Pay
Pal
BLOCKCHAIN, CRYPTO AND DIGITAL CURRENCIES (BCDC)
POLICY MEMORANDUM
Global Regulatory Affairs & Financial Integrity
TO:
Product Engineering, Global Compliance, Risk Operations, and Merchant Services
FROM:
O
ffi
ce of the Chief Executive O
ffi
cer & SVP, Blockchain, Crypto and Digital Currencies
DATE:
September 18, 2026
SUBJECT:
PayPal Cryptocurrency Policy & Digital Asset Governance
1. STRATEGIC INTENT & MARKET CONTEXT
The transition toward digital currencies and programmable
fi
nancial rails represents a fundamental evolution in global
commerce. As one of the world's most trusted two-sided payments networks, PayPal is uniquely positioned to bridge
mainstream consumers and merchants with regulated, interoperable digital asset ecosystems.
This policy directive de
fi
nes the operational, compliance, and product standards governing customer retail crypto
services, off-chain liquidity provisioning, cross-border settlement rails, and the institutional issuance architecture for
PayPal USD (PYUSD).
2. FOUNDATIONAL PILLARS OF DIGITAL ASSET ARCHITECTURE
All business lines integrating cryptocurrency features must adhere strictly to three foundational architectural
requirements:
Fully Backed, Regulated Stablecoin Operations (PYUSD):
PYUSD is issued exclusively by licensed trust entities
(Paxos Trust Company) under direct supervision of the New York State Department of Financial Services (NYDFS),
backed 100% by U.S. dollar deposits, short-term U.S. Treasuries, and cash equivalents.
Zero Volatility Exposure for Merchants:
Merchants accepting cryptocurrency or stablecoins settle automatically
into their preferred local
fi
at currency by default, eliminating balance sheet exposure to market price
fl
uctuations.
Bi-directional Portability & Self-Custody Interoperability:
Veri
fi
ed consumer and merchant accounts retain full
capability to transfer supported digital assets seamlessly between PayPal, Venmo, and compliant third-party
external hardware or institutional wallets.
Core Risk Principle:
Mainstream adoption requires unquestioned stability and transparency. We do not participate in
unbacked algorithmic tokens, speculative yield lending, or proprietary liquidity arbitrage. Every unit of stablecoin within
our ecosystem represents veri
fi
ed, liquid reserves held in segregated custody.
3. CONSUMER ASSET SAFEGUARDS & ASSET WHITELISTING
Retail asset support is restricted to established, highly liquid digital currencies that satisfy rigorous regulatory,
technical, and anti-money laundering (AML) standards. Additions to the asset roster require unanimous approval from
the Enterprise Digital Asset Governance Committee.
PayPal Holdings, Inc.
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Internal Regulatory & Product Policy
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