Stablecoin Conference · · 25 min

Compliance Is the Moat: Why Walapay Owns Its Licenses Instead of Renting Them

With Tom Borgers

Key takeaways

  • Walapay has been operating for about two and a half years as stablecoin-based B2B money movement infrastructure for emerging markets.

  • Tom Borgers calls compliance the most underappreciated thing in the industry and warns that companies that underinvest will collide with their banks and regulators.

  • Walapay is adding onchain treasury products with Agora and Brale and describes a possible two-way integration with Etherfuse.

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Summary

Tom Borgers argues that owning licenses, bank relationships and liquidity, and putting money into compliance, matters more than renting infrastructure, as Walapay moves into treasury products.

Walapay has been around for about two and a half years, co-founder and CEO Tom Borgers says. He describes it as money movement infrastructure centered on stablecoins, built to move money in and out of emerging markets for business customers. Its strategy is to own its licenses and bank relationships rather than rent them.

Owning the stack

Tom Borgers says Walapay has tried to get licenses wherever it can. It has also built direct relationships with bank partners in countries such as Mexico and the US, and built its own liquidity engine on top. The company has acquired a few licenses it has not yet announced, he says, and they will become part of its licensing stack. He describes Walapay as a licensed infrastructure provider that does not want to compete with its customers.

Walapay partners for some layers. Kapa provides liquidity between MXN and stablecoins in Mexico. Avenia and Blindpay play that role in Brazil, and Juicyway does in Nigeria. For wallets it works mainly with Dfns, and also with Privy.

“If you're not, like, investing a huge amount in building your compliance program and, again, maintaining and growing it, then you're going to hit a point at which your growth kind of goes head to head with what your bank partners and your regulators are basically comfortable with. Right? It's going to come to a head, and it's gonna be very ugly.”
Tom Borgers

Customers and corridors

Customers range from PSPs like Nuvei to stablecoin neobanks like KAST, Zarpay and Ugly Cash. Tom Borgers says corridors such as Mexico to China, Brazil to Hong Kong and Colombia to Singapore have been the company's biggest source of growth. For Kast, he says, Walapay adds the most value by off-ramping stablecoins into local currencies in markets including Pakistan, Egypt, Nigeria, UAE, Colombia and Japan.

Compliance as discipline

Tom Borgers says compliance is the most underappreciated thing in the industry. If a company does not invest heavily in its compliance program, he argues, its growth will eventually run into what its bank partners and regulators are comfortable with. Walapay's answer has been to build compliance directly into the product so it can be more automated, and he says AI helps a lot with this.

From movement to management

Walapay has gone from a money movement company to a money movement and management company, Tom Borgers says. It works with Agora and Brale to issue reward-bearing stablecoins for customers, and Agora's AUSD was one of its first partners. It is expanding into other tokenized fixed income products and looking at money market funds, and it hopes to add tokenized equities and funds. Walapay has not worked with Etherfuse yet. Borgers describes a possible integration in which each side would offer the other to its own customers.

Tom Borgers says Walapay is expanding into more financial products and more geographies, and that it is not stopping at payments and treasury. The goal is financial services built around wallets and public ledgers, with stablecoins at the center. He expects that to take a few years.

Agora, Etherfuse, Privy, and KAST come up most.

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