks to deploy on—choices that could determine their stablecoin’s success or failure in the marketplace.

GENIUS Act Corporate Stablecoin Provisions: The Amazon USD Path

Section 4(a)(12): The Corporate Stablecoin Gateway

The GENIUS Act specifically addresses “Non-Financial Services Public Companies” in Section 4(a)(12), creating a regulated pathway for major corporations to enter the stablecoin market. This provision could fundamentally reshape digital payments by allowing trusted consumer brands to issue their own digital currencies.

Key Definition: The Act applies to any “public company that is not predominantly engaged in 1 or more financial activities,” which would include:

  • Amazon (e-commerce/cloud services)
  • Apple (technology/consumer electronics)
  • Google/Alphabet (technology/advertising)
  • Walmart (retail)
  • Microsoft (technology/software)

The Unanimous Approval Requirement

Unlike traditional financial institutions, corporations face a higher regulatory bar. Any non-financial public company must obtain unanimous approval from the Stablecoin Certification Review Committee, which includes:

  • Secretary of the Treasury (Chair)
  • Chair of the Federal Reserve Board
  • Chair of the FDIC

This committee must unanimously find that the corporate stablecoin will not pose material risk to:

  • U.S. banking system safety and soundness
  • Financial stability of the United States
  • The Deposit Insurance Fund

Critical Blockchain Infrastructure Decisions for Corporate Stablecoins

Layer 1 Selection: More Than Just Technical Specs

While the GENIUS Act sets regulatory standards, corporations and their customers must carefully evaluate which blockchain networks to deploy their stablecoins on. The choice impacts liquidity, security, operational risk, and long-term viability.

Current Stablecoin Market Distribution by Blockchain

Market Leadership by Volume (2024 Data)1:

  • Solana: $10.5 trillion in stablecoin transfers (leading all networks)
  • Ethereum: $7.8 trillion in stablecoin transfers
  • Tron: $5.4 trillion in stablecoin transfers
  • BNB Chain: $899 billion in transfers

Market Share by Stablecoin Supply2:

  • Ethereum: 49.1% of total stablecoin market cap
  • Tron: 34.8% of total stablecoin market cap
  • BNB Chain: 2.9% of total stablecoin market cap
  • Solana: 2.2% but growing rapidly (+107.1% in 2024)

Ethereum: The Established Infrastructure Leader

Advantages for Corporate Stablecoins

Market Dominance: Ethereum hosts 49.1% of all stablecoin market capitalization, making it the most established infrastructure. Major stablecoins like USDC and USDT have their primary liquidity pools on Ethereum.

Institutional Adoption: Ethereum’s mature DeFi ecosystem includes established institutions and enterprise-grade infrastructure. The network has $70+ billion in Total Value Locked (TVL).3

Security Track Record: Even after migrating to a Proof-of-Stake network in 2022, Ethereum has maintained strong security without major consensus failures or extended outages.

Regulatory Familiarity: U.S. regulators have the most experience overseeing Ethereum-based assets, potentially smoothing approval processes for corporate stablecoins.

Limitations and Risks

Higher Transaction Costs: Despite Layer 2 solutions, Ethereum main net transactions remain expensive during network congestion, potentially limiting microtransaction use cases.

Scalability Constraints: Ethereum processes a maximum of approximately 62 transactions per second on Layer 1.4

Complexity: Multi-layer ecosystem with various L2 solutions creates complexity for corporate implementation and user experience.

Solana: The High-Performance Alternative

Advantages for Corporate Stablecoins

Superior Performance: Solana can process 50,000-65,000 transactions per second with transaction costs of approximately $0.000015. This makes it ideal for high-frequency consumer transactions.

Growing Market Share: Solana recorded the highest stablecoin transfer volume in 2024 ($10.5 trillion) and became “the most active blockchain for stablecoin transfers.”

Corporate Adoption: Major companies like PayPal have launched PYUSD on Solana, and Stripe now accepts USDC payments on the network.

DeFi Momentum: Solana DEX trading volumes have consistently exceeded Ethereum’s, with $120.6 billion in weekly DEX volume versus Ethereum’s $24.7 billion.

Critical Security Concerns

Network Outage History: Solana has experienced seven major outages since 2021, including a five-hour outage in February 2024.6 While the network achieved over 40 weeks without outages in 2024, the history raises reliability questions for mission-critical corporate applications.

Centralization Risks: Solana uses a Proof-of-History (PoH) consensus mechanism that some critics argue is more centralized than traditional Proof-of-Stake systems. The network has approximately 1,000 validators compared to Ethereum’s larger validator set.

Restart Procedures: When outages occur, Solana requires manual coordination among validators through Discord channels to restart the network, creating operational dependencies that may concern corporate risk managers.

Chain Fork and Consensus Risks

Liveness vs. Safety Trade-offs: Solana prioritizes safety over liveness, meaning “the network will halt in cases of extreme network stress or consensus failure rather than risk state corruption.”7 While this protects funds, it can disrupt corporate payment systems.

Recovery Complexity: Network restarts require off-chain consensus among validators to agree on rollback points, creating potential governance disputes during critical periods.

BNB Chain: The Exchange-Backed Option

Advantages for Corporate Stablecoins

Binance Ecosystem Integration: Direct connection to the world’s largest cryptocurrency exchange by volume, providing immediate liquidity access.

Low Costs: 3-second block times and transaction fees around $1 for complex operations like USDT transfers.

EVM Compatibility: Full Ethereum Virtual Machine compatibility allows easy migration of existing smart contracts and tooling.

Stable Performance: BNB Chain has maintained consistent uptime without the outage issues experienced by Solana.

Limitations and Risks

Centralization Concerns: BNB Chain uses Proof-of-Staked Authority (PoSA), which is more centralized than pure Proof-of-Stake systems.

Regulatory Risk: Binance faces ongoing regulatory scrutiny in multiple jurisdictions, creating potential compliance complications for corporate issuers.

Limited DeFi Ecosystem: $5.0 billion stablecoin market cap compared to Ethereum’s dominance suggests more limited DeFi integration opportunities.

Declining Market Share: BNB Chain’s stablecoin market share dropped from 3.5% to 2.9% in 2024, indicating potential loss of momentum.

Tron: The Efficiency-Focused Network

Advantages for Corporate Stablecoin

Low-Cost Transactions: Extremely low transaction fees make Tron suitable for micropayments and high-frequency transactions.

Established Infrastructure: Mature ecosystem with proven stablecoin custody and management tools.

Limitations and Risks

Limited Corporate Adoption: Tron has seen less institutional and corporate adoption compared to Ethereum and Solana.

Reputation Challenges: Historical controversies around plagiarism accusations and founder Justin Sun‘s multiple conflicts of interest may complicate corporate partnerships.

Regulatory Uncertainty: Less regulatory clarity compared to more established U.S.-focused networks.

Multi-Chain Deployment Strategy

Benefits of Multi-Chain Approach

Risk Diversification: Deploying across multiple networks reduces single-point-of-failure risks from network outages or security vulnerabilities.

Market Access: Different blockchains serve different user bases and geographical markets, maximizing potential adoption.

Liquidity Optimization: Multiple networks provide more diverse liquidity sources and trading venues.

Implementation Challenges

Operational Complexity: Managing stablecoin reserves, compliance, and technical infrastructure across multiple chains increases operational burden.

Regulatory Complications: Different blockchain networks may face varying regulatory treatment, complicating compliance strategies.

Security Multiplier: Each additional blockchain deployment multiplies security requirements and potential attack vectors.

Corporate Stablecoin Requirements Under GENIUS Act

Mandatory Data Privacy Protections

Corporate stablecoin issuers must comply with strict rules stating that nonpublic personal information from stablecoin transactions cannot be:

Prohibited Uses (unless consumer consents):

  • Used to target, personalize, or rank advertising
  • Sold to any third party
  • Shared with non-affiliates

Permitted Uses:

  • Compliance with federal, state, or local laws
  • Responding to civil, criminal, or regulatory investigations
  • Judicial process or government regulatory authority requirements

Anti-Tying Prohibitions

Corporate issuers must comply with strict anti-tying provisions preventing them from:

  • Requiring customers to obtain additional paid products as a condition of stablecoin services
  • Forcing customers to avoid competitor products
  • Bundling stablecoin access with other corporate services

Standard Compliance Requirements

Reserve Backing: Maintain 1:1 backing with approved assets including:

  • U.S. coins, currency, and Federal Reserve deposits
  • Treasury bills with 93 days or less maturity
  • Demand deposits at insured banks
  • Government money market funds

Audit Requirements: For issuers over $50 billion outstanding:

  • Annual audited financial statements
  • Monthly reserve certifications by registered accounting firms
  • Public disclosure of reserve composition

Investment and Risk Analysis by Blockchain

Ethereum-Based Corporate Stablecoins

Investment Implications:

  • Higher institutional confidence due to regulatory familiarity
  • Access to largest DeFi liquidity pools
  • Premium positioning possible due to security reputation

Risk Profile:

  • Higher operational costs may reduce profitability
  • Competition with established stablecoins (USDC, USDT)
  • Scalability limitations for mass consumer adoption

Solana-Based Corporate Stablecoins

Investment Implications:

  • Rapid user adoption potential due to superior performance
  • Lower operational costs enable competitive fee structures
  • Early mover advantage in high-growth ecosystem

Risk Profile:

  • Network reliability concerns for mission-critical applications
  • Potential service disruptions during outages
  • Greatest infrastructure risk but highest growth potential

Multi-Chain Corporate Stablecoins

Investment Implications:

  • Risk diversification across network failures
  • Maximum market penetration and user access
  • Ability to optimize for different use cases per network

Risk Profile:

  • Significantly higher operational complexity
  • Multiplied regulatory compliance requirements
  • Higher development and maintenance costs

Market Outlook: Corporate Stablecoin Adoption Timeline

Phase 1 (2025-2026): Early Adopters

Most Likely Corporate Candidates:

  • Amazon: Extensive payments infrastructure and regulatory compliance experience
  • Apple: Established mobile payments ecosystem and privacy-focused brand
  • PayPal: Existing cryptocurrency expertise and payment platform integration

Expected Blockchain Choices:

  • Conservative adopters likely to choose Ethereum for regulatory clarity
  • Performance-focused companies may select Solana despite reliability concerns
  • Multi-chain strategies for corporations with diverse use cases

Phase 2 (2026-2027): Market Maturation

Competitive Dynamics:

  • Blockchain performance becomes key differentiator for consumer-facing applications
  • Security track records increasingly important for institutional adoption
  • Regulatory preferences may emerge favoring specific blockchain networks

Market Consolidation:

  • Successful corporate stablecoins likely to gain significant market share
  • Traditional stablecoin issuers face increased competition from trusted consumer brands
  • Network effects favor early successful implementations

Strategic Recommendations for Corporate Stablecoin Investors

For Individual Investors

Blockchain-Aware Investment Strategy:

  • Ethereum-based corporate stablecoins: Prioritize for conservative portfolios seeking regulatory clarity
  • Solana-based corporate stablecoins: Consider for growth portfolios accepting higher technical risk
  • Multi-chain corporate stablecoins: Evaluate for balanced exposure to blockchain infrastructure diversity

Risk Management:

  • Monitor network uptime and security metrics for chosen blockchain platforms
  • Understand potential service disruptions from infrastructure dependencies
  • Consider geographic and regulatory factors affecting blockchain adoption

For Institutional Investors

Due Diligence Framework:

  • Evaluate corporate issuers’ blockchain selection rationale and technical capabilities
  • Assess operational risk management for chosen blockchain infrastructure
  • Review disaster recovery and business continuity plans for network outages

Portfolio Construction:

  • Diversify across blockchain networks to reduce single-network dependency
  • Weight investments based on corporate issuers’ technical sophistication and risk management
  • Monitor regulatory developments affecting specific blockchain networks

Conclusion: The Infrastructure-Dependent Future of Corporate Digital Currency

The GENIUS Act’s corporate stablecoin provisions represent more than regulatory innovation—they herald an era where infrastructure choices determine competitive success. While comprehensive federal oversight provides consumer protection and market stability, the underlying blockchain technology creates new categories of operational and technical risk.

For Amazon and other potential corporate issuers, blockchain selection becomes a strategic decision comparable to choosing cloud infrastructure or payment processors. Ethereum offers regulatory familiarity and institutional confidence but may limit scalability. Solana provides superior performance and growth potential but introduces reliability concerns that could disrupt mission-critical payment systems.

The historical parallel to wildcat banking remains relevant: just as the National Banking Act created winners and losers through standardization, the GENIUS Act’s interaction with blockchain infrastructure will likely favor corporations that make optimal technical choices early in the regulatory transition.

For investors and consumers, the key insight is that corporate stablecoin success depends on both regulatory compliance and infrastructure reliability. The most successful corporate digital currencies will likely be those that balance regulatory certainty with technical performance—a combination that may require sophisticated multi-chain strategies rather than single-network deployments.

The transition from unregulated “wildcat stablecoins” to federally supervised corporate digital currencies represents not just regulatory compliance, but the beginning of infrastructure-dependent competition where blockchain performance, security, and reliability determine market winners in the new era of corporate digital money.

This analysis is provided for informational purposes only and does not constitute investment or legal advice. Corporate stablecoin investments carry risks including regulatory denial, network outages, security vulnerabilities, and potential loss of value. Blockchain infrastructure choices involve technical risks that could impact stablecoin functionality and market acceptance. Consult qualified legal, technical, and financial advisors before making investment decisions.

About Burrell Law, P.C.: Our digital asset attorneys specialize in GENIUS Act compliance and blockchain infrastructure considerations for corporations considering stablecoin issuance. We provide comprehensive legal guidance for corporate digital currency strategies including multi-chain deployment risk assessment. Visit burrell-law.com for expert consultation on cryptocurrency regulations and blockchain infrastructure decisions.

  1. Stablecoin Trends: Solana’s $10.5 Trillion Transfer Volume in 2024
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  2. Ethereum and Tron Dominate Stablecoins With 83.9% Share | CoinGecko
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  3. Ethereum – DefiLlama
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  4. Fastest Blockchains by TPS [2025] | Chainspect
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  5. Ibid. ↩︎
  6. History of Solana’s Network Outages Since Its Inception
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  7. A Complete History of Solana Outages: Causes and Fixes ↩︎