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Peer-to-peer (P2P) stablecoin payments are transfers between wallets controlled by their users, with no virtual-asset service provider or other obliged entity participating in the transfer itself. They can remain useful where people have limited access to foreign currency or conventional payment networks, or face costly cross-border transfers. But a wallet-to-wallet transfer is only one part of a payment: acquiring tokens and converting them back to local currency may still involve exchanges, banks, payment providers or issuers, and local rules can apply throughout.
What makes a stablecoin payment peer-to-peer?
P2P describes the transfer route, not a promise that the entire payment is intermediary-free. The Financial Action Task Force (FATF) defines a P2P virtual-asset transfer as one conducted without a virtual-asset service provider (VASP) or other obliged entity, including a transfer between two unhosted wallets whose users act on their own behalf. FATF’s definition and report scope
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An unhosted wallet is controlled by its user rather than operated as a custodial account by a service provider. In a direct transfer, the sender instructs the relevant blockchain network to move tokens from an address they control to an address controlled by the recipient. The network processes the transfer according to its rules; the recipient then controls the tokens at the destination address. Stablecoin arrangements differ, so the roles and powers of issuers and other participants are not identical across tokens. IMF, “Understanding Stablecoins,” December 2025
How the payment works from start to finish
A stablecoin payment usually involves three distinct stages. Only the middle stage is necessarily the wallet-to-wallet blockchain transfer.
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- Acquire or receive tokens. The sender may buy stablecoins through an exchange or another provider, receive them as payment, or already hold them. Buying them can involve a bank, card network, exchange or payment provider.
- Transfer the tokens on a network. The sender uses a wallet to direct a transfer to the recipient’s address on a particular blockchain. Whether this leg fits FATF’s P2P definition depends on whether a VASP or other obliged entity participates in it.
- Keep, spend or convert the tokens. The recipient can hold the tokens, use them in another transaction, or seek to exchange or redeem them. Conversion to local currency may require a service provider and can add fees, exchange-rate spread or delay.
Tokens on different networks—or issued under different arrangements—are not automatically interchangeable. Sender and recipient need compatible token and network access, and the ability to convert tokens at one end does not guarantee access at the other. IMF, “Understanding Stablecoins,” December 2025
Why use can persist where conventional payments are restricted
Access to foreign-currency exposure
The BIS says dollar-denominated stablecoins may appeal to people and businesses in places with high inflation, capital controls or limited access to dollar accounts, as well as users facing restrictions on dollar-based international payment networks. That helps explain demand for another way to hold or transfer dollar exposure; it does not establish that any particular use is lawful or that a stablecoin can lawfully bypass a restriction. BIS Annual Economic Report 2025
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Cross-border payment costs and practical needs
A BIS working paper analyzing 184 countries from 2017 through 2024 found stablecoin flows had stronger associations with remittance costs and transactional motives than flows of native cryptoassets. This supports the idea that payment friction can be one reason stablecoin use persists, particularly in emerging and developing economies. It does not show that every stablecoin transfer is a remittance or that a specific transfer is cheaper after network charges, exchange spreads and cash-in or cash-out costs. BIS Working Paper 1265
Availability beyond banking schedules
A direct wallet transfer may be available outside bank opening hours and on public holidays. Whether that is useful in practice depends on the token, network, wallet and service providers: network congestion can affect settlement time and fees, while access to an exchange or local-currency conversion may follow separate schedules. BIS Annual Economic Report 2025
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Liquidity and network effects
FATF identifies price stability, liquidity and interoperability as factors that can support legitimate stablecoin use. These benefits vary by token and payment corridor. A token may be widely usable in one market but difficult to exchange in another, and compatible access across networks cannot be assumed. FATF report on stablecoins and unhosted wallets
What the available transaction estimates show—and what they do not
Published figures describe different things: ecosystem size, estimated geographic flows or modeled cross-border cryptoasset activity. None of the following figures should be read as a count of P2P consumer payments.
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| Measure | Finding and scope | Source |
|---|---|---|
| Stablecoin ecosystem | FATF’s report, published March 3, 2026, says more than 250 stablecoins were in circulation by mid-2025, with market capitalization above USD 300 billion. These are ecosystem measures, not P2P payment volumes. | FATF, 2026 |
| Estimated 2024 stablecoin transactions | An IMF working paper estimated USD 2 trillion in transactions for 2024. Its geographic estimates included USD 633 billion in North America and USD 519 billion in Asia and Pacific; relative to GDP, it estimated 7.7% for Latin America and the Caribbean and 6.7% for Africa and the Middle East. These are estimated geographic flows, not P2P-only transfers or a count of consumer purchases. | IMF Working Paper 2025/141 |
| Modeled cross-border cryptoasset flows | A BIS paper’s dataset of Bitcoin, Ether, USDT and USDC flows showed cross-border flows peaking at around USD 2.6 trillion in 2021, with stablecoins accounting for close to half. This is not a stablecoin-only retail-payment measure. | BIS Working Paper 1265 |
The same BIS working paper found that capital-flow measures appeared largely ineffective at curbing the sampled digital transactions in aggregate. That empirical result does not determine whether an individual transfer complies with a particular country’s rules. Separately, FATF’s 2026 report cites Chainalysis’ estimate that illicit activity accounted for 84% of illicit virtual-asset transaction volume in 2025; that figure is about illicit transaction volume, not the share of stablecoin use that is illicit. BIS Working Paper 1265; FATF report, citing Chainalysis
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It does not settle the legal question
A transfer that occurs directly between unhosted wallets is not automatically permitted. Local rules may govern holding, transferring, exchanging or redeeming tokens, and restrictions can apply to the transfer itself as well as to the services used to acquire or convert tokens. The BIS finding about aggregate responses to capital-flow measures is not legal advice and does not resolve any individual case. The BIS also cautions that payment benefits can be outweighed by drawbacks and that policy approaches differ across jurisdictions. BIS Working Paper 1265; BIS CPMI report on cross-border stablecoin arrangements
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It does not mean anonymous or beyond issuer control
P2P is not a synonym for untraceable. Blockchain activity can be observable, and a transfer without a VASP participating in the transfer does not prevent an issuer or intermediary from exercising controls within its role. FATF lists possible issuer measures such as freezing or burning stablecoins, withdrawing them, applying due diligence at redemption, and using allow- or deny-list controls. The capacities available depend on the arrangement. FATF report on stablecoins and unhosted wallets
“Stable” is not a guarantee of par redemption
A stablecoin targets the value of a reference asset, but that target does not guarantee that a user can always redeem at par, that reserves are risk-free, or that there is no issuer, market, custody or operational risk. A wallet-to-wallet transfer can therefore move tokens without establishing what those tokens will be worth or how easily the recipient can convert them.
How to assess a stablecoin payment route
Compare the whole route, not only the network transfer. The relevant details vary by corridor, token and provider; the following checks help identify costs and constraints before relying on a payment method.
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- Total cost: What are the network and service fees, and what exchange-rate spread applies when converting?
- Timing: How long does the network leg usually take, and when are the service providers needed for conversion available?
- Compatibility: Do both parties support the same token on the same network?
- Token arrangements: What is established about reserves, redemption and issuer controls?
- Wallet control: Who holds the keys, and what custody and recovery arrangements apply?
- Privacy and visibility: What transaction details are publicly observable, and what information do providers collect?
- Rules and recourse: What local requirements apply, and what consumer protections or complaint channels are available?
These factors can produce different answers in different jurisdictions and payment corridors. The CPMI’s policy approach is that stablecoin arrangements should meet applicable requirements; it does not treat a direct transfer as a reason to ignore the risks or rules that apply to the broader arrangement. BIS CPMI report
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