FFEdu Publishes 2025 Brief on TBML's Shift Into the "Stablecoin Settlement Layer"
New framework—"Four Ledgers / Four Mismatches"—aims to improve public and institutional risk literacy as stablecoins reshape cross-border value transfer
WASHINGTON, Jan. 21, 2026 /PRNewswire/ -- The Federal Financial Education Institute (FFEdu) today released its 2025 observation brief, "TBML Enters the 'Stablecoin Settlement Layer' Era: 2025 Observation Brief," offering a practical, evidence-graded framework for understanding how trade-based money laundering (TBML) is evolving as stablecoins become a de facto settlement instrument in certain cross-border value-transfer ecosystems.
FFEdu's central finding is that TBML in the stablecoin era is best surfaced as a coherence problem, not a single narrative: risk becomes most visible when trade documentation, logistics corroboration, banking/payment flows, and on-chain settlement traces cannot be reconciled into a commercially plausible story with attributable control.
To make TBML education more teachable and reusable, the brief introduces a two-line toolkit:
- Four Ledgers: Trade / Logistics / Banking / On-chain
- Four Mismatches: Tempo / Path / Identity / Geography
The brief argues that stablecoin-mediated settlement can compress transaction cycles and increase fragmentation, raising the importance of cross-domain attribution and consistency checks. It also emphasizes methodological discipline, distinguishing between typologies and case-level facts and outlining an evidence hierarchy spanning statutes and official advisories, enforcement materials, quantitative research, and public advocacy.
Why 2025 is a pivot year
FFEdu identifies 2025 as a turning point shaped by three converging dynamics:
- Perimeter construction: The GENIUS Act established a federal framework for payment stablecoins, and implementation activity elevated financial-integrity and sanctions considerations as core design questions.
- Typology formalization: FinCEN's 2025 advisory reinforced typology-based detection and BSA reporting expectations related to professional laundering networks, supporting earlier identification of coherence failures without implying a universal "pipeline."
- Settlement-layer agenda formation: In December 2025, the Stablecoin Standards Authority (SSA), an initiative within the Federal Money Services Business Association (FedMSB), publicly announced a petition urging coordinated GENIUS implementation, heightened risk treatment for USDT exposure, and exploration of "on-chain node" identification concepts—an agenda signal that policy debates may move from issuers and intermediaries toward settlement-layer identifiability.
Designed for financial education
FFEdu noted that the brief is a public-education resource aimed at improving analytical discipline and policy literacy. It includes "red-flag bundles" designed for training and a short classroom-style exercise illustrating how cross-ledger coherence testing works in practice, while avoiding operational instructions.
About FFEdu
The Federal Financial Education Institute (FFEdu) is a 501(c)(3) public-interest organization focused on public financial education and financial-risk literacy. FFEdu's work aligns with U.S. financial literacy priorities, including the objectives associated with the Federal Financial Literacy and Education Commission (FLEC), to strengthen financial capability and informed decision-making.
Media Contact
Ms. Mia Lee | Specialist
Media Relations, Office of Communications
Federal Financial Education Institute (FFEdu)
202-681-6667
[email protected]
SOURCE Federal Financial Education Institute (FFEdu)
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