USDC and USDT need a documented accounting treatment. A dollar reference does not make either token cash.

A stablecoin audit starts with transaction-level records, not year-end wallet screenshots.
A stablecoin treasury policy should cap exposure, control wallet access and test redemption.

Stablecoin treasury management starts with accounting and control, not a wallet. USDC and USDT can speed cross-border payments, but a CFO must decide what asset the company holds and what keeps an operational balance from becoming a speculative position.

That decision belongs to management. The auditor tests it. A reserve report from an issuer does not replace either task.

Stablecoin Accounting Comes Before Token Selection

USDC accounting and USDT accounting cannot start with a one-dollar target price. Legal rights, custody terms, reporting framework and business purpose decide the treatment.

USDC and USDT can fund supplier settlement, payroll or intra-group transfers.

IFRS guidance covers cryptocurrency without contractual claims on another party. Stablecoins need their own issuer-term and redemption-right review. 

IFRS 102 does not name cryptoassets. Section 10 requires management judgement for transactions that the standard does not address. The FRC notes that companies often review inventory and intangible-asset rules for cryptocurrency holdings. 

US GAAP groups need a separate scope memo. FASB excludes assets with enforceable rights or claims on underlying goods, services or other assets. That point can affect stablecoin treatment. 

Document the conclusion. Cover initial measurement, later measurement, FX, fees, presentation and disclosures.

Build a Stablecoin Audit Trail

A clean stablecoin audit depends on evidence collected during each transfer. UK audit standards require sufficient, appropriate evidence. Management records form part of that evidence, but the audit team needs records it can test. 

Keep a controlled monthly close pack with:

• A wallet and custody register covering legal entity, address, custodian, token, chain and business purpose.
• Evidence of key control, multisignature rights or custodian access permissions.
• Direct custodian confirmations and balance statements.
• Transaction records with hash, time, sender, recipient, invoice, FX conversion and ledger entry.
• A valuation record with named price source, time stamp, exchange rate and conversion spread.
• Issuer and counterparty due diligence.

An on-chain balance proves an address holds tokens. It does not prove legal title, approval authority or the business reason for a payment.

Circle publishes USDC reserve information and monthly third-party assurance. Tether publishes USDT reserve and circulation information. Use those sources for issuer due diligence. They do not prove the company’s ownership or custody. 

Create a Stablecoin Treasury Policy

A corporate stablecoin treasury needs rules that work like a bank mandate. The policy should cover:

1. Purpose and limits: Hold tokens only for named operational uses. Set caps by legal entity, issuer, wallet and payment corridor.
2. Approved tokens and chains: Name permitted tokens, networks, custodians, exchanges and on-ramp providers. Block transfers to unknown addresses.
3. Custody and access: Ban personal wallets. Require dual approval for key changes, payment permissions and new beneficiary addresses.
4. Payment authority: Match payment limits to the existing bank mandate. Separate payment preparation from approval.
5. Reconciliation: Reconcile wallet and custodian balances to the ledger each business day during a pilot. Investigate unmatched items straight away.
6. Liquidity and exit: Set a tested redemption route into a named fiat account. Record the accepted time and cost for redemption.
7. Financial crime: Retain KYB, sanctions-screening and transaction-monitoring records. UK cryptoasset businesses within the money-laundering regime must register with the FCA.
8. Incidents: State who can halt payments after a de-peg, wallet compromise, sanctions alert, provider outage or failed redemption.

Test Stablecoin Payments through a Controlled Pilot

A crypto treasury management pilot does not need a large balance. Choose one corridor, one token, one chain and one approved provider. Run a full cycle from fiat funding through settlement, reconciliation and redemption.

The test should produce a clean accounting entry, a complete audit pack and an exception report. Stop the pilot where documents are missing, a redemption fails, or payment approvals do not operate as written.

For cross-border supplier payments, Merge’s stablecoin treasury management uses USDC or USDT as the settlement leg between two local-currency payments. The company funds the payment in fiat. Merge converts it into a stablecoin, moves it on-chain, converts it into the recipient’s local currency, then sends the local payment.

This model matters for finance teams. The stablecoin can act as a controlled transit asset rather than an open-ended treasury holding. Merge combines on-ramp and off-ramp conversion, multi-currency accounts, payment routing and reconciliation records in one operating flow. Treasury can track the source of funds, the conversion, the transfer and the final payout.

FAQ

Can a company hold USDC and USDT on its balance sheet?

Yes. The company needs a documented accounting conclusion that reflects its legal rights, custody terms, reporting framework and reason for holding the tokens.

Are USDC and USDT cash?

Not automatically. A dollar reference price does not decide cash classification. Finance must assess redemption rights, control of the token and the terms of the custodian or payment provider.

What does a stablecoin audit require?

Auditors need evidence of ownership, wallet or custodian control, valuation, transaction cut-off, payment approvals and reconciliation to the general ledger. A blockchain transaction hash alone is not enough.

What belongs in a stablecoin treasury policy?

The policy should name approved tokens, payment corridors, custodians and wallets. It should set balance limits, approval thresholds, reconciliation rules, sanctions controls, redemption routes and incident procedures.

How should a CFO start stablecoin treasury management?

Start with one payment corridor, one token and a limited balance. Test funding, settlement, reconciliation, redemption and audit records in one complete cycle. Expand only after finance and control owners sign off on the results.