Bastion proposes to be the regulated issuer for USDH.

Who We Are

Bastion is a regulated stablecoin issuance platform for institutions, enterprises, and ecosystems. We operate under a New York limited‑purpose trust charter while holding many MTLs, maintain bankruptcy‑remote, segregated reserves (cash, short‑duration U.S. Treasuries, overnight RRP), and operate under New York Banking Law and NYDFS regulations. We are non‑extractive by design: we provide the technology, operations and compliance rails; communities keep the economics. And more importantly, we do not compete with you.

Members of our team include:

Nassim Eddequiouaq — Founder & CEO. Previous: Chief Information Security Officer, Crypto @ a16z, Tech Lead on Crypto Custody & Wallets on the Libra Project at Meta, Tech Lead & Employee #10 at Anchorage Digital—the first OCC-chartered digital asset bank, Security Team at Docker & Apple. Built and scaled some of the world’s most secure regulated crypto infrastructure.

Caroline Friedman — COO, Founding Member, Board Member. Previous: a16z, Regulatory Strategy Counsel @ Kraken, Federal Prosecutor @ U.S. Department of Justice. Led large scale operations, policy and compliance strategies across public and private sectors.

Beth Gibson — General Counsel. Previous: Head of Regulatory Legal at Western Union, Senior Compliance Leader at TIAA, Federal Prosecutor at U.S. Department of Justice. Architected enterprise compliance programs at the largest scale.

Rohan Kohli — Chief Risk & Compliance Officer. Previous: CRO & CCO at Gusto, Global CCO at TIAA, Global Head of Financial Crimes Compliance and Deputy CCO at Capital One, Americas CCO at GE Capital, Global CCO of Morgan Stanley’s commercial and private banks, Senior Compliance Officer at American Express. Designed and ran global risk/compliance programs for several of the largest U.S. institutions.Jameel Al‑Aziz —Chief Technology Officer. Previous: Early engineer at Hulu and Scopely. Engineered highly scalable systems for enterprise-scale consumer platforms.

Alex Bazhenov — Head of Product. Previous: Tech Lead at ZeroHash and Old Mission. Engineering and product leader focused on crypto custody and settlement infrastructure.

Sean Lai — Issuance Product Lead. Previous: Stablecoin Product Operations Paxos, Grab. Led the launch and operationalization of multiple stablecoins, including PYUSD (PayPal USD).

Vince Tejada — Head of Treasury & Strategic Finance. Previous: Led major payments and strategic finance initiatives at Ripple including for RLUSD, J.P. Morgan, IBM. Built and scaled treasury and stablecoin treasury infrastructure across global markets.

Jasmine Mucha — Product Compliance Lead. Previous: Head of Partnerships Compliance @ Cash App, Director of Global Product Compliance @ Western Union, ex-J.P. Morgan and Manhattan District Attorney’s Office. Expert in product compliance, BaaS/financial‑institution partnerships, and third‑party risk management.

Jared Klee — Head of Revenue. Previous: Head of Sales at Vouch Insurance, IBM Blockchain. Led strategy and growth for institutional insurance and blockchain products, built the largest crypto insurance practice.

Bastion is built by people from the top companies Cash App, Coinbase, Palantir, Brex, Robinhood, Uber, Bridgewater, Goldman Sachs, Microsoft, Ethereum Foundation, Paxos, Gemini, U.S. Department of Homeland Security, MongoDB, Alchemy, Ripple, Block.

Summary

Bastion is a regulated white-label stablecoin issuance platform designed for institutions.

We do not issue our own competing stablecoin (unlike most issuers that have submitted proposals so far), nor do we have our own competing chain.

Our mission is to enable amazing ecosystems and businesses to launch and grow their stablecoins, as a neutral partner.

• Bastion proposes to be the regulated, GENIUS‑compliant issuer of USDH, as Hyperliquid's native stablecoin.
• USDH should be a full‑stack stablecoin (not a wrapped asset—think being the L1 rather than just an L2): USDH would have its own legally segregated, bankruptcy‑remote reserves with high quality, tokenized MMFs, and obtain its own independent regulatory approval. We propose the reserve structure to be composed of BUIDL in partnership with Securitize, and WisdomTree’s short term MMF.
• 95% of the interest from reserves to be distributed towards USDH and HYPE growth initiatives across AF, builder codes, liquidity seeding, USDC-to-USDH swaps, and more.
• USDH is made accessible and spendable via Bastion and its partners’ global on/off‑ramps and card spendability, cross‑chain interoperability, and a dedicated liquidity program — these include well known partners like Rain, LayerZero, Borderless, and many others.
• Bastion prioritizes the issuance of additional stablecoins as wrappers on top of partner stablecoins including USDH, not the other way around.

Regardless of who ends up issuing USDH, whether it’s a single issuer or multiple issuers forming a consortium, issuing under a U.S. federal or state charter that meets GENIUS standards is absolutely critical to derisk USDH on the regulatory front.

USDH — Powered by Bastion

Bastion is proposing to issue USDH under its licenses to enable GENIUS-compliance. Bastion will provide industry-leading regulatory coverage, banking connectivity, and stablecoin issuance of wrapped stablecoins on top of USDH. So if Hyperliquid is the blockchain that houses all of finance, USDH should become the house of all money.

We also partner with incredible industry players to ensure utility, distribution, and liquidity of USDH — Rain, LayerZero, and Securitize.

Industry-Leading Regulatory Coverage

Bastion is one of the most regulated U.S. companies in the global crypto industry with a New York trust chartered company and another subsidiary that holds dozens of money transmitter licenses (MTLs) and is registered as an MSB with FinCEN.

Based on the consistency between New York’s requirements and the GENIUS Act, Bastion will be one of the few issuers able to offer a GENIUS-compliant stablecoin on day 1 rather than in a hypothetical future.

Strong Banking Connectivity

Bastion both has strong banking relationships in the US. Bastion and its partners offer seamless on & off-ramp capabilities through our own infrastructure as well as through incredible partners including Rain, and many others that have been mentioned as part of other proposals.

Bastion also has strong international on & off-ramp connectivity and partnerships in more than 50 countries.

USDH as a Foundation for Future Stablecoins

Bastion views USDH as a strong foundation for other stablecoins and intends to issue additional stablecoins for partners through wrapping on top of USDH. This will allow USDH to benefit from the liquidity and distribution of additional stablecoins built on top of it over time.

Reward Distribution

Bastion proposes allocating 95% of USDH reserve interest as follows:

• 50% to the Assistance Fund,
• 40% to incentives for builder codes, traders, and liquidity providers
• 5% reinvested into $USDH and $HYPE growth (directly growing liquidity for existing pairs, seeding liquidity in new markets, listing on other exchanges, market making retainers, adoption partnerships such as with card networks, and more).

We believe the community is best positioned to decide what drives value back to $HYPE holders and Hyperliquid ecosystem users. The 95% distribution toward USDH and ecosystem growth should remain flexible and evolve with community needs.

In the early days, bootstrapping liquidity across top pairs and covering redemption fees from converting USDC to USDH at scale will be more important. Over time, priorities would likely shift toward expanding liquidity and adoption of USDH across other ecosystems across trading and payments use-cases, and rewarding people & businesses who drive adoption in a sustainable way.

Important Transparency Questions to Ask All Issuers

Explain how you are GENIUS-compliant *today*:

• What U.S. charter do you have today? Do you have a bank or a trust charter? Is it a federal or state charter? If state charter, which state?
  • Money transmission licensing does not cover stablecoin issuance activities. Stablecoin issuance requires the approval and supervision of a U.S. federal or state banking regulator that has explicit issuance frameworks.
  • What is the name of the legal entity that has a GENIUS-compliant charter?
  • If you do not have a U.S. federal or state charter, why should the Hyperliquid community take the risk of having USDH issued by a company that has not yet received GENIUS-compliant licensing?
• What is the name of the U.S. regulator that approves and supervises your stablecoins activities today? What stablecoin issuance framework do they have in place today? Is their issuance guidance framework equivalent to the GENIUS Act?
• What is the expected time range for your U.S. regulator to review requests to issue new stablecoins?

Bastion has a New York Trust Charter company, Dibbs Trust, which is supervised by the NYDFS. Our focus is on regulated whitelabel institutional stablecoin issuance. Like any regulated entity, coin use cases are subject to approval.

NYDFS has built the most robust stablecoin issuance framework in the U.S. to this day. This is one of the main reasons why most institutional regulated stablecoins have selected New York as an issuance jurisdiction and why New York is well positioned under GENIUS. The GENIUS Act requirements map and take inspiration from NYDFS’ stablecoin issuance guidance. See NYDFS’ website for more information including guidance from 2022: https://www.dfs.ny.gov/industry_guidance/industry_letters/il20220608_issuance_stablecoins.

The review time for new stablecoins varies based on different factors (multi-chain vs mono-chain, closed vs open loop, reserve management partners, etc..) so the regulators can ensure that proper risk and compliance controls are built and activated. We anticipate stablecoin issuance request reviews to take months to launch for any properly supervised issuer, Bastion or any other, just like it did for Ripple’s RLUSD.

Explain your conflicts of interest with Hyperliquid and USDH:

• Do you issue your own branded stablecoin that may compete with USDH?
  • If so, explain how you’d treat a conflict of interest between your stablecoin and USDH? When will you promote USDH and when will you promote your stablecoin?
• Have you launched or are a core contributor to a blockchain that may compete with Hyperliquid’s chain?
  • If so, explain how you’d treat a conflict of interest between your chain and Hyperliquid? When will you promote Hyperliquid and when will you promote your chain?
• Do you or will you have your own exchange that may compete with Hyperliquid’s exchange?
  • If so, explain how you’d treat conflict of interest between your exchange and Hyperliquid? When will you promote Hyperliquid and when will you promote your exchange?

Bastion is a neutral partner without conflict of interest.

Bastion does not issue its own stablecoin.

We haven’t, nor do we plan to, launch our own blockchain. We are also not a core member of any alliance developing a competing blockchain.

We haven’t, nor do we plan to, launch our own competing exchange.

Explain whether USDH would be a full-stack stablecoin or a wrapped stablecoin:

• What would the structure of USDH be? Is it its own stablecoin across the stack? Or simply a wrapper on top of an existing stablecoin?
• If you envision USDH as a wrapper:
  • Why would USDH be built on top of a smaller stablecoin? How would USDH be benefiting from your stablecoin and not your own stablecoin getting all the liquidity and distribution benefit from USDH?
  • Why not have USDH as the base stablecoin and build other stablecoins as wrappers on top of it?
• If you envision USDH as a full-stack stablecoin, are you planning on using USDH as a base for other wrapped stablecoins you’ll issue in the future? If not, why not?

USDH powered by Bastion would be its own full-stack stablecoin with:

• Its own segregated bankruptcy-remote stablecoin reserves
• Its own fiat liquidity management system
• Its own GENIUS-compliant regulatory review and approval

Currencies are networks.

We do not believe that USDH should live as an extension of another network as if it were an L2. USDH must be the L1.

USDH has the distribution and liquidity bootstrap capabilities, with the support of the ecosystem, to activate the incredible network effects that we see with highly liquid and distributed stablecoins such as USDC, and USDT.

Bastion recommends and prioritizes stablecoin issuance for large institutions, enterprises and ecosystems to be full-stack stablecoins.

In the future, we will be issuing for smaller ecosystems, fintechs, and apps by wrapping full-stack stablecoins including USDH. Instead of funneling USDH’s liquidity into a smaller competing underlying stablecoin, we’d funnel the liquidity of smaller stablecoins into USDH.

If Hyperliquid is the blockchain to house all finance, then USDH should be the stablecoin that houses all of money. Making it a wrapped stablecoin would unfortunately achieve the opposite effect.

Other stablecoins should be built on USDH, not the other way around.

Detail your U.S. banking relationships, money transmitter licenses, and On&Off-ramp setup:

• What U.S. banking relationships do you have?
• In the U.S., what money transmitter licenses do you have? How many states can you operate in today?
• Do you—and if not when will you—have full U.S. coverage for money transmission?
• What banking networks do you support today for on&offramp (mint & burn)?

Bastion has several banking relationships with highly established banking partners including with one of the largest U.S. custodians, and the primary banking partner of the leading U.S. CEX. We support ACH, Wire, and SWIFT.

Bastion has dozens of money transmitter licenses and can operate in the vast majority of the states. Full coverage expected in the near future.

Explain your minting and burning (redemption) fee structure:

How do you charge each of the following?

• USD → USDH minting

Free

• USDH → USD redemptions

Free up

• non-USD fiat → USDH minting

Depends on jurisdiction

• USDH → non-USD fiat redemptions

Depends on jurisdiction

• non-USDH stable → USDH minting

Depends on jurisdiction

• USDH → non-USDH stable redemptions

Depends on jurisdiction

Explain your risk and compliance programs, capabilities and function:

• Do you provide the full suite of risk management and compliance capabilities needed to support a GENIUS-compliant stablecoin issuance program?
  • If yes, please provide details of the capabilities offered.
  • If no, which capabilities are offered/not offered.
• Detail the experience and qualifications of your legal, risk and compliance functions who would be overseeing the stablecoin issuance program.

As a regulated NY trust company and Money Service Business, Bastion’s risk and compliance program is designed to meet the highest standards of safety, transparency, and accountability — with the flexibility and rigor to scale globally and meet both U.S. and international regulatory expectations as Hyperliquid’s stablecoin grows.

Strong Foundation

Our compliance program empowers Hyperliquid to launch and operate a stablecoin program with confidence.

Deep Experience

Our legal, risk & compliance team combines decades of hands-on experience navigating complex regulatory landscapes and implementing robust risk management frameworks for global enterprises, bringing focused expertise to Hyperliquid’s stablecoin strategy.

Trusted Growth

We proactively monitor regulatory developments to help ensure Hyperliquid’s existing and future stablecoin issuance remains compliant, future-proof, and aligned with global standards and regulatory requirements.

Bastion’s Risk and Compliance program isn’t just a requirement — it’s a core part of how we deliver secure, scalable, and enterprise-ready infrastructure for all of our products and services, including Stablecoin-as-a-Service (Issuance), Crypto-as-a-Service (Custody), and Buy/Hold/Sell.

Our dedicated Risk and Compliance team ensures that every component of our platform operates with robust oversight and risk mitigation practices in line with regulatory requirements. This includes Reserve and Liquidity Risk Management, Listing and Delisting Risk Management, Consumer Protection Compliance, Privacy Compliance, Financial Crimes Compliance, and Third Party Risk Management.

Disclosure statement: Dibbs Trust, a subsidiary of Bastion, is chartered as a limited purpose trust company by the New York State Department of Financial Services to engage in virtual currency business.