Crypto Edumacation

Rain.xyz and the Stablecoin Payments Stack

Executive Summary

Rain.xyz is a stablecoin-native payments infrastructure provider focused on enabling card issuance and

global money movement using stablecoins as a settlement and treasury layer, while presenting familiar

payment surfaces (e.g., cards accepted on existing merchant networks). Rain positions itself as a “full stack”

platform spanning card issuance, fiat↔stablecoin on/off-ramps, embedded wallets/accounts, compliance tooling, and cross-border money movement.

Rain publicly states it is a Visa is accepted (marketed as “more than 150 million merchants” and “over 150 countries”).

Principal Member and that Rain-issued cards can be used anywhere Visa

A central differentiator Rain claims is stablecoin-based settlement with Visa outside traditional banking

windows. Rain announced it joined Visa’s pilot program for stablecoin settlement, transitioned settlement

transactions for its Visa cards to USDC, and can “settle with Visa 7 days a week, 365 days a year.”

This

maps to Visa’s broader strategy: Visa’s stablecoin settlement capabilities enable select issuer/acquirer

partners to settle VisaNet obligations in stablecoins (e.g., USDC), with seven‑day availability and blockchain-

based settlement rails.

Why this matters at infrastructure level: moving issuer/acquirer settlement from “banking-day windows”

toward “7-day windows” can reduce prefunding/collateral and improve working capital timing—benefits

Visa itself highlights for its stablecoin settlement framework.

In a Visa case study, Visa reports USDC

settlement reduced prefunding days and reduced FX fees (reported as 20–30 bps) for a stablecoin-settling

card program, underscoring the treasury mechanics behind stablecoin settlement claims.

Where Rain sits in the payments value chain (publicly evidenced): Rain acts as an issuing/program layer

enabling partners to launch card programs and connect stablecoin balances to card and payout surfaces.

Rain also emphasizes it is not a bank or custodian and that payment products are offered in partnership

with licensed institutions.

In its Rain Spend corporate card terms, Rain discloses a specific issuing bank

partner (Third National Bank

) for that product, reinforcing the “licensed partner” model even when Rain

provides the program layer.

Key competitors span two clusters: - “Stablecoin orchestration + compliance wrappers” (e.g., Zero Hash

BVNK

, Fireblocks

) with varying custody/regulatory footprints.

“Large PSPs and networks integrating stablecoins” (e.g., Stripe

’s stablecoin payments, stablecoin

financial accounts, and stablecoin issuance tooling via its Bridge acquisition; Visa’s own expanding

stablecoin settlement and stablecoin-linked card initiatives).

Strategic risks (source-grounded triggers, not internal speculation): - Network dependency concentration

(Visa rules, settlement frameworks, card program compliance) is inherent to card-linked models.

Regulatory tightening around stablecoins and VASPs (e.g., AML/Travel Rule expectations) increases

compliance burden and could constrain corridors, on/off-ramps, and counterparties.

Competitive

compression as Visa expands stablecoin settlement (more partners, more chains, more stablecoins) and as

Stripe productizes stablecoin acceptance, balances, and issuance—potentially commoditizing parts of Rain’s

value proposition.

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Traditional Card Rails Foundations

This section uses official regulatory and network/processor documentation to define roles, economics, risk

allocation, and transaction flow—because the stablecoin-card stack is still anchored to these primitives at

authorization, clearing, dispute, and merchant settlement layers.

Core parties and roles (four‑party model plus fintech program stack)

Merchant: accepts card payments and submits transactions for authorization and later clearing/settlement

through an acquirer or its processor. The Office of the Comptroller of the Currency

describes the point-

of-sale transaction data flowing merchant → acquirer/processor → card association network → issuer/ processor during authorization.

Acquirer (merchant’s bank / acquiring bank): provides merchant acquiring and routes authorization/

clearing; later receives funds via settlement and pays merchants (often via ACH). OCC notes acquirers (or

processors) collect merchant transaction data, transmit through the card association network, and later pay

merchants under the merchant agreement; acquirers may also “pay select merchants before receiving

funds,” increasing credit/liquidity exposure.

Issuer (cardholder’s bank): approves/declines authorizations and posts transactions to the cardholder

account after clearing; remits funds via the card association settlement process. OCC describes issuers

receiving transaction data for posting and remitting funds (via Fedwire) for net settlement.

Card network / card association: routes authorization and performs clearing and net settlement position

calculation between issuers and acquirers. OCC explicitly describes the association role in the clearing/

settlement chain and net positions.

BIN / ICA and membership: OCC defines the Bank Identification Number / Interbank Card Association

number as identifying the settling bank for acquiring/issuing, and describes “bank card associations”

requiring membership rights/obligations under association rules.

Processor (issuer processor / acquirer processor): entities directly connected to network rails providing

authorization, clearing, settlement, and payment-related processing services. Visa’s developer glossary

defines a “processor” this way, aligning with issuer processor roles in modern stacks.

Program manager / BIN sponsor (fintech-era overlay)

In many fintech card programs, a program manager coordinates KYC/KYB, program operations, compliance

processes, and integrations with issuing banks/BIN sponsorship and issuer processing. This role is often

disclosed in card program legal agreements; e.g., a third-party card program agreement describes a

“Program Manager” providing onboarding, settlement, and network connectivity for a card program

(illustrating how these roles are contractually separated).

Information not publicly available. Rain’s public site and press releases do not provide a comprehensive,

global matrix of “issuer vs BIN sponsor vs program manager” roles by jurisdiction for all Rain-powered

programs. Research attempted: Rain legal pages and public documentation, Rain API docs, and partner

case studies; Rain API docs appear access-controlled and program terms vary by product and partner.

Interchange economics (what gets paid, to whom, and why it matters)

Interchange is generally paid by the acquirer to the issuer on purchase transactions, and is a primary

component of what merchants pay to accept card payments.

Stripe (as a processor/acquirer-facing PSP)

describes interchange as part of the transaction amount transferred from the acquiring bank to the issuing

bank, compensating the issuer for its role and risk in guaranteeing payment.

OCC adds operational

detail: discount fees (merchant-facing) may be collected monthly, while interchange is collected daily at net

settlement.

Disputes and chargebacks (risk allocation and timelines)

OCC categorizes chargebacks as technical, clerical, quality, and fraud, and outlines the typical dispute path:

cardholder disputes with issuer; issuer may post temporary credit; issuer requests documentation; if

chargeback upheld, amount is charged back to the merchant’s account. OCC also notes a 60‑day period for

a credit card consumer to report a dispute to the issuer (in the context of chargeback rights).

Visa

likewise frames dispute initiation as cardholder → issuer → merchant/acquirer evidence exchange.

Settlement timing, float mechanics, and who bears fraud risk (operational reality)

At the network level, OCC describes settlement as (i) transmitting sales information to issuers for collection

and reimbursement and (ii) calculating/reporting net positions for cleared transactions; the issuer pays the

association via Fedwire (instant transfers from Fed accounts), and the association’s settlement bank pays

the acquirer via Fedwire.

Merchant funding timing is governed by the acquiring bank–merchant

agreement; acquirers often pay merchants by initiating ACH credits, and may delay settlement when fraud

teams flag suspicious transactions.

This creates the practical “float” and exposure: if acquirers pay

merchants before receiving interchange settlement, the acquirer increases credit and liquidity exposure.

Step-by-step traditional card transaction flow (authorization to settlement)

Below is a representative flow consistent with OCC’s regulator-grade description, with additional dispute

handling grounded in Visa documentation.

Authorization initiation (point of sale / e-commerce): merchant captures card data + amount and

transmits to acquiring bank or its processor.

Network routing: acquirer/processor forwards authorization through the card association network to

the issuer (or issuer processor).

Issuer decision: issuer approves/declines based on account status/limits and fraud controls; decision

transmits back via network to POS.

Clearing: final transaction data is delivered from acquirer to issuer for posting, including fee calculations

and currency conversion to settlement currencies.

Settlement (issuer ↔ acquirer net positions): issuer remits funds through the association; OCC

describes issuer payments via Fedwire to the association settlement bank, and funds flow issuer →

association → acquirer → merchant. 6) Merchant funding: acquirer pays the merchant, often via ACH, per merchant agreement terms;

settlement may be delayed for fraud review.

Dispute/chargeback (if triggered): cardholder disputes via issuer; issuer requests documentation; if

upheld, the amount is charged back to the merchant’s account (merchant ultimately bears loss in upheld

cases).

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Stablecoin Settlement Architecture

This section describes documented stablecoin primitives (mint/redeem, reserves, compliance expectations)

and then maps them into stablecoin-backed payment models—especially where stablecoins touch legacy

rails (e.g., card settlement, fiat off-ramps, and treasury).

Stablecoin minting / redemption and reserve model (issuer level)

Stablecoins like USDC rely on issuance/redemption pathways and reserve backing disclosures to maintain

parity. Circle documents USDC tokenization/redemption operationally as a flow where USD is sent to an

issuer bank account, the issuer requests minting to the USDC smart contract, and redemption reverses this

(burn + fiat return).

Circle also states USDC and EURC are fully backed by highly liquid fiat reserves held

separately from operating funds, and that reserve holdings and mint/burn flows are disclosed, with

monthly third-party assurance aligned to AICPA attestation standards.

On-chain settlement and “always-on” operating window (settlement layer)

Visa’s stablecoin settlement framework explicitly positions stablecoins as a settlement mechanism for

VisaNet obligations, enabling faster funds movement over blockchains with seven-day availability and “no

change to the consumer card experience.”

Visa further states its settlement support is expanding

across additional stablecoins (e.g., USDG, PYUSD, EURC) and blockchains (e.g., Stellar, Avalanche alongside

Ethereum and Solana), which matters because stablecoin settlement becomes a network feature rather

than a bespoke one-off integration.

Custody layer (who holds keys, who bears operational control)

Custody is frequently misunderstood in stablecoin payment stacks: the “wallet security provider” is not

necessarily the regulated custodian. Fireblocks

explicitly distinguishes custody technology service

providers from licensed custodians and states Fireblocks is “not a qualified cryptocurrency custodian” in the

qualified custodian sense, while also describing operating models (direct custody/self-custody vs

subcustody) and associated red flags.

This distinction matters for BD qualification because a stablecoin payments prospect may require a

qualified custodian (or a regulated trust/bank custody arrangement) depending on jurisdiction, product,

and customer asset-handling posture.

Compliance layers (AML/KYC/Travel Rule expectations)

The Financial Action Task Force

(FATF) updated guidance clarifies that countries should assess/mitigate

risks for virtual asset activities, license/register providers, and apply AML/CFT measures to VASPs, including

stablecoins and Travel Rule implementation.

Many infrastructure providers productize this: Fireblocks states it embeds AML, KYC, and Travel Rule tooling

into transaction flows, illustrating how compliance is operationalized in payment orchestration layers.

Treasury management and liquidity provisioning (where stablecoins change the math)

Visa’s own stablecoin settlement narrative emphasizes treasury benefits: seven-day settlement windows,

modernized liquidity and treasury management, and collateral reduction considerations for seven-day

settling parties.

A Visa-published case study of USDC settlement reports operational benefits (reduced prefunding days;

reduced FX fees), framing stablecoin settlement as working-capital optimization, not only “faster payments.”

Fiat on/off-ramp integration and cross-border mechanics (bridge between worlds)

The canonical “stablecoin payment” often still needs fiat interfaces—especially for payroll, merchant

settlement, or cash-out. Rain’s money-in page markets fiat on-ramps (ACH, wire, SWIFT) converting local

currencies to stablecoins, supporting payouts and earned wage access use cases.

Rain’s money-out

page positions wallet-to-world transfers and local-currency off-ramps with 24/7/365 settlement claims.

Separately, Stripe documents a stablecoin remittance model where the sender converts local currency to a

stablecoin and sends it over a blockchain network to a recipient wallet, who can hold/spend/cash out—

explicitly noting 24/7 operation and reduced intermediary complexity.

Step-by-step stablecoin-backed card transaction flow (what can be documented vs what cannot)

A fully detailed “stablecoin-backed card” flow requires issuer-program specifics (ledgering, conversion

timing, custody posture, settlement accounts). Across publicly available network and company

documentation, the most defensible description is layered:

Cardholder experience: customer initiates a purchase with a network-branded card; consumer

experience is unchanged even when issuer settlement uses stablecoins.

Merchant flow remains traditional: merchant still relies on the standard acquiring and network rails for

authorization and merchant funding. This is implied by Visa’s framing (“no change to consumer card

experience”) and by the regulator-defined clearing/settlement mechanics staying intact for merchants and

acquirers.

Issuer ↔ network settlement can shift to stablecoins: for participating issuers/acquirers, Visa enables settlement of VisaNet obligations using stablecoins (e.g., USDC) over supported blockchains, enabling

seven-day settlement.

Issuer treasury benefit: Visa highlights modernized liquidity management and collateral reduction

considerations; Visa case study data illustrates reduced prefunding and FX improvement outcomes for

stablecoin settlement.

Information not publicly available. Public sources do not provide a universal, issuer-agnostic specification

for: (a) whether stablecoin-to-fiat conversion occurs at authorization vs clearing vs settlement, (b) how

issuer processors represent stablecoin balances in ledgers, and (c) exact reconciliation schemas between

on-chain settlement and network clearing files for every issuer/program. Research attempted: Visa public

stablecoin settlement releases and case studies, Rain’s public pages, and third-party issuer processor case

studies; the remaining details are product- and contract-specific.

[[PAGE BREAK]]

Rain.xyz Product and Operating Model

This section is restricted to what Rain, partners, networks, and regulators document publicly.

Product surface area (what Rain markets as the platform)

Rain positions as a full stack across: - Cards: issuing branded cards (physical/virtual), Apple Pay/Google Pay

support, global acceptance, and interchange-linked revenue opportunities for partners.

Money-in: fiat → stablecoin conversion via “ACH, wire, or SWIFT” (as described in Rain’s B2B case study) and broader “bank to blockchain” on-ramp positioning.

Accounts: embedded “digital dollar accounts” and wallets that connect to Rain-issued cards, including

“optional yield” language.

Money-out: stablecoin transfers and local currency off-ramps, positioned for payouts/remittances.

Network settlement claims and Visa pilot participation

Rain publicly states it “settles directly with Visa in USDC, including weekends and holidays.”

Rain’s press release with Visa states Rain joined Visa’s stablecoin settlement pilot, transitioned settlement

transactions for its Visa cards to USDC, and can settle with Visa 7 days/week/365 days/year.

This aligns

with Visa’s public stablecoin settlement program description enabling issuer/acquirer partners to settle

VisaNet obligations using USDC over supported blockchains.

Tokenized receivables and on-chain credit financing (as described by Visa and Rain)

Rain claims it has “fully tokenize[d] credit card receivables,” and Visa separately describes Rain leveraging

blockchain-enabled lending platforms (e.g., Credit Coop, Huma Finance) to borrow USDC secured by card

receivables for “just‑in‑time funding,” and then settle directly with Visa as a pilot partner.

This is unusually specific—because it comes from Visa’s own onchain finance content, not only Rain

marketing—yet it is still described at a conceptual rather than system-diagram level (no smart contract

addresses, no control framework, no waterfall mechanics disclosed).

Partnerships and ecosystem integrations (explicitly documented)

Nuvei

launched a blockchain-based payments solution in LATAM with Rain, BitGo

, and Visa,

enabling merchants to use stablecoins (including USDC) for settlement and to spend via Visa-supported

physical/virtual cards from a digital asset wallet.

Rain and Western Union

: Rain announced plans to participate in Western Union’s Digital Asset

Network, converting stablecoins held in Rain-powered wallets into local cash payouts at participating

Western Union locations (launch details pending).

Rain + issuer processing: Paymentology

describes supporting Rain in launching physical and virtual

Visa credit cards and characterizes integration of Rain “onchain infrastructure” with fiat rails, including

“crypto-to-fiat” real-time transaction language.

Rain + card manufacturing: Rain states integration with CompoSecure

(Arculus) for physical card

programs.

Example partner “end-user” programs: Rain’s case study on the Avalanche Card claims self-custody wallet

control for users and support for assets including USDC and USDT for spending wherever Visa is accepted

(initial region focus LATAM/Caribbean stated).

Custody relationships and banking partnerships

Rain’s legal language emphasizes it is not a bank, exchange, or asset custodian; payment products are

provided with licensed institutions and cards are issued by partners licensed in their jurisdictions.

For the Rain Spend corporate card product specifically, Rain’s corporate card program terms identify the

issuing bank as Third National Bank (Visa corporate card) and describe a collateralized credit line structure.

Information not publicly available. Rain does not publish a single canonical list of (a) issuing banks/BIN

sponsors by jurisdiction for all Rain-powered programs, (b) custody counterparties for every program or

custody model, or (c) the full set of regulatory licenses/registrations held by relevant Rain entities across

markets. Research attempted: Rain legal pages (including corporate card terms), Rain trust center, Rain

press releases, partner disclosures; Rain trust center appears to require gated access and did not render in

accessible text via automated capture.

[[PAGE BREAK]]

Flow of Funds and Economics

This section provides step-by-step flows only where documentation supports each step. When flows

require internal processing assumptions, they are explicitly marked as unavailable.

Flow of funds: Rain-linked consumer stablecoin card transaction

What can be stated with sources 1) User initiates purchase using a Rain-powered Visa card (e.g.,

Avalanche Card described as Visa-accepted spending). 2) Merchant processes via standard acquiring rails; authorization/clearing/settlement follow traditional

card network routing (merchant → acquirer/processor → network → issuer/processor), per OCC baseline.

Issuer settlement leg can use USDC: Rain states it transitioned its Visa card settlement transactions to

USDC and can settle with Visa 7 days/week/365 days/year as part of Visa’s stablecoin settlement pilot.

Visa stablecoin settlement mechanics (general): Visa states issuer and acquirer partners can settle

VisaNet obligations using USDC over supported blockchains, enabling seven-day settlement windows and

treasury automation.

Information not publicly available. The following are not specified in publicly accessible Rain/Visa

documentation for consumer card transactions: - Whether the card is pre-funded with stablecoins vs

credit-based vs hybrid per program.

Where and when stablecoin↔fiat conversion happens (authorization-time vs clearing-time vs settlement-time), and which entity takes principal risk on conversion.
Exact ledgering and reconciliation process between on-chain receipts (USDC transfers / receivable

tokenization) and Visa clearing files for each program.

Search basis: Rain card marketing pages, Rain-Visa press release, Visa stablecoin settlement materials, and

Visa onchain credit content.

Flow of funds: Rain-enabled B2B payment (invoice/vendor scenario)

Rain provides a higher-fidelity public description at the capability layer (still not a wiring diagram).

Documented capability steps: 1) Enterprise funds via fiat on-ramp rails: Rain describes fiat on-ramps via

ACH, wire, or SWIFT with conversion to stablecoins and funding to an enterprise wallet.

Wallet infrastructure holds stablecoins for transfers and card access.

Programmable cross-border transfer via API, with real-time status and metadata for audit/

reconciliation (Rain marketing language).

Recipient spend options: (a) load funds to a Rain-issued Visa card for immediate spendability, or (b) off-

ramp to bank accounts when cash settlement is required.

LATAM example: Nuvei describes a partnership enabling LATAM merchants to use stablecoins for faster

settlement and to spend via Visa-supported physical/virtual cards from a digital asset wallet, with custody

support from BitGo.

Information not publicly available. Public materials do not specify the contractual party bearing FX risk,

stablecoin depeg risk, and chargeback/fraud losses in each B2B configuration (wallet-to-wallet vs card-

based spend vs bank off-ramp), nor do they detail correspondent banking partners for fiat legs.

Flow of funds: Cross-border settlement and cash-out (Western Union integration)

Documented steps (program-level, still high-level): 1) User holds stablecoins in a Rain-powered wallet

(Rain describes wallet infrastructure and “Rain-powered wallets” in the Western Union announcement).

Conversion into local cash payout: Rain states the integration allows users to convert stablecoins into

local cash payouts at participating Western Union locations (details on supported geographies/eligibility

pending).

Information not publicly available. The announcement does not disclose the exact on/off-ramp operator,

FX execution venue, fees, or which entity acts as money transmitter/cash payout principal in each country

corridor. Rain explicitly states details will be announced closer to availability.

Revenue model breakdown (documented vs not disclosed)

Documented (Rain)

Rain explicitly markets that partners can “earn revenue through interchange,” and that service tiers vary by

“interchange shared with partners” and “program fees.”

Rain Spend pricing is publicly listed as a subscription model ($0/month starter; $7,500/month unlimited),

indicating at least one direct SaaS-like revenue stream in Rain’s portfolio.

Rain Spend’s corporate card terms disclose foreign purchase fee components (FX fee up to 3% and cross-

border fee up to 3%), indicating fee revenue/fee pass-through categories for that specific product.

Documented (ecosystem comparables relevant for qualification)

Interchange is paid by acquirers to issuers; this is central to card-program unit economics, and network +

scheme fees accrue at multiple points (issuer, network, acquirer).

Information not publicly available. Rain does not publicly disclose: - Interchange split percentages

between Rain, issuing partners, and program partners by region.

FX spread capture model (who sets rates; whether Rain earns spread vs passes through).
Whether Rain earns treasury yield on reserves, and under what custody/legal structure (beyond “optional

yield” marketing language).

Any per‑API pricing schedule (Rain API docs appear gated).

Research attempted: Rain cards pricing FAQ, Rain accounts/money-in/money-out pages, Rain legal pages,

Rain API docs access attempt.

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Competitive Landscape and ICP Qualification

Competitive landscape (technical comparison)

Table: Technical comparison of Rain.xyz vs key infrastructure alternatives (publicly documented only)

Custody /

Provider

Core offering

asset control

Settlement

ICP focus

(documented)

model

layer

(public)

(documented)

Notes:

Regulatory

differentiators /

positioning

weaknesses

(public)

(publicly

supportable)

Differentiators:

Visa stablecoin

settlement

participation +

tokenized receivables

claims.

Weakness:

many

operational

details (bank

partners,

custody,

pricing) not

publicly

specified.

Rain.xyz

Full-stack:

cards +

wallets/ accounts +

money-in/

out;

stablecoin

settlement

with Visa;

States it is

not a bank/

custodian; payment

products via

licensed

institutions;

supports

custodial &

multi-chain

non-custodial

support

wallet models

messaging

(marketing)

Visa settlement

Platforms, fintechs,

Not a bank/

custodian; relies on

in USDC 7d/

neobanks,

licensed

365 via Visa

enterprises,

partners;

pilot; plus

wallets

Visa

on/off-ramp

(marketing +

Principal

rails

press)

Member

(claimed)

On-chain

businesses

payment +

accepting

off-chain

settlement

to Stripe

global

stablecoin

payments;

USD balance

broader PSP

as card

(Stripe says no

base

issuer

disputes/

Provider

Core offering

asset control

Settlement

ICP focus

(documented)

model

layer

(public)

Custody /

(documented)

Stripe settles

in USD to

Stripe

balance

(merchant

does not

custody

crypto in

Stripe’s

stablecoin payments

flow);

customer

pays via

crypto wallet

N/A (network)

stablecoin

payments

that settle

into Stripe

balance in

USD; broader

crypto

product suite;

stablecoin

accounts +

issuance

tooling

(Bridge)

Stablecoin

settlement

for VisaNet

obligations;

expanding

stablecoin

settlement

support

(more coins/

chains)

Stripe

Visa

(network

programs)

Settlement

over

supported

blockchains

(USDC, etc.)

enabling

7‑day

windows

Issuers,

acquirers,

banks,

fintech

partners

Notes:

Regulatory

differentiators /

positioning

weaknesses

(public)

(publicly

supportable)

Differentiator:

distribution +

merchant

tooling;

Weakness vs

Rain: not a

card-issuing

Product

terms and

restricted-

business

policies; not

stack, dispute

positioned

support differs

chargebacks

for stablecoin

payments).

Differentiator:

controls

network

settlement

layer;

Network

rules +

stablecoin

Weakness vs

settlement

Rain: does not

pilot

provide end-to-

programs

end program

management

stack by itself.

Differentiator:

broad

ecosystem

connectivity +

security

workflow;

Weakness vs

Rain: not

inherently an

issuing/

network

membership

layer.

Stablecoin

payments

Explicitly not

a qualified

custodian;

orchestration

provides

Orchestrates

layer

custody tech

across

Fireblocks

connecting

workflows;

blockchains

rails, issuers,

custody

liquidity,

model

and

partners

compliance

depends on

tools

client

architecture

Institutions

Embeds

needing

AML/KYC/

secure wallet

Travel Rule

infra +

payment

tooling

(product

orchestration

claim)

Custody /

Provider

Core offering

asset control

Settlement

ICP focus

(documented)

model

layer

(public)

(documented)

Notes:

Regulatory

differentiators /

positioning

weaknesses

(public)

(publicly

Zero Hash

API

infrastructure

Offers

for crypto/

stablecoin

funding,

payouts,

custody and

compliance

via regulated

entities;

settlements;

publishes

provides

licensing

wrapper

licenses/

disclosures

Integrates

fiat rails +

stablecoin

rails;

supports

configurable settlement

Platforms

wanting to

add

stablecoin/

crypto

features

without building

licensure

FinCEN MSB

state

money

transmitter

licensing;

publishes

US licenses/

disclosures

Stablecoin

rails + fiat

settlement

options

Operates as

EMI via

System Pay

Enterprises /

Services

platforms

Limited (UK

integrating

FCA ref

stablecoin

payments

disclosed);

publishes

licenses/

registrations

help docs

Generates

wallet

addresses,

monitors

blockchain,

converts and

Enterprise

stablecoin

payments

BVNK

infrastructure

settles in fiat/

stablecoin;

custody

posture

depends on

BVNK

product

Debit card:

issued by

(receive/

convert/

settle)

Consumer

debit card;

commerce

stablecoin

payment

stack

(Coinbase

Payments)

Coinbase

(card +

payments)

Pathward and

Cards: Visa

Consumers +

as issuer for

commerce

debit

commerce

third-party

rails; Weakness

Marqeta

(explicit);

acceptance;

platforms

cards;

commerce:

Coinbase

vs Rain: less

evidence of

Not framed

distribution +

(Shopify

example

claimed)

Payments is

being a third-

a commerce

party issuing

stack

platform for

enterprises.

commerce

on-chain

stack: USDC

USDC rails

payments

positioning

supportable)

Differentiator:

explicit

regulatory

wrapper with

disclosed

licenses;

Weakness vs

Rain: does not

equal card

issuance stack (card programs

would still

need issuer/

network layer).

Differentiator:

strong

enterprise

payout/receive

flows;

Weakness vs

Rain: not

positioned as

card issuance +

network

settlement

partner.

Differentiator:

consumer

ICP analysis and scoring rubric (BD-ready)

This rubric is an analytical framework built from Rain’s publicly stated positioning and capabilities,

designed for qualifying inbound leads. It is not a claim about Rain’s internal scoring.

Scoring model overview (100 points total)

Product use-case fit (0–20): Does the prospect explicitly need (a) card issuance, (b) stablecoin settlements,

Volume potential (0–15): Evidence of high-frequency spend or large payout volume (e.g., payroll,

marketplaces, B2B supplier payments). Rain positions itself for payroll/payout modernization and B2B

settlement.

Geographic footprint (0–10): Multi-region programs benefit from Rain’s “global” positioning; Visa

acceptance claims imply cross-border reach, but licensing/availability must be validated on call.

Regulatory exposure (0–15): Higher if the prospect touches high-risk corridors, cash-out, or quasi-banking

features; stablecoin providers face AML/CFT/Travel Rule expectations (FATF).

Stablecoin usage intensity (0–10): Does the product require holding/transferring stablecoins vs using

them as a hidden settlement layer? Rain and Stripe both support “invisible plumbing” narratives, but

operating implications vary.

Urgency signals (0–10): Clear trigger events—new market launches, replacing slow cross-border

settlement, launching card programs in weeks—align with Rain’s marketed time-to-launch.

Treasury sophistication (0–10): Prospects with working-capital sensitivity may value stablecoin

settlement’s seven-day windows and reduced prefunding/FX friction (Visa narrative).

Integration complexity (0–10): Higher when the prospect demands non-custodial control, multi-chain,

custom flow-of-funds, or bespoke compliance routing; Rain and peers market modularity and multi-chain

support, but implementation burden must be qualified.

Qualification call “must-answer” checklist (infrastructure-level)

Which entity is the regulated issuer / who holds network membership for each market? (Rain: Visa

Principal Member claim; licensed partners still used; must clarify per program.)

What custody model is required (self-custody vs subcustody) and who is the qualified custodian if needed?

Where does FX occur, and who bears principal risk? Information not publicly available without program

specifics; must be obtained during diligence.

Is the flow card-based (chargebacks/fraud exposure) or wallet-based (irreversibility, different dispute

posture)?

Settlement preference: fiat-only, stablecoin-only, or hybrid; whether seven-day settlement is required (Visa

stablecoin settlement).

[[PAGE BREAK]]

Risk and Regulatory Landscape

This section focuses on documented requirements, exposures, and risk vectors at the intersection of card

rails and stablecoin rails.

Card network compliance and program obligations

Card programs are subject to detailed network rules and dispute processes. OCC highlights that strict card

association rules govern chargebacks and that high chargeback volumes can trigger penalties/fines from

card associations; it also emphasizes fraud and operational controls in merchant processing and

settlement.

Visa publishes merchant-facing dispute management guidance and stepwise dispute

handling, reflecting formalized dispute workflows across issuers/acquirers/merchants.

Chargeback and fraud risk allocation (card-linked stablecoin programs inherit this)

Even if issuer settlement uses stablecoins, merchant-side chargebacks remain a core risk mechanism in

card payments. OCC describes how chargebacks can be upheld by issuers and charged back to merchants,

and notes merchant processing banks can be liable for merchant fraud and factoring/laundering behaviors.

This is a critical qualification point: a “stablecoin card” does not eliminate chargebacks; it can shift treasury

settlement timing while leaving dispute rails intact.

Stablecoin regulatory scrutiny and AML/KYC obligations

FATF guidance requires countries to license/register VASPs and apply AML/CFT measures, including

stablecoin-related guidance and Travel Rule implementation expectations.

Operationally, infrastructure providers embed these requirements: Fireblocks states sanctions screening,

AML/KYC, and Travel Rule are embedded into transaction workflows, demonstrating how providers

anticipate multi-jurisdiction compliance demands.

Custody and consumer protection obligations

Custody posture drives regulatory and operational risk. Fireblocks documents that “custody technology

service providers are usually regulated differently than licensed custodians,” and warns against

misrepresenting who controls keys (a proxy for whether a license might be required).

For regulated “wrapper” providers, Zero Hash publishes extensive money transmitter licensing disclosures,

including warnings that virtual currency is not FDIC/SIPC insured and that transactions may be irreversible

—consumer protection disclosures that shape BD diligence for stablecoin payment flows.

Cross-border compliance and sanctions exposure (documented at the framework level)

FATF explicitly ties VASP obligations to cross-border information sharing and Travel Rule compliance.

Payment orchestration providers highlight sanctions screening as a built-in requirement for global

stablecoin flows.

Information not publicly available. Public sources do not provide Rain’s corridor-by-corridor sanctions/

compliance operating procedures, nor the specific screening vendors or rule tuning. This must be verified in

diligence and contract review.

[[PAGE BREAK]]

Strategic Outlook and Technical Appendix

Strategic analysis (source-backed signals, then interpreted implications)

Source-backed market signals - Visa is scaling stablecoin settlement support (more stablecoins, more

chains, broader stability settlement framework) and explicitly enables issuer/acquirer settlement in USDC

over blockchains with seven-day windows.

Stripe has operationalized stablecoin payments (customers pay via crypto wallets; settlement to USD

balance), expanded stablecoin money management capabilities, and launched stablecoin issuance tooling

via Bridge (“Open Issuance”).

Rain is publicly positioned as a Visa stablecoin settlement pilot participant, with USDC settlement for its

Visa card obligations and tokenized receivables narrative; Visa additionally describes Rain using lending

protocols for just-in-time USDC funding secured by receivables.

Reasoned strategic interpretation (explicitly not a claim about internal systems) - Margin

compression risk concentrates at commoditized layers: stablecoin on/off-ramp conversion, basic wallet

infrastructure, and “vanilla” stablecoin acceptance (Stripe-style). As Stripe and Visa productize stablecoin

settlement/acceptance at scale, providers without proprietary risk, compliance, or distribution moats may

face pricing pressure.

Disintermediation vectors likely come from (a) networks expanding direct stablecoin settlement to more

issuers/acquirers and (b) large PSPs embedding stablecoins as a default settlement method. If Visa’s

stablecoin settlement becomes broadly available and standardized, some of Rain’s differentiation shifts toward program operations, compliance, and distribution rather than “stablecoin settlement access” alone.

Rain’s defensibility, based only on public evidence, appears to rest on: (i) being integrated into Visa’s pilot

settlement + operationalizing seven-day settlement, (ii) building/operating credit receivables tokenization

concepts and related financing efficiency (as Visa describes), and (iii) bundling issuance + wallets + on/off-

ramps into a single integration. The degree to which this is defensible depends on execution, regulatory

durability, and network relationships—details not fully public.

Technical appendix (infrastructure fluency pack)

Glossary (selected, source-grounded) - Authorization: approving/declining a transaction before purchase

finalization; routed merchant → acquirer/processor → network → issuer/processor and back.

Clearing: delivering final transaction data from acquirers to issuers for posting; includes fee calculations

and currency conversion to settlement currencies.

Settlement: transmitting sales information for collection and reimbursement to merchant; also

calculating net positions for issuers/acquirers on cleared transactions.

Chargeback: dispute-driven reversal/chargeback process; OCC categories include technical, clerical,

quality, and fraud; Visa details merchant/issuer/acquirer dispute workflow.

Stablecoin settlement (Visa): ability for issuer/acquirer partners to settle VisaNet obligations using USDC

over supported blockchains, enabling seven-day windows.

Custody technology service provider vs qualified custodian: Fireblocks describes custody tech

providers as often regulated differently than licensed custodians and states Fireblocks is not a qualified

custodian; custody model depends on who controls key material.

BD diligence questions (designed to force clarity without assumptions) - “Show the exact flow-of-funds

diagram you use for regulators and network partners—who holds assets at each step?” (OCC emphasizes

transaction + funds flow complexity with third parties.)

“What is the settlement asset and window (fiat vs USDC; 5-day vs 7-day), and which Visa stablecoin

settlement rails/chains are used?”

“Which entity bears chargeback losses and fraud losses under network rules?”

“Are you a VASP in the relevant jurisdictions, and how do you meet Travel Rule and sanctions screening

expectations?”

“What custody model is required (self-custody vs subcustody), and do you need a qualified custodian?”

Public-data gaps checklist (explicitly confirm on discovery; do not infer) - Issuing/banking partners by

market (only partially disclosed via specific product terms such as Rain Spend).

Exact stablecoin↔fiat conversion timing and principal risk bearer for each program configuration. Information not publicly available.

Rain API specifications (Rain API docs appear gated). Information not publicly available.

100

SOC 2 / PCI report details: Rain markets SOC 2 compliance; trust center appears gated and did not render

in accessible capture. Information not publicly available.

101

https://www.rain.xyz/

https://legal.raincards.xyz/legal/corporate-card-terms

Launch Stablecoin-Powered Cards in Weeks | Rain

https://www.rain.xyz/cards

Rain & Visa Partner to Accelerate Onchain Credit Cards

https://www.rain.xyz/resources/rain-and-visa-partner-to-accelerate-onchain-credit-cards?utm_source=chatgpt.com

Visa Launches Stablecoin Settlement in the United States,

Marking a Breakthrough for Stablecoin Integration | Visa

https://usa.visa.com/about-visa/newsroom/press-releases.releaseId.21951.html

https://usa.visa.com/content/dam/VCOM/regional/na/us/Solutions/documents/visa-crypto.com-

usdc-case-study.pdf

https://usa.visa.com/content/dam/VCOM/regional/na/us/Solutions/documents/visa-crypto.com-usdc-case-study.pdf

https://www.rain.xyz/money-out

100

https://www.rain.xyz/money-in

https://docs.bvnk.com/bvnk/use-cases/stablecoin-payments-for-platforms/get-payment/

Merchant Processing, Comptroller's Handbook

https://www.occ.treas.gov/publications-and-resources/publications/comptrollers-handbook/files/merchant-processing/pub-ch-

merchant-processing.pdf

US Licenses and Disclosures

https://docs.zerohash.com/page/us-licenses-and-disclosures

Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service

Providers

https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-virtual-assets-2021.html

docs.stripe.com

https://docs.stripe.com/payments/stablecoin-payments

https://developer.visa.com/pages/glossary

https://autospend.ai/legal/card-user-agreement

https://www.rain.xyz/legal

https://www.mastercard.com/us/en/business/support/merchant-interchange-rates.html

https://stripe.com/resources/more/interchange-fees-101-what-they-are-how-they-work-and-how-to-cut-

costs

https://stripe.com/resources/more/interchange-fees-101-what-they-are-how-they-work-and-how-to-cut-costs

https://usa.visa.com/support/small-business/dispute-resolution.html

https://help.circle.com/s/article/Tokenizing-and-redeeming-USDC

Transparency & Stability | Circle

https://www.circle.com/transparency

Visa - Visa Expands Stablecoin Settlement Support

https://investor.visa.com/news/news-details/2025/Visa-Expands-Stablecoin-Settlement-Support/default.aspx

https://www.fireblocks.com/blog/do-i-need-a-qualified-custodian-to-hold-my-crypto-and-digital-

assets

https://www.fireblocks.com/blog/do-i-need-a-qualified-custodian-to-hold-my-crypto-and-digital-assets

Payments | Fireblocks

https://www.fireblocks.com/products/payments

https://stripe.com/en-mx/resources/more/stablecoin-remittances-explained

https://www.rain.xyz/resources/b2b-stablecoin-payments-that-settle-in-minutes-and-spend-

instantly

https://www.rain.xyz/resources/b2b-stablecoin-payments-that-settle-in-minutes-and-spend-instantly

101

Technology

https://www.rain.xyz/technology

Stablecoins and the future of onchain finance | Visa

https://corporate.visa.com/en/solutions/crypto/stablecoins/stablecoins-and-the-future-of-onchain-finance.html?

utm_source=chatgpt.com

Nuvei launches comprehensive blockchain payment solution

https://www.nuvei.com/posts/nuvei-launches-comprehensive-blockchain-payment-solution?utm_source=chatgpt.com

https://help.coinbase.com/en/coinbase/trading-and-funding/coinbase-card/cb-card-apply

https://www.rain.xyz/resources/rain-joins-western-unions-digital-asset-network-bringing-real-

world-payment-utility-to-stablecoins

https://www.rain.xyz/resources/rain-joins-western-unions-digital-asset-network-bringing-real-world-payment-utility-to-

stablecoins

https://www.paymentology.com/client-story-rain

https://www.rain.xyz/resources/lets-get-physical

https://www.rain.xyz/resources/rain-powers-avalanche-card-for-crypto-friendly-spending

https://www.rain.xyz/rain-spend

https://docs.zerohash.com/

https://www.rain.xyz/resources/rain-and-toku-partner-to-launch-real-time-stablecoin-payroll-

infrastructure

https://www.rain.xyz/resources/rain-and-toku-partner-to-launch-real-time-stablecoin-payroll-infrastructure

https://www.rain.xyz/resources/klutch-built-a-smarter-credit-card-and-the-onchain-magic-stays-invisible

https://usa.visa.com/content/dam/VCOM/global/support-legal/documents/merchants-dispute-

management-guidelines.pdf

https://usa.visa.com/content/dam/VCOM/global/support-legal/documents/merchants-dispute-management-guidelines.pdf

https://www.fireblocks.com/report/a-guide-to-digital-asset-wallets-and-service-providers

Rain Xyz Stablecoin Payments Stack