The opportunity
The stablecoin market holds $150B+ in circulating supply (USDC, USDT, and newer entrants). Every existing dollar-pegged instrument is fully transparent: merchants can surveil your spending history, counterparties can observe your balance, and on-chain analytics firms build profiles from your transaction graph. A stablecoin issuer with existing MSB licensing can deploy shyware as a “private mode” with no new regulatory obligations:- Merchants see a payment — not your balance or history
- Issuer retains the account registry for FinCEN subpoena response
TotalSupplyis publicly auditable — no fractional reserve risk- The two-list invariant is enforced by canonical consensus and the shared managed signing boundary
Architecture
FinCEN compliance mapping
| Regulatory requirement | shyware mechanism |
|---|---|
| Customer identification (KYC/AML) | Account registration requires wallet ECDSA proof; issuer holds off-chain KYC record linked to account_commitment |
| Transaction monitoring | Issuer queries admin API for account history on demand (reactive, not proactive) |
| SAR filing | Issuer’s compliance team accesses full records via admin SDK under standard MSB obligations |
| Travel Rule (31 CFR § 103.33) | Transfer metadata (amount, timestamp, asset) stored in List 1; sender/recipient linkage available to issuer under legal process |
| Supply auditability | GET /supply/{asset_id} is public; total_supply == total_minted - total_burned enforced by BFT consensus |
Deployment steps
Stand up the node
Deploy the canonical validators on your current sensitive/core hosting tier.
The current long-term posture is Verne Global for sensitive/core hosting,
Cloudflare at the front door, and the shared
AWS KMS + Azure Managed HSM
boundary for managed signing.Integrate account registration into your onboarding flow
When a user completes KYC, your backend:
- Receives
account_commitment = H(wallet_address)from the user’s wallet SDK - Posts
TxTypeRegisterAccountto the node - Stores
(account_commitment, kyc_record_id)in your compliance database