---
title: Stablecoin issuance infrastructure
url: "https://www.unknowngravity.com/en/servicios/stablecoin-issuance-infrastructure"
site: Unknown Gravity
published: "2026-11-01T11:26:56+00:00"
modified: "2026-11-01T11:26:56+00:00"
language: en
description: "Token contracts, reserve bank integration, a mint and redeem dashboard and MiCA or GENIUS Act compliance tools for licensed issuers. You issue; we build."
section: "Home > Services > Stablecoin issuance infrastructure"
---

# Stablecoin issuance infrastructure

FOR LICENSED ISSUERS MICA, GENIUS ACT AND LATAM EVM, SOLANA AND OTHER CHAINS

[Book a meeting](/en/meeting)

Stablecoin issuance infrastructure is the technology a licensed issuer uses to mint and burn its token against reserves, comply with freeze orders, reconcile supply with its reserve bank and report to its supervisor. Unknown Gravity designs and builds it for EU credit and e-money institutions under MiCA, permitted payment stablecoin issuers under the GENIUS Act, or the type of entity each Latin American country requires. We do not issue stablecoins, hold reserves or client funds, act as a regulated entity or give legal advice.

**You hold the license, or you are applying for it; we build the technology the rules take for granted. Issuance, reserves and the relationship with your supervisor stay with you.**

## 01 / What we build for an issuer, and what stays out of scope

Issuing a [stablecoin](/en/glosario/stablecoin) has two halves. The regulatory half belongs to the issuer: the license, the reserves, the bank that holds them, the auditor and the supervisor. The technical half is what we build: the contract that mints and burns the token, the systems that connect it to the reserves, and the tools to meet the obligations the rules impose every day.

This service is for the institution that holds, or is applying for, the authorization its market requires:

- **In the EU**, a credit institution or an electronic money institution. Only they may issue an e-money token ([EMT](/en/glosario/emt-token-dinero-electronico)) for offer to the public, and they must first notify and publish a crypto-asset white paper; others may offer it with the issuer's written consent (MiCA, Art. 48).
- **In the US**, a permitted payment stablecoin issuer: once the [GENIUS Act](/en/glosario/genius-act) takes effect, issuing a payment stablecoin in the United States without being one will be unlawful (Sec. 3(a)).
- **In Latin America**, whatever each country requires, because there is no common regime. In El Salvador, for example, a regulation from the National Digital Assets Commission (CNAD) sets out who may issue (Art. 3). The country-by-country summary is in [stablecoins in Latin America](/en/articulos/stablecoins-in-latin-america).

If you are a bank, our guide to [bank stablecoins](/en/articulos/bank-stablecoins) sums up what Spanish banks are preparing.

### What we do not do

- **We do not issue stablecoins.** You are the issuer: the token is minted under your license, and your authorized signers approve each operation with your keys.
- **We do not hold reserves, funds or issuance keys.** The reserves sit with your bank or custodian. In the US, only a supervised entity may provide custody of the reserves or of the private keys used to issue (GENIUS Act, Sec. 10).
- **We are not a regulated entity:** not an e-money institution, a credit institution, a [CASP](/en/glosario/casp-proveedor-servicios-criptoactivos) or a permitted payment stablecoin issuer.
- **We do not obtain licenses or give legal advice.** Your counsel interprets the rules and your institution files the application. A blockchain does not replace any authorization: without one, no contract makes issuance lawful.

### When it does not make sense

- **If you have not yet decided whether to apply.** That is a regulatory decision, and it comes first. If you need MiCA or the GENIUS Act translated into architecture, timelines and budget to make it, start with [blockchain consulting](/en/servicios/consultoria-blockchain).
- **If you want to accept, pay or hold stablecoins that already exist.** You do not need to issue one: what you need is [stablecoin payments](/en/servicios/stablecoin-payments).
- **If your token is not pegged to an official currency** or carries securities-like rights, a different framework applies ([MiCA vs MiFID II](/en/articulos/mica-vs-mifid-ii)).

## 02 / What MiCA, the GENIUS Act and LATAM require of the technology

Neither law mandates a particular blockchain or token standard. MiCA rests on the principle of technology neutrality (Recital 9), and in its final GENIUS Act rule of October 23, 2026, the OCC declines to mandate technical requirements the Act does not impose. Still, several obligations can only be met if the contracts and systems are designed for them from day one:

| What the rules require | Where | What we build |
| --- | --- | --- |
| Issue at par value on receipt of funds; redeem at any time, at par and, as a rule, free of charge | MiCA, Art. 49 | Minting only once the bank confirms the funds, and a redemption flow that burns the token and prepares the payment instruction your institution signs |
| At least 30% of funds in segregated accounts at credit institutions; the rest in highly liquid assets in the same currency | MiCA, Art. 54 | Balance feeds by account and asset type, reconciled with supply |
| Reserves of at least 1:1 and a monthly reserve composition report, examined by a registered public accounting firm | GENIUS Act, Sec. 4(a)(1) and 4(a)(3) | Daily reconciliation of supply on every chain against reserves, with exportable data for the report and the auditor |
| Redemption within two business days at most, and notice to the OCC within 24 hours if requests in a single 24-hour period exceed 10% of outstanding issuance | OCC rule, 12 CFR 15.12 | A redemption queue with measured timelines and volume alerts |
| Technological capability to comply with orders to seize, freeze, burn or prevent transfers, and to block illicit transactions | GENIUS Act, Sec. 2(16), 4(a)(5) and 4(a)(6)(B) | Address-level freezing, a blocklist and burning of blocked balances, on every chain |
| Validate that key systems and controls, “including smart contracts,” operate as intended, with periodic independent testing, and manage private keys with backup and recovery | OCC rule, 12 CFR 15.13(b) | An audit of every version, monitoring, key procedures and continuity testing with your providers |
| A white paper describing the technology, its risks and the outcome of its audit, if one was conducted | MiCA, Art. 51 and Annex III | Technical documentation of the token, the chains and the controls |

The detail of the US law is in our [GENIUS Act guide for issuers](/en/articulos/genius-act-stablecoin-issuers), and how it differs from the market structure bill, in [GENIUS Act vs CLARITY Act](/en/articulos/genius-act-vs-clarity-act). For the EU, see the [MiCA](/en/glosario/mica-reglamento-criptoactivos) glossary entry and our guide to [euro stablecoins](/en/articulos/euro-stablecoin-mica).

**If the EMT grows.** When the European Banking Authority classifies an EMT as significant, the e-money institution issuing it must meet MiCA's reserve-of-assets requirements, with an independent audit every six months (Arts. 56 and 58). The supervisor may impose some of those requirements even on a token that is not significant (Art. 58(2)). That is why we design reporting for the most demanding regime your token could reach.

**In Latin America**, the logic repeats with different numbers. El Salvador's CNAD regulation requires the issuer to file a monthly sworn statement on its reserves and quarterly attestations by an external auditor, published on its website (Art. 11): the system has to produce the data the issuer certifies and the auditor reviews.

### Status as of November 1, 2026

- **EU.** MiCA's Title IV, on e-money tokens, has applied since June 30, 2024 (Art. 149).
- **US.** The GENIUS Act (Public Law 119-27, signed July 18, 2025) is not yet in effect. It takes effect on January 18, 2027: the OCC's final rule, published October 23, 2026, is the first final rule from a federal payment stablecoin regulator and does not move that date up, because the 120 days after its publication end later. The FDIC, the Federal Reserve and the NCUA have only proposed rules; Treasury also has an interim final rule on state regimes.
- **OCC applications.** The OCC will accept them once the Office of Management and Budget (OMB) approves its forms, which are open for comment until November 23, 2026, and will announce it in a bulletin. Latest action verified in the Federal Register: October 29, 2026, a correction to the notice on those forms.

## 03 / Token contracts and multichain deployment

The token contract is the one piece you cannot patch on the fly: any change needs a procedure, an audit and often an explanation to the supervisor. That is why it is designed with the issuer, its counsel and its auditor at the table. What we build:

- **Minting and burning.** Only addresses with a minter role can [mint](/en/glosario/minting), within an allowance set by a separate role, and burning is reserved to the issuer so that supply matches redemptions. It is the pattern Circle publishes for its stablecoins on EVM chains: minters with allowances, used “to limit the damage if any particular minter is compromised.”
- **Pause.** A switch that halts transfers, minting and burning after a serious bug or a key compromise, while the functions needed to fix the problem stay available.
- **Freezing and lists under legal orders.** Blocking specific addresses and, when the order requires it, burning or moving the blocked balances. The technical function is only half of it: the other half is the internal procedure that says who executes it and under which order.
- **Roles and multisig.** Minting, pausing, list management, upgrades and administration are separate roles, each with its own [multisig](/en/glosario/multisig-multifirma) or [MPC](/en/glosario/mpc-computacion-multiparte) scheme. The OCC rule already defines a private key as the cryptographic material that authorizes a transaction, “whether held in whole, in shares, or reconstructed ephemerally.”
- **Upgrades.** An upgradeable contract lets you fix bugs, but the power to upgrade is the most sensitive one: it sits in its own role, with an execution delay and a log of every change.
- **Audit.** Every version goes through an independent audit before deployment, by an outside firm the issuer chooses; we help scope it and fix what it finds (what an audit covers: [smart contract audit](/en/servicios/blockchain-security-audits)). MiCA asks the white paper to include the audit outcome of the technology, if an audit was conducted (Annex III, Part E), and the OCC rule requires periodic independent testing of key systems.

### Several chains, one issuance

A stablecoin usually circulates on more than one chain. What we build so it remains a single token:

- **EVM chains** (Ethereum, its layer 2s and compatible networks): an [ERC-20](/en/glosario/erc-20) contract with the functions above. How we work on them is in [development for Ethereum (EVM)](/en/servicios/desarrollo-para-ethereum-evm).
- **Solana**: the Token-2022 program ships extensions that cover much of that design, such as pausable mints or the permanent delegate, which its documentation gives as a way a stablecoin issuer can transfer or burn tokens held by sanctioned entities. How they map to a regulated token is in [Solana Token Extensions for regulated assets](/en/articulos/solana-token-extensions-regulated-assets).
- **Other chains**, public or permissioned, if your counterparties operate there. The GENIUS Act tasks regulators with assessing interoperability standards with other issuers and with “blockchains, permissioned or public” (Sec. 12).
- **One supply.** Native issuance on each chain, controlled by the issuer, and reconciliation of the total against reserves. The OCC confirms that a single brand on several blockchains can be backed by a single pool of reserve assets and does not need a separate application per chain. We avoid making the token depend on third-party bridges: a bridged token is controlled by the bridge contract, not by the issuer.

## 04 / Reserves, issuer dashboard and compliance

### Integration with the reserve bank and reserve reporting

Reserves never pass through our systems: they sit with your bank or custodian. We connect to them by API to read balances and movements and, where your procedures allow it, to prepare instructions that your institution signs.

- **Daily reconciliation** of supply across all chains against reserve balances by account and asset type, with alerts on any mismatch.
- **Data for the reports and attestations** your regime requires: under the GENIUS Act, the number of outstanding stablecoins and the amount and composition of reserves, including the average tenor and geographic location of custody of each category (Sec. 4(a)(1)(C)); in the EU, whatever your supervisor asks for and, if the token is significant, the six-monthly reserve audit.
- **An audit trail** your auditor can follow. An on-chain [proof of reserves](/en/glosario/proof-of-reserves) helps transparency, but it does not replace an auditor's examination or attestation.

### Issuer dashboard

- **Minting.** The verified customer sends funds; the dashboard confirms them with the bank and prepares the mint, which your authorized signers approve.
- **Redemption.** The customer returns the tokens, they are burned and the payment is triggered, with the timeline measured against the one the rules set: in the EU, at any time and at par; under the OCC rule, two business days at most.
- **Reconciliation and reporting.** Supply per chain, reserves, daily mints and redemptions, exportable for accounting, compliance and audit.
- **Sensitive operations.** Freezes, pauses and role changes with dual approval and a record of the reason and of the order behind them.

If our systems take part in redemptions, your redemption plan has to be able to rely on them: MiCA requires the continuity of the critical activities needed for an orderly redemption, including those performed by third parties, and the plan must be notified within six months of the offer (Arts. 47 and 55). That is why we hand over the code, documentation and procedures so your team, or another provider, can run it without us.

### Compliance: KYC/KYB, travel rule and monitoring

- **[KYC](/en/glosario/kyc-know-your-customer) and [KYB](/en/glosario/kyb-know-your-business)** for the customers who request mints and redemptions, integrated with the verification provider you choose. In the US, the Act treats the issuer as a financial institution under the Bank Secrecy Act: an anti-money laundering program, customer identification and verification, suspicious activity reporting, a sanctions compliance program and the technical capability to block, freeze and reject transactions (Sec. 4(a)(5)). In the EU, a credit institution or e-money institution is already an obliged entity under anti-money laundering rules; in Spain, under Law 10/2010 (Art. 2(1)).
- **[Travel rule](/en/glosario/travel-rule-regla-de-viaje).** Since December 30, 2024, Regulation (EU) 2023/1113 has required a crypto-asset service provider that transfers on a customer's behalf to send the originator's and beneficiary's information with the transfer. If your institution or your distributors provide that service, the system has to send and receive that data.
- **On-chain monitoring.** Screening of addresses against sanctions lists, alerts on risk patterns and a case file for each alert. Your compliance officer decides; the system executes and keeps the record.

## 05 / Technical documentation, phases and deliverables

### Documentation for the white paper or the application

**In the EU**, an EMT white paper has to describe the technology: the ledger, the protocols and technical standards, what a purchaser needs to gain control over the token, the consensus mechanism and, if one was conducted, the audit outcome. It must also cover the risks of that technology with any mitigation measures, and the adverse climate impacts of the consensus mechanism (Art. 51 and Annex III). It is notified to the supervisor at least 20 working days before publication, with no prior approval, in a machine-readable format; the intention to offer the token is notified at least 40 working days in advance (Arts. 48(6) and 51). The white paper also names the people involved in design and development, including the development team (Annex III, Part B).

**In the US**, an application to the OCC includes a detailed business plan and the reserve, redemption and risk management policies, and risk management includes an information technology and security program (12 CFR 15.13(b)).

We draft the technical part of those documents (architecture, contracts, roles and keys, continuity and controls) for your counsel to integrate. The document and the application are yours. If you need help with the full white paper, see our [white paper service](/en/servicios/whitepapers); what it is and what it contains is explained in the [MiCA white paper](/en/glosario/whitepaper-mica) glossary entry.

### How we work

1. **Assessment** with the issuer and its counsel: regime, chains and institutions (bank, custodian, auditor, verification), and which obligations have a technical side.
2. **Design**: specification of contracts and roles, key model, integrations and technical documentation.
3. **Development and audit**: contracts, dashboard and integrations on testnet; independent audit and remediation of findings.
4. **Deployment and handover**: deployment on each chain, signed by your authorized signers with your keys, continuity testing with your critical providers and training for your team.

Typical project deliverables:

- Technical specification and a role and key matrix.
- Contracts with tests and an audit report.
- Issuer dashboard and integrations with the bank, custodian, verification and monitoring providers.
- Procedures for minting, redemption, pausing, freezing and key management.
- Technical documentation for the white paper or the application.

**How much it costs and how long it takes.** It depends mainly on how many chains and institutions have to be integrated, and on the regime. We do not give a figure without seeing the project. The licensing timeline is set by the rules and the authority, not by development.

If you want to walk us through your case, [book a meeting](/en/meeting).

**Who builds it.** Unknown Gravity is a blockchain and tokenization company based in Málaga, Spain, and a member of Alastria.

### Sources

- EU: [Regulation (EU) 2023/1114 (MiCA)](https://eur-lex.europa.eu/eli/reg/2023/1114/oj), Recital 9, Arts. 47 to 51, 54 to 58 and 149, and Annex III; [Regulation (EU) 2023/1113](https://eur-lex.europa.eu/eli/reg/2023/1113/oj), Arts. 14 and 40; [Spanish Law 10/2010](https://www.boe.es/buscar/act.php?id=BOE-A-2010-6737), Art. 2(1).
- US: [GENIUS Act, Public Law 119-27](https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm); Federal Register, [OCC final rule 2026-21706](https://www.federalregister.gov/documents/2026/10/23/2026-21706/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the) (12 CFR part 15), [notice on application forms 2026-21704](https://www.federalregister.gov/documents/2026/10/23/2026-21704/agency-information-collection-activities-proposed-information-collection-submission-for-omb-review) and its [correction 2026-22036](https://www.federalregister.gov/documents/2026/10/29/2026-22036/agency-information-collection-activities-proposed-information-collection-submission-for-omb-review).
- Latin America: [CNAD, stablecoin public offering regulation (El Salvador)](https://cnad.gob.sv/docs/marco-legal/reglamento-emision-ofertas-publicas-monedas-estables-2023.pdf), Arts. 3 and 11.
- Technical: [Circle, FiatToken design](https://github.com/circlefin/stablecoin-evm/blob/master/doc/tokendesign.md); [Solana, Token-2022 extensions](https://www.solana-program.com/docs/token-2022/extensions).

FAQ

## Frequently asked questions

**Can Unknown Gravity issue the stablecoin for me or get me the license?**

No. The licensed institution issues it, with its own keys and under its own responsibility, and the supervisor grants the authorization to that institution: in the EU, as a credit institution or e-money institution; in the US, as a permitted payment stablecoin issuer. We are not a regulated entity, we do not hold reserves or funds, and we do not give legal advice. We build the technology and document it so your counsel can include it in the white paper or the application.

**Who can issue a stablecoin in the EU and the US?**

In the EU, a stablecoin that references one official currency is an e-money token, and only a credit institution or e-money institution that has notified and published its white paper may issue it for offer to the public; others may offer it with the issuer's written consent (MiCA, Art. 48). In the US, a permitted payment stablecoin issuer formed in the United States: an approved subsidiary of an insured bank or credit union, a federal qualified issuer approved by the OCC, or a state qualified issuer (GENIUS Act, Sec. 2(23)). The requirements for each route are in our [GENIUS Act guide for issuers](/en/articulos/genius-act-stablecoin-issuers).

**Which blockchain should we issue on?**

The one your counterparties (exchanges, custodians, payment gateways) support natively, and that allows the controls your rules require. Neither MiCA nor the GENIUS Act mandates a network, and the GENIUS Act states that issuing on an open, public or decentralized network is not a valid ground for denying an application (Sec. 5(d)(2)(A)(ii)). We decide it with you during design, using data from your actual counterparties. It pays to start with few chains: each one adds a contract to audit and operate.

**Can the same stablecoin be issued on several chains?**

Yes. A native contract is deployed on each chain, all controlled by the issuer, and total supply is reconciled against reserves. The OCC confirms that a single brand on several blockchains can be backed by a single pool of reserve assets and does not require a separate application per chain. What does not change is that every chain must support freezing, burning and pausing, and every contract must pass its own audit.

**How much does it cost and how long does it take?**

It depends on how many chains and institutions have to be integrated (bank, custodian, verification, monitoring) and on the regime; we do not give a figure without seeing the project. The timeline is driven more by the rules than by development: in the EU, the intention to offer an EMT is notified at least 40 working days in advance and the white paper at least 20 working days before publication (Arts. 48(6) and 51(11)); in the US, the federal regulator has 120 days to decide on a substantially complete application (Sec. 5(d)), and according to the OCC that clock does not start before January 18, 2027.

This page is informative. It is not legal, tax or investment advice, and it does not replace a case-by-case review. The rules cited change: check the current version on [BOE](https://www.boe.es) and [EUR-Lex](https://eur-lex.europa.eu).

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