SACF-05 — Counterparty & Infrastructure: will your stablecoin remain usable if a critical link fails?
Updated: Aug 29
RESEARCH & INTELLIGENCE • SACF 2026
BECTRA SACF — Stablecoin Accounting & Control Framework • Pillar 5 of 7 • Counterparty & Infrastructure
01 Classification → 02 Purpose & Exposure → 03 Accounting & Measurement → 04 Ownership & Evidence → 05 Counterparty & Infrastructure → 06 Governance & Control → 07 Reconciliation & Reporting
Which counterparties and infrastructures does the position depend on?
A company may have correctly classified, accounted for and evidenced its stablecoin holdings while remaining exposed to a dependency chain it does not control. Issuer, custody, network, conversion providers and exit routes can each become a point of failure.
SACF CONNECTION — A critical dependency is only controlled when responsibilities, limits, alternatives and emergency procedures are formally defined. SACF-06 explores this point in greater detail.
SACF CONNECTION — The criticality of a dependency should be assessed against the position’s purpose, holding horizon and actual liquidity or conversion needs. SACF-02 explores this point in greater detail.
SACF PRINCIPLE — A stablecoin's robustness for a company depends as much on issuer, custody, network and exit routes as on its monetary peg.
1. Map the dependency chain
For each stablecoin, the map should identify the issuer, entities involved in redemption, custodians and sub-custodians, wallets or MPC solutions, networks, bridges or smart contracts, and the providers or banking partners that enable conversion back to bank money.
2. Assess issuer risk
Review financial strength, reserve quality and liquidity, redemption rights, suspension or freeze clauses, governance, regulatory status and transparency. A stable peg is not enough to conclude that issuer risk is low.
3. Assess custody, access and outsourcing
The framework should review provider status, segregation, access and withdrawal conditions, reliance on sub-custodians, liability in case of incident and exit plans. Custody should not be analysed separately from the company's real ability to recover assets.
4. Assess networks, smart contracts and bridges
Network availability, fees, finality, congestion, fork, bridge, smart-contract or technical-suspension risks may affect usability even while the stablecoin remains at par.
5. Test liquidity and exit routes
Market depth, banking partners, accepted platforms, timing, geographic restrictions and AML/CFT controls determine whether an exit is actually available. Conversion routes should be tested, not merely documented on paper.
6. Measure concentration, redundancy and substitutability
A critical non-substitutable dependency should be treated as a potential point of failure. The file should identify alternatives, mobilisation time, capacity limits, tests performed and conditions for activating contingency arrangements.
SACF RULE — A critical dependency that cannot be substituted should be treated as a potential point of failure.
7. Build the expected evidence file
The minimum file includes due diligence, contracts and terms, transparency reports or attestations, continuity procedures, exit tests, periodic reviews and incident tracking.
SACF CONNECTION — SACF-04 proves the holding. SACF-05 identifies the third parties and systems on which that holding depends. SACF-06 then organises the internal powers and controls used to manage those dependencies.
Sources
Continue through the BECTRA SACF framework
To extend this analysis, the following pillars are the most directly connected to the issues addressed in this article.
Comments