Stablecoin Settlement Guide
Stablecoin Settlement Guide
USDC · PYUSD · GENIUS Act Compliance · End-to-End Purchase Flow · On-Chain Settlement
How ST22 Digital Securities purchases settle on the RWA Tokens platform. All transactions — primary offerings and secondary CEDEX trades — settle through GENIUS Act-compliant stablecoins. No fiat wire transfers. No SOL or other cryptocurrency. This page explains which stablecoins are accepted, why stablecoins were chosen over alternatives, how an investor goes from dollars in a bank to ST22 tokens in a wallet, and the on-chain settlement mechanics that apply uniformly across all three production modules: Equities (Module 1), Real Estate (Module 2), and CORECM — Carbon Ore, Rare Earth, and Critical Minerals (Module 3).
Settlement is module-agnostic at the technical level. The same USDC and PYUSD primitives, the same atomic-settlement architecture, and the same fee distribution apply to every ST22 token regardless of which module issued it. Module-specific behavior arises only from offering structure (Reg CF flow for Module 1) and module-aware Transfer Hook controls (NAV-deviation breaker for Module 2; federal-action freeze for Module 3).
Table of Contents
Settlement Architecture
Accepted Stablecoins
Why Stablecoins — Not Fiat, Not Crypto
GENIUS Act Compliance
End-to-End Purchase Flow — Primary Offering
End-to-End Purchase Flow — Secondary Trade
Fiat On-Ramp Options
On-Chain Settlement Mechanics
Settlement Finality
Fee Application During Settlement
Stablecoin Risk Framework
CTR and BSA Implications
Developer Integration
Module-Specific Settlement Considerations
Investor FAQ
1. Settlement Architecture
Key Property — Atomic Settlement
The stablecoin transfer and the ST22 token transfer execute in the same Solana transaction. If either side fails — Transfer Hook rejection, insufficient balance, oracle staleness, NAV-deviation breaker active (Module 2), federal-action freeze active (Module 3) — the entire transaction reverts. No partial settlement is possible.
This atomicity is the structural difference between blockchain settlement and traditional securities settlement. T+1 in DTCC requires reconciliation, fails-management, and counterparty risk monitoring; ~13-second on-chain settlement either completes both legs or completes neither.
2. Accepted Stablecoins
StablecoinIssuerBackingSolana Mint AddressProgramDecimals
USDC
Circle
USD reserves + short-duration US Treasuries
EPjFWdd5AufqSSqeM2qN1xzybapC8G4wEGGkZwyTDt1v
SPL Token
6
PYUSD
Paxos (for PayPal)
USD deposits + US Treasuries + overnight repos
2b1kV6DkPAnxd5ixfnxCpjxmKwqjjaYmCZfHsFu24GXo
SPL Token
6
Why These Two
CriterionUSDCPYUSDUSDT (not accepted)
GENIUS Act compliant
Yes — Circle is a registered money transmitter
Yes — Paxos is NYDFS-regulated trust company
Pending — Tether's reserves composition is less transparent
US-regulated issuer
Yes — Circle (US entity)
Yes — Paxos (NY-regulated)
No — Tether (BVI-domiciled)
Reserve transparency
Monthly attestations by Deloitte
Monthly attestations by WithumSmith+Brown
Quarterly reports, historically contested
Solana native
Yes — native SPL Token mint
Yes — native SPL Token mint
Yes, but regulatory profile insufficient
Institutional acceptance
Widest — used across regulated financial products
Growing — PayPal distribution network
Limited institutional adoption in regulated products
The platform accepts only GENIUS Act-compliant stablecoins from US-regulated issuers with transparent reserve attestations. This is a regulatory-architecture decision, not a technical limitation. Adding additional stablecoins is governance-gated and requires compliance review, GENIUS Act qualification, and a 5-of-9 multi-signature update to the Network Configuration.
3. Why Stablecoins — Not Fiat, Not Crypto
Why Not Fiat Wire Transfer
IssueDetail
Speed
Wire transfers take 1–5 business days. Stablecoin settlement: ~13 seconds.
Availability
Wire transfers operate during banking hours (M–F). CEDEX trades 24/7/365.
Atomic settlement
Wire plus token delivery cannot execute atomically. Creates settlement risk (investor sends wire, tokens not delivered; or vice versa). Stablecoin plus ST22 settle in the same Solana transaction.
Global access
International wires are expensive ($25–$50), slow (3–5 days), and involve correspondent-banking friction. USDC and PYUSD are global by design.
Reconciliation
Wire transfers require manual reconciliation between bank statements and on-chain records. Stablecoin settlement is self-reconciling — the on-chain record IS the settlement record.
Why Not SOL or Other Cryptocurrency
IssueDetail
Price volatility
SOL, BTC, and ETH fluctuate significantly intraday. An investor subscribing $100,000 in SOL could receive $90,000 or $110,000 of value depending on the hour. Stablecoins maintain $1.00 ± 0.01 parity.
Issuer proceeds
Issuers need predictable USD proceeds for operations. Receiving volatile crypto creates treasury-management complexity and FX risk.
Reg D / Reg CF compliance
Subscription amounts must be denominated in USD for Form D and Form C filings, and accreditation thresholds ($200K income / $1M net worth) and Reg CF investment limits are USD-denominated.
GAAP accounting
Cryptocurrency accounting is complex (ASC 350-60 intangible-asset treatment). Stablecoins are treated as cash equivalents.
GENIUS Act alignment
The GENIUS Act establishes a federal framework for payment stablecoins. Using compliant stablecoins positions the platform within this framework.
Why Stablecoins Are the Right Answer
Stablecoins provide the speed and atomicity of on-chain settlement with the price stability of USD. The combination is unique — no other instrument provides sub-second, 24/7, globally accessible, programmatically-settleable, price-stable value transfer.
4. GENIUS Act Compliance
What the GENIUS Act Does
The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) establishes a federal framework for "payment stablecoins" — digital assets pegged to the US dollar, issued by regulated entities, backed by qualifying reserves, and redeemable at par.
GENIUS Act Requirements for Payment Stablecoins
RequirementUSDCPYUSD
Issued by licensed entity
Circle — state money transmitter licenses + pending federal registration
Paxos — NYDFS-regulated trust company
Backed by qualifying reserves
USD deposits, US Treasury bills, overnight repos
USD deposits, US Treasury bills, overnight repos
1:1 redeemable at par
Yes — redeem USDC for $1.00 USD on demand
Yes — redeem PYUSD for $1.00 USD on demand
Regular reserve attestations
Monthly by Deloitte (Big Four)
Monthly by WithumSmith+Brown (CPA firm)
Segregated reserves
Yes — reserves held separate from operating funds
Yes — held at regulated custodians
Why This Matters
Using GENIUS Act-compliant stablecoins means that the platform's settlement layer operates within a recognized federal framework — not in a regulatory grey area. When an investor purchases ST22 tokens with USDC, every component of the transaction has a regulatory home: the token (SEC Release No. 33-11412), the custody (Empire Stock Transfer §17A), the compliance enforcement (42 Transfer Hook controls), and the settlement currency (GENIUS Act).
This regulatory layering is part of the platform's Category 1 Model B compliance posture under the January 28, 2026 Joint Staff Statement.
5. End-to-End Purchase Flow — Primary Offering
The primary-offering flow varies slightly by exemption. The fundamental on-chain mechanics are identical; the verification gate at Empire and the documents executed differ.
5.1 Reg D (US Accredited) and Reg S (Non-US) Primary
5.2 Reg CF (US Retail) Primary
Reg CF offerings must be conducted through a FINRA-registered funding portal. The platform is currently evaluating funding-portal registration to support direct Reg CF issuances. Until that registration is in place, Reg CF offerings on the platform are conducted in partnership with an existing FINRA-registered funding portal that handles the offering origination and Form C filing.
The investor flow is structurally identical to Reg D / Reg S, with three differences at Empire's verification gate:
The same atomic-settlement architecture, same Transfer Hook 42 controls, same fee distribution, and same Empire MSF update apply.
6. End-to-End Purchase Flow — Secondary Trade
After the holding period elapses, investors trade ST22 tokens on CEDEX. Settlement is stablecoin-denominated regardless of module.
Sell Flow
Buy Flow
7. Fiat On-Ramp Options
The platform does not operate a fiat on-ramp directly. Investors acquire stablecoins through regulated third-party providers before interacting with CEDEX.
Recommended On-Ramp Providers
ProviderStablecoinsMethodsSolana Native?Speed
Coinbase
USDC
Bank transfer (ACH), wire, debit card
Yes — direct Solana USDC withdrawal
ACH 1–3 days; wire same day; card instant
Kraken
USDC
Bank transfer, wire, crypto deposit
Yes — Solana USDC withdrawal
Wire same day; ACH 1–3 days
PayPal
PYUSD
PayPal balance, bank, debit card
Yes — native PYUSD on Solana
Instant with PayPal balance
MoonPay
USDC
Credit/debit card, bank transfer, Apple Pay
Yes — direct to Solana wallet
Card instant; bank 1–3 days
Transak
USDC
Bank, card, Apple Pay, Google Pay
Yes — direct to Solana wallet
Card instant; bank 1–3 days
On-Ramp Flow
Important: On-Ramp KYC Is Separate from Empire KYC
The KYC performed by Coinbase, Kraken, or any other on-ramp provider satisfies that platform's regulatory requirements. It does not satisfy Empire Stock Transfer's investor verification requirements. Investors must complete Empire's full KYC / KYB / AML / OFAC / accreditation verification and wallet verification (KYW) separately before trading on CEDEX. Holding stablecoins in a Solana wallet does not grant CEDEX access — Empire's MSF registration does.
8. On-Chain Settlement Mechanics
Token Programs Involved
TokenProgramMint AddressRole in Settlement
USDC
SPL Token (original)
EPjFWdd5AufqSSqeM2qN1xzybapC8G4wEGGkZwyTDt1v
Payment currency
PYUSD
SPL Token (original)
2b1kV6DkPAnxd5ixfnxCpjxmKwqjjaYmCZfHsFu24GXo
Payment currency
ST22
SPL Token-2022
Per-issuer mint address
Security being traded
USDC and PYUSD use the original SPL Token Program (no Transfer Hook). ST22 tokens use SPL Token-2022 (with Transfer Hook). A CEDEX swap involves both token programs in a single transaction.
Transaction Composition
A complete CEDEX swap transaction contains multiple instructions. The structure is the same regardless of module — a Module 1, Module 2, or Module 3 ST22 swap composes identically:
Atomicity
Every instruction in the transaction executes or none do. If the Transfer Hook rejects the ST22 transfer — holding period not elapsed, OFAC match, wallet limit exceeded, NAV-deviation breaker active (Module 2), federal-action freeze active (Module 3) — the USDC transfer also reverts. The investor keeps their stablecoins. No partial settlement.
This is enforced at the Solana runtime level. There is no software path to a partially-completed settlement, regardless of which party tries to construct one.
9. Settlement Finality
StageTimingMeaning
Transaction submitted
0ms
Submitted to Solana via Jito Block Engine (MEV protection)
Processed
~400ms
Leader validator has processed — not yet safe
Confirmed
~400ms
2/3+ stake supermajority voted — CEDEX considers settled
Finalized
~13 seconds
32 confirmations — irreversible under all conditions
CEDEX uses confirmed commitment for displaying trade results to users and finalized commitment for fee distribution and Empire MSF updates. The practical settlement time for an investor is ~400ms (trade appears in portfolio) with full finality at ~13 seconds.
Comparison to Traditional Settlement
VenueSettlement TimeFinality
NYSE / NASDAQ
T+1 (next business day)
DTCC settlement
OTC Markets (OTCQB / OTCID / Expert Market)
T+2 (two business days)
Transfer agent
Other digital-securities platforms
T+0 to T+1
Platform-dependent
CEDEX
~13 seconds
Solana blockchain — irreversible
The CEDEX settlement time is a structural property of running on-chain. It is not faster because of optimization — it is faster because the architectural model collapses several DTCC-era steps (matching, clearing, settling, custody update) into a single atomic transaction.
10. Fee Application During Settlement
The 5% fee is applied within the settlement transaction — not as a separate charge.
Primary Offering
Secondary Trade
The 0.44% Global Pool allocation is the structural mechanism for monotonic pool deepening. Across all modules, every secondary trade adds to the Global Pool reserve. This is verified by Certora invariant E.3 (Global Pool non-extractability) — no instruction in any program can reduce the Global Pool balance.
11. Stablecoin Risk Framework
Stablecoins are not risk-free. The platform mitigates stablecoin-specific risks through architectural choices.
Risk Assessment
RiskDescriptionMitigation
De-peg risk
USDC or PYUSD trading below $1.00
Two accepted stablecoins — if one de-pegs, investors can use the other. CEDEX displays real-time peg status from Pyth Network.
Issuer insolvency
Circle or Paxos becomes insolvent
Both are US-regulated with segregated reserves. GENIUS Act requires qualifying reserve composition. Monthly reserve attestations.
Regulatory freeze
US government freezes stablecoin addresses
OFAC compliance — Empire screens all wallets via CIP/AML/KYW. Frozen stablecoin addresses cannot interact with CEDEX.
Smart-contract exploit
Vulnerability in USDC or PYUSD token program
Both use the battle-tested original SPL Token Program (not Token-2022). Years of production usage; multiple audits.
Blacklisting
Circle or Paxos blacklists a wallet address
Both stablecoins have issuer-level blacklist capability. The platform cannot prevent issuer-level action. Investors should maintain compliance with stablecoin issuer terms.
Redemption risk
Unable to convert back to USD
Both offer direct redemption. Coinbase, Kraken, PayPal, and other on-ramp providers offer liquid off-ramp.
De-Peg Circuit Breaker
If either accepted stablecoin deviates more than 2% from the $1.00 peg (as measured by Pyth Network oracle), CEDEX automatically halts acceptance of that stablecoin for new orders until the peg is restored. Existing positions are unaffected — the breaker prevents new trades from executing at distorted prices. The breaker is implemented as part of the Pyth-backed price-impact circuit-breaker check (CB-21).
12. CTR and BSA Implications
Currency Transaction Reports
CTR requirements (31 CFR §1010.311) apply when fiat currency is involved. Most platform transactions are stablecoin-based and do not trigger CTR filing.
Transaction TypeFiat Involved?CTR Applicable?
Investor buys USDC on Coinbase with bank transfer
Yes — at Coinbase
Coinbase files if ≥ $10,000
Investor transfers USDC to Solana wallet
No — stablecoin transfer
No CTR
Investor buys ST22 on CEDEX with USDC
No — stablecoin settlement
No CTR
Investor sells ST22 on CEDEX, receives USDC
No — stablecoin settlement
No CTR
Investor sells USDC on Coinbase for USD bank deposit
Yes — at Coinbase
Coinbase files if ≥ $10,000
BSA Obligations
Empire Stock Transfer's BSA obligations apply to all platform transactions regardless of settlement currency. SAR filing thresholds (≥ $5,000 suspicious activity) are evaluated on the USD-equivalent value of stablecoin transactions, not only on fiat transactions. Empire's CIP (31 CFR §1023.220), CTR (§1010.311), and SAR (§1023.320) procedures are documented in the AML Policy.
13. Developer Integration
Checking Investor's Stablecoin Balance
Executing a CEDEX Swap via SDK
Estimating a Swap Before Execution
The pre-flight check evaluates all 42 Transfer Hook controls in simulation mode before the actual transaction is submitted. Module-aware checks (Module 2 NAV-deviation, Module 3 federal-action freeze) are included in the simulation. If wouldSucceed is false, the application can present a specific reason to the user before requiring a wallet signature.
14. Module-Specific Settlement Considerations
The settlement architecture is module-agnostic at the technical level. The same USDC and PYUSD primitives, same atomic-settlement transaction structure, same fee distribution, and same SDK integration apply to all three modules. Module-specific settlement considerations arise in three places: pre-flight compliance behavior, holding-period configuration, and circuit-breaker interactions.
14.1 Module 1 — Equities
Settlement architecture. Standard. No module-specific behavior beyond the standard 42 Transfer Hook controls.
Holding period. Reg D 6 months; Reg S 12 months; Reg CF 12 months (when Reg CF is the offering exemption).
Pre-flight checks. Standard — Empire verification, accreditation, OFAC, AML, wallet concentration, and TWAP-based price impact (CB-21).
Module-specific failure modes. EDGAR-pipeline issuer eligibility (Control 37 — issuer SEC reporting must be current; protective conversion may trigger if issuer's reporting lapses).
14.2 Module 2 — Real Estate
Settlement architecture. Standard at the SPL Token-2022 / fee distribution level. The NAV-deviation breaker is layered into the price-impact check.
Holding period. Reg D 6 months; Reg S 12 months (Reg CF rare for real estate).
Pre-flight checks. Adds NAV-deviation check. The pre-flight verifies that the proposed trade price is within nav_deviation_max_bps of the most recent appraised NAV. If the on-chain price exceeds this bound, the pre-flight returns wouldSucceed: false with failureReason: "NAV_DEVIATION_EXCEEDED". The mint stays paused on the AMM until a fresh appraisal restores the price within bounds.
Module-specific failure modes. Stale NAV oracle (nav_reappraisal_max_age_secs exceeded — the mint is paused pending fresh appraisal). Settlement is unaffected for in-flight trades that pass pre-flight, but new orders are rejected.
Settlement implication for integrators. Application code displaying real-time prices for Module 2 ST22 tokens should also display the NAV reference and the deviation. This gives users the context for understanding why a trade may be rejected by NAV-deviation enforcement even when pool reserves and stablecoin balance are sufficient.
14.3 Module 3 — CORECM
Settlement architecture. Standard at the SPL Token-2022 / fee distribution level. The federal-action freeze is an additional pre-flight check that activates Control 42 (regulatory freeze).
Holding period. Reg D 6 months; Reg S 12 months; Reg CF 12 months.
Pre-flight checks. Adds Classification-oracle freshness check and federal-action status check. The pre-flight verifies that the Classification oracle is fresh (within classification_max_age_secs) and that no active federal action is in force for the basin asset. If either check fails, the pre-flight returns wouldSucceed: false with failureReason: "CLASSIFICATION_STALE" or failureReason: "FEDERAL_ACTION_FROZEN".
Module-specific failure modes. A federal action issued during market hours triggers an automatic P0 incident under the Incident Response Playbook §13. Legal Counsel and 3-of-5 multi-signature execute Control 42 (regulatory freeze) on each affected mint within 60 minutes. From the moment the freeze is on chain, all in-flight settlement transactions targeting affected mints will revert at the Transfer Hook level. Pre-flight checks made before the freeze return correct results; pre-flight checks made after the freeze immediately return wouldSucceed: false.
Settlement implication for integrators. Application code handling Module 3 ST22 tokens should subscribe to the RegulatoryFreezeEvent and ClassificationOracleUpdated events emitted by the Oracle Aggregator program. This gives the integrator real-time visibility into freeze state changes without polling.
14.4 Cross-Module Settlement Properties
The following settlement properties are identical across all three modules:
USDC and PYUSD are the only accepted settlement currencies.
The 5% fee distribution (2% / 1.5% / 1.06% / 0.44%) is identical.
The Global Pool 0.44% allocation is permanently locked across all module activity.
Settlement finality (~13 seconds, 32 confirmations) is identical.
Atomic settlement guarantees are identical.
Empire MSF update via UCC Article 8 entitlement order is identical.
The same SDK (
@rwatokens/sdk) handles swaps for all modules transparently.The pre-flight check API is the same —
client.cedex.estimateSwap()returns the same structure regardless of module; module-specific failure reasons are surfaced through thefailureReasonfield.
15. Investor FAQ
Can I pay with a credit card?
Not directly on CEDEX. You can purchase USDC via MoonPay or Transak using a credit or debit card, then use that USDC on CEDEX. Card purchases may incur the on-ramp provider's fees (typically 1–3%).
Can I pay with SOL?
No. ST22 purchases settle exclusively in USDC or PYUSD. This is a regulatory architecture decision — stablecoins provide the price stability required for Reg D / Reg S / Reg CF subscription denomination and issuer USD proceeds.
Can I pay with Bitcoin or Ethereum?
No. Convert BTC or ETH to USDC on any exchange (Coinbase, Kraken), then use USDC on CEDEX.
What if USDC de-pegs?
If USDC deviates more than 2% from $1.00, CEDEX halts USDC acceptance for new orders. You can use PYUSD instead (or vice versa). Existing positions are unaffected.
How do I get my money back as USD?
Sell your ST22 tokens on CEDEX (after the holding period elapses) → receive USDC or PYUSD → transfer to Coinbase, Kraken, or PayPal → withdraw as USD to your bank. The off-ramp process is the reverse of the on-ramp.
Are stablecoin transactions reported to the IRS?
The platform does not provide tax advice. Generally, stablecoin-to-ST22 swaps may be taxable events. Consult a qualified tax advisor. CEDEX provides transaction history exports for tax-reporting purposes.
Why not just use a bank wire?
Bank wires cannot settle atomically with on-chain token delivery. A wire takes 1–5 business days, operates during banking hours only, and creates settlement risk (investor sends wire but tokens are not delivered, or vice versa). Stablecoin settlement is instant, 24/7, and atomic — both sides of the trade complete in the same Solana transaction or neither does.
Is there a minimum purchase amount?
The minimum is determined by the issuer's offering terms and CEDEX's minimum order size (configurable per ST22 token). There is no platform-wide minimum imposed by the stablecoin settlement layer.
Do I need both USDC and PYUSD?
No. Either one works. CEDEX accepts both interchangeably. Most investors use whichever stablecoin is easiest for them to acquire.
What happens to my settlement if a Module 3 federal-action freeze is issued during my trade?
If you submit a transaction before the freeze is on chain, the transaction may still settle if it lands before the freeze. Once the freeze is on chain, all subsequent transactions on the affected mint revert at the Transfer Hook layer; your stablecoins remain in your wallet untouched. If your application uses pre-flight checks (client.cedex.estimateSwap()), the failure surfaces with failureReason: "FEDERAL_ACTION_FROZEN" and you can avoid signing a transaction that would fail.
Related Documentation
CEDEX API Reference — Swap endpoints, estimate endpoints, order types.
SDK Reference —
RwaTokensClientswap and estimate methods.Tokenomics Deep Dive — 5% fee structure, distribution, NAV mechanics, Global Pool dynamics.
Compliance Integration Guide — BSA/AML implications, CTR filing thresholds, Empire CIP/SAR procedures.
Issuer Onboarding Guide — Module-specific onboarding flow including Reg D / Reg S / Reg CF gates.
Oracle Integration Guide — Pyth TWAP, NAV oracle (Module 2), Classification oracle (Module 3).
Architecture Decisions — ADR-009 (GENIUS Act stablecoin settlement) and related decisions.
Incident Response Playbook — Module 3 federal-action freeze runbook (§13).
RWA Tokens · Stablecoin Settlement Guide · Groovy Company, Inc.
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