Integrated payments fka BAAS
Integrated payments are the new BAAS. This isn’t your dad’s ‘pocket-protector API to a bank’. Integrated payments is code that plugs seamlessly into any platform to add fiat, crypto and stablecoin settlement in seconds. Gone are the days when users are driven through docusign dda account docs with the sponsor banks. Now the bank terms (if any) are sometimes hard to find.
We were supposed to learn from actions concerning Synapse by The Fed, FDIC, OCC, Bankruptcy Court. There was even an article Yale Journal of International Affairs, not to mention countless breathless posts by Jason Mikula in his excellent Fintech Business Weekly substack. The tragic comedy of Synapse probably peaked in October of 2025 when Evolve’s new CEO hired to cleanup ironically faced unrelated but serious charges. To their credit, the new generation of integrated payments players move fast, but there seems to be a greater-than-ever legal gap between the end user and the financial institution holding assets. Even with all parties acting in good faith, that gap will present challenges to parties that are trying to asset their rights in funds or digital assets in play.
Thankfully and true to its name, Lead Bank is picking up the slack after the legacy crew of SVB, Silvergate, MCB etc… went under or ran for the hills. Cross River Bank is also powering a lot of integrated payments.
We recommend that end users be informed about exactly which institution is holding their funds. Not just because Texas crystalised the rule on this ten years ago in DOB Supervisory Opinion 1038, but because the ‘data platform only’ services need to be able to prove that someone else took liability for user fiat or digital assets in play.
Stablecoin to the moon
What else we can do to get stablecoin pumping? Genius Act, STABLE Act, OCC, The Fed the SEC. But wait, stablecoin is never supposed to pump, it’s just supposed to be backed by treasuries and serve as a faster cheaper bank ledger. Indeed, Circle is angling to be the world’s bank. Not to be left out, Visa and MasterCard each have their own stablecoin rails. MasterCard even bought BVNK which looks like it solved stablecoin remittance. BVNK is a leader in newen integrated payments using its own licenses but also Paxos for digital asset custody, Rain / Third National for fiat custody and Lead for remittance. There are so many ‘I also have a stablecoin’ to keep track of, like MoneyGram’s MGUSD, it feels like 1820.
Meanwhile, central banks around the world use foreign exchange as a source of income for the bank and the country. This presents a challenge for international adoption of stablecoin. Brazil has banned remittance by stablecoin. Optimistically, this kind of ban is temporary to leave room for local stablecoins to come into existence allowing central banks to retain their traditional hold on exchange rates while plugging into USDC and the like.Agentic payments
What’s in your agent’s wallet? The leading case on agentic shopping right now is Amazon v. Perplexity. Amazon doesn’t like users shopping with the Perplexity bot because the bit doesn’t pay attention to ads and stays ‘on task’ buying what they are instructed to buy. This case is a ‘finger in the dyke’ to an incoming avalanche of bots shopping and doing everything else (including legal lol). Perhaps the next most interesting legal finger pointing might be between publishers of agents and those who use them and drop in payment credentials. My flight was supposed to be to Paris, France not Paris, Texas and the like. Fortunately, payment networks bring to the table a wealth of experience with error resolution and chargeback dispute management that can be adapted to the air gap between a rogue agent and their user. Within that gap there might also be opportunities for arbitrage of the error – e.g. reselling the ticket to Paris, Texas on a secondary market. When implementing agentic payments, it might make sense to include: (i) specific risk disclosure around agent-initiated payments; (ii) audit trails for decisions made; and (iii) a dashboard feature that discloses the allocation of liability as between user, fintech, ai, issuer, acquirer, merchant etc… Issuers have an opportunity to claim open territory in the ‘agent with a card’ space. Integrated ai payments providers can help cut early trails into this new territory.
My favorite vibe coding platform is Replit where we host a few custom agents that accelerate our legal work. If I can spin up apps there, so can you.