Integrating DAOs and DUNAs with Stablecoin Ecosystems

We have analyzed Decentralized Autonomous Organizations (DAOs) and how the GENIUS Act  will permit regulation of payment stablecoins in prior articles.^[1]  This article examines how decentralized organizations interact with stablecoin ecosystems and the synergies between organizational and payment infrastructure innovation.

The connection is natural: DAOs need stable value to operate effectively, while stablecoin protocols need governance structures to manage their evolution. Wyoming’s leadership in both DUNA legislation and state-issued stablecoins creates unique integration opportunities.

DAOs and Treasury Management

Stablecoins have become the bedrock of DAO treasury management. As of 2025, stablecoins represent 18.2% of DAO treasury holdings, with service-oriented DAOs averaging over 41% in stablecoins—reflecting a strong preference for liquidity and risk management. Stablecoin vaults have emerged as the strategic backbone of on-chain treasury management.^[2]

The Role of Stablecoins in DAO Treasuries

DAOs face a fundamental challenge: they operate in volatile cryptocurrency markets while needing stable value to fund operations, pay contributors, and plan long-term. Native tokens like ETH or protocol-specific governance tokens fluctuate unpredictably. Stablecoins provide the stability that enables budgeting and operational continuity.

Best practices have emerged around tiered treasury management:

Operational runway (3-6 months): Easily accessible stablecoins like USDC or DAI for immediate expenses, contributor payments, and vendor obligations.

Strategic reserves (6-12 months): Low-risk DeFi lending or staking positions that generate yield while maintaining accessibility.

Long-term growth allocations (12+ months): More aggressive yield strategies for capital not needed in the near term.^[3]

The Arbitrum DAO consolidated $2.54 million in idle USDC into its Treasury Management Committee in July 2025 to optimize yield generation, illustrating how major DAOs actively manage stablecoin positions.^[4]

USDC vs. DAI: Centralization Trade-offs

DAOs face a philosophical choice between centralized stablecoins like USDC and decentralized alternatives like DAI.

USDC offers regulatory compliance, monthly attestations, and 1:1 dollar backing. Its availability across multiple blockchain networks allows DAOs to operate across ecosystems without switching stablecoins. However, USDC’s centralized issuer (Circle) can freeze addresses, creating censorship risk.

DAI, now transitioning to USDS under the Sky protocol, aligns with decentralization values but introduces complexity through its collateralized debt position mechanism and governance overhead.

The choice depends on organizational priorities: stability and regulatory alignment favor USDC; decentralization and censorship resistance favor decentralized alternatives.

FRNT as a Treasury Asset

Wyoming has recently  introduced a new option: FRNT, a state-issued stablecoin with 102% overcollateralization, Franklin Templeton reserve management, and no private profit motive.

For DAOs, FRNT offers potential advantages:

Government backing: Unlike private stablecoins, FRNT carries the implicit backing of Wyoming state government, potentially reducing counterparty risk.

Regulatory positioning: FRNT operates outside the GENIUS Act’s “business entity” definition,  creating a distinct regulatory status that some DAOs might find attractive.

Alignment with public purpose: DAOs focused on public goods might prefer a stablecoin whose yield supports public education rather than private shareholders.

However, FRNT’s limited circulation and exchange availability currently restrict its practical utility as a treasury asset. As the Wyoming Stable Token Commission expands partnerships through 2026, treasury use cases may become more viable.

DeFi Protocol Governance

Some of the most significant DAOs govern stablecoin protocols themselves. The governance of these protocols illustrates the intersection of organizational structure and stablecoin design.

Sky Protocol: Governance Evolution

MakerDAO’s transition to Sky Protocol in 2024-2025 demonstrates the complexity of governing a major stablecoin system. The protocol completed its “Endgame” transition in May 2025, retiring the MKR governance token and launching SKY as its successor.^[5]

The scale is substantial: USDS (the DAI successor) grew from $5.3 billion to $9.86 billion supply during 2025, an 86% increase. The protocol oversees over $7.8 billion in stablecoin liabilities across DAI and USDS.^[6]

Sky’s governance structure includes:

Token-weighted voting: SKY holders vote on protocol parameters, risk management, and treasury allocations.

Real-world asset integration: The protocol has expanded into off-chain lending, including arrangements with Anchorage Digital for up to $200 million in exposure.

Ecosystem expansion: Keel, Sky’s on-chain capital allocator, launched a $500 million campaign to attract tokenized assets to Solana.^[7]

However, one year after the transition, adoption metrics have flatlined in some areas, illustrating that governance innovation does not automatically translate to market growth.

Regulatory Compliance Through Structure

The Uniswap DUNI adoption demonstrates how governance structure enables regulatory compliance. By establishing DUNI as a Wyoming DUNA, Uniswap created an entity that can:

• Sign contracts with service providers
• Retain legal counsel and auditors
• File taxes as an organization
• Activate protocol fees with legal clarity

The $16.5 million allocation to DUNI for legal defense and tax compliance acknowledges that operating as a compliant entity requires ongoing investment.^[8]

This pattern may repeat across DeFi. High-profile enforcement actions, including the Ooki DAO case and Samuels v. Lido DAO, have demonstrated regulatory willingness to pursue unstructured DAOs through partnership law. The Lido case confirmed that all members, including venture capital firms, could face unlimited personal liability for organizational obligations.^[9]

Decentralized Unincorporated Nonprofit Associations (DUNAs) offer an alternative: legal structure that preserves decentralized governance while providing liability protection.

Payment Infrastructure DAOs

The combination of DUNA organizational structures and regulated stablecoins creates potential for community-governed payment networks.

The Opportunity

Traditional payment networks like Visa and Mastercard operate as for-profit corporations, extracting fees that fund shareholder returns. Blockchain-based payment infrastructure could operate differently: as nonprofit networks where fee revenue funds development and maintenance rather than dividends.

A DUNA-structured payment network could:

• Operate stablecoin payment rails as a nonprofit public utility
• Govern protocol upgrades through token-holder voting
• Direct fee revenue to network development and maintenance
• Maintain open-source infrastructure accessible to all

Current Limitations

No major payment network currently operates as a DUNA. The requirement that a DUNA have at least 100-members, untested legal status, and banking access challenges create barriers to adoption.

However, the building blocks exist. FRNT operates on seven blockchains with cross-chain transfer capability. LayerZero’s OFT standard enables unified tokens across networks. DUNAs provide legal recognition for decentralized governance.

A future payment infrastructure DAO might combine these elements: a DUNA-structured organization governing a multi-chain stablecoin payment protocol, with FRNT or similar state-issued stablecoins as the settlement layer.

Open-Source Stablecoin Infrastructure

The DUNA framework explicitly supports open-source development. The statute permits profit-making activities if profits further the nonprofit purpose, and allows reasonable compensation for services provided to the ecosystem.^[10]

This structure could support development of:

• Open-source wallet software for stablecoin payments
• Interoperability protocols connecting different stablecoin networks
• Compliance tools enabling regulated stablecoin use
• Developer tooling for building on stablecoin infrastructure

WYDE launched $EAT on December 10, 2025, as the first impact-focused DUNA. Unlike Syndicate and Uniswap, which use the DUNA framework for protocol governance, WYDE applies it to charitable funding.  This framework can support novel use cases beyond traditional protocol governance.

Tokenization and DAOs

RWA tokenization represents one of the fastest-growing areas of blockchain application, and DAOs play a central role in governance.

Centrifuge: Tokenization at Scale

Centrifuge has emerged as a leading real-world assets (RWA) tokenization platform, with total value locked surging from under $100 million to over $1.2 billion during early 2025.^[11]

The platform’s governance has evolved significantly:

Token migration: In August 2025, 241 million legacy tokens migrated to Ethereum-native CFG, unifying governance across chains.

Committee structures: The DAO added expert committees, including a Treasury Advisory Group, to oversee financial risk and transparency.

Governance pause: Proposal CP171 paused active DAO governance in late 2025, shifting execution to the Centrifuge Network Foundation for faster decision-making.^[12]

Tokenization Platform as DUNA

Centrifuge’s November 2025 launch of Centrifuge Whitelabel, a tokenization platform for institutions, illustrates opportunities for DUNA-structured tokenization services.

A tokenization platform operating as a DUNA could:

• Provide infrastructure for creating tokenized financial products
• Govern standards for token issuance and compliance
• Operate as a nonprofit utility rather than extractive intermediary
• Distribute governance to platform users

Daylight, the first project building on Centrifuge Whitelabel, is creating tokenized vaults for energy infrastructure assets. Similar platforms could tokenize credit funds, equity indices, or other asset classes under community governance.

Sky’s RWA Expansion

Sky Protocol’s expansion into real-world assets demonstrates how stablecoin protocols integrate tokenization. The protocol’s Solana-focused campaign aims to channel up to $2.5 billion into tokenized finance, using USDS as the stablecoin layer for RWA products.^[13]

This integration creates a stack: tokenized assets governed by DAOs, settled in stablecoins, with legal structure provided by frameworks like DUNA.

Wyoming’s Unique Position

Wyoming provides both organizational structures (DUNA, DAO LLC, SPDI) and stablecoin infrastructure (FRNT). No other jurisdiction offers this combination.

Organizations building at the intersection of DAOs and stablecoins can:

• Form DUNAs for nonprofit governance of stablecoin-related activities
• Use FRNT for treasury management with state-backed stability
• Access Wyoming’s crypto-friendly banking infrastructure through SPDIs
• Operate under clear legal frameworks developed over a decade of legislation

The state’s approach treats blockchain innovation as economic development, creating regulatory environments that attract projects rather than drive them offshore.

The convergence of federal stablecoin regulation through the GENIUS Act and state innovation around organizational structures like the DUNA provides the regulatory certainty needed for the crypto sector to integrate with the traditional economy. The nonprofit framework is particularly significant: it offers a path for community-governed financial infrastructure that protects consumers and investors while preserving the decentralization principles that make blockchain technology distinctive. As these frameworks mature through 2026 and beyond, Wyoming’s pioneering combination of organizational and payment infrastructure may serve as a model for other jurisdictions seeking to foster responsible innovation.

^[1]Wyoming Laws More Crypto-Friendly with State Stablecoin;  GENIUS Act Establishes Legal Framework for Stablecoins; Formation and Operation | Decentralized Autonomous Organization (DAO).

^[2]CoinLaw, “DAO Treasury Holdings Statistics 2025: Decentralized Wealth,” November 19, 2025, https://coinlaw.io/dao-treasury-holdings-statistics/

^[3] OnChain Treasury, “Best Stablecoin Vaults for Maximizing DAO Treasury Yield in 2025,” November 2025.

^[4]AInvest, “USDC’s $2 Billion Surge and Its Implications for Crypto Payroll and DAO Treasury Strategies,” September 2025.

^[5]Messari, “What is Sky Protocol?” https://messari.io/project/sky-protocol/profile. 

^[6]Blockworks, “One year into Sky, adoption lags behind vision,” 2025.

^[7]CoinMarketCap, “Latest Sky News,” 2025.

^[8]Uniswap Governance, “Establish Uniswap Governance as ‘DUNI,’ a Wyoming DUNA,” Proposal 90.

^[9]Calibraint, “DeFi Regulatory Compliance 2025: Master SEC & CFTC Rules.”

^[10]Wyo. Stat. § 17-32-106.

^[11]Edgen Tech, “Centrifuge 2025 Q4 Outlook: Unlocking Trillions in Real-World Assets.”

^[12]CoinMarketCap, “Latest Centrifuge News,” 2025.

^[13]CoinMarketCap, “Latest Sky News,” 2025.