The Birth of the First State-Level Stablecoin in the U.S.: How Wyoming Built FRNT — A Conversation with Anthony on the Story Behind the State Government

In this episode of Stableminded, Drew engages in a conversation with Anthony Apollo, the Executive Director of the Wyoming Stable Token Commission (@wyostable), discussing how Wyoming became the first state in the U.S. to issue an official stablecoin and why its operation exists outside the federal regulatory framework.

The Frontier Stable Token (FRNT) is not issued by a bank or trust company in Wyoming, but directly by the state of Wyoming as a sovereign entity. The GENIUS Act defines stablecoin issuers as "people," including banks, trusts, fintech companies, and commercial entities, but does not include "state governments" in the definition of issuers. Anthony reviews the decade-long legislative journey in detail, explaining how FRNT is deployed across seven interoperable blockchains through LayerZero, and how it collaborates with institutions like Franklin Templeton, Fireblocks, and Chainalysis to build a complete infrastructure system. The entire team that accomplished this consists of only five people, with a total budget of less than $6 million.

The application scenarios for FRNT extend far beyond Wyoming itself. Emergency relief fund disbursements that previously took 45 days can now be completed in 45 seconds; a county treasurer noted that if tax collection were moved on-chain, it could save $70,000 annually in credit card processing fees. Furthermore, through interstate compacts, other states can directly adopt Wyoming's entire mature framework—including laws, rules, policies, and technology stack—without having to rebuild from scratch.

Drew:
The Wyoming stablecoin is issued by the state of Wyoming as a sovereign entity, right? This means the issuer is the Wyoming state government itself. It is not a bank in Wyoming, nor a trust company in Wyoming, but the state government itself. This means we are essentially only subject to federal oversight and those federal rules that apply to state governments. From the current text, our position is that the GENIUS Act does not apply to the Wyoming Stable Token Commission or the Wyoming stablecoin. The reason is that the GENIUS Act defines "issuer" as "people," and "people" includes banks, trusts, fintech companies, and other commercial entities. The term "state" or "sovereign entity" is never mentioned throughout the entire bill.

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Drew:
Anthony Apollo, I’m very glad you could join the show, and I really appreciate you taking the time to participate. How has your day been?

Anthony Apollo:
Busy, very busy. There’s a lot going on with the Stable Token Commission. We just wrapped up a holiday weekend, but now we’re officially back to work.

Drew:
The construction process you’ve been going through has been almost completely public. How long have you been with the Wyoming Stable Token Commission?

Anthony Apollo:
That’s a good question and a good way to provide some background. The stablecoin bill was passed in March 2023, but prior to that, the state legislature had been laying the groundwork for several years. The commission had also done some preliminary work before that. I officially joined in September 2023, so I’m nearing my second year in this role.

In the first year, it was just me. I was literally the only person operating the entire agency. And I had no prior government experience; my background is in traditional finance and crypto startups, serving as a "bridge" between both worlds. We gradually built out the team after that. So far, the team has been operational for about a year, and the Frontier stablecoin has been launched on multiple interoperable blockchains. We will also have partners involved to demonstrate to the public how ordinary residents can obtain and use the Wyoming stablecoin.

Drew:
Yes, you’ve released a lot of news recently. We’ve been following the FRNT token and the series of infrastructure partners you’ve chosen. We’ll dive into those details later. But what I’m most interested in right now is: how did all of this happen?

From my perspective, what you’re doing actually provides a replicable framework or "recipe" for other states. I’m based in St. Louis, Missouri, and we’ve had discussions with some Missouri state representatives and senators who are very eager to learn from you. So let’s take a step back and start with your personal experience. How did you first get involved in this field? I see that you have a background with ConsenSys working on "crypto-native" projects. Can you start from earlier and give us an overall context?

Anthony Apollo:
Sure, I can even go back before ConsenSys. My career started in traditional finance, and I can say I’m a "product" of the 2008 global financial crisis. I studied accounting rather than finance, so I was assigned to serve large bank clients—G-SIBs. At that time, I mainly helped them update their regulatory reports after the Dodd-Frank Act was passed. Once you get inside these banks, you see how the system operates: the infrastructure is extremely outdated, technology maintenance has long been insufficient, and technical debt continues to accumulate.

Around the same time—in the fall of 2015—I was introduced to Bitcoin and the newly launched Ethereum, and soon my career focus began to shift in that direction. In 2017, I joined ConsenSys and participated in a project called Solarius. That was an early attempt at tokenizing intellectual property. We built a sci-fi universe set in 2084, where an AI gains self-awareness. Users could create content around this world, and we tried to tokenize all IP. There were governance tokens, IP tokens, and ERC-20 tokens for payments and royalty distribution. That was right around the time CryptoKitties launched and "clogged" the Ethereum network. Later, some commented that we were permanently ahead of our time.

In the following years, I continued to participate in similar tokenization projects. I was involved in a project called Renza, which focused on digital multimedia and real-time revenue sharing for content creators. I even participated in a compliant bond token issuance for an NBA player. That player was Spencer Dinwiddie, who was with the Nets at the time and is now with the Hornets. Essentially, it was a tokenized bond backed by his NBA contract, personal guarantees, and endorsement income, allowing investors to receive returns in stablecoin form each month.

So, I’ve been in this field for many years. In September 2021, I moved to Wyoming precisely because it is extremely open in terms of digital asset legislation. It’s a small and agile government: as long as you consistently attend meetings and provide valuable professional opinions, legislators are willing to listen.

Later, when the Stable Token Act was passed, they needed an executive director who could integrate banking, securities, legal, product, and blockchain expertise and could start working the next day in Cheyenne, a city of 60,000 people. That responsibility fell on me.

Drew:
So you moved to Wyoming and felt that it was a place where legislation could advance quickly and where new ideas could truly be heard. For those who are not legislative experts and may not fully understand what Wyoming has done over the years, could you provide an overview? For example, what sets Wyoming apart from other states? What unique actions have been taken over the years to reach this point?

Anthony Apollo:
Of course. I think it’s important to emphasize that Wyoming's efforts in the broader Web3 space can actually be traced back about ten years, to 2016. At that time, there were people in the state wanting to buy Bitcoin, but due to some local details in the Uniform Commercial Code (UCC), it was not legally possible to establish an exchange in Wyoming, and residents could not purchase Bitcoin. So the question became: how do we update existing laws?

This initiated the entire process. From 2016 to now, Wyoming has proposed a total of 80 bills related to digital assets, of which 50 have been formally passed into law, covering almost all key dimensions of digital assets. Stablecoins are just one part of it. For example, we have privacy protection clauses that explicitly state that in civil or criminal litigation, you cannot be compelled to disclose your public key, which is protected by the First Amendment—the state government cannot force you to "speak." We introduced new forms of business entities, such as DAO LLCs and DUNAs (Decentralized Nonprofit Organizations). Uniswap just voted to migrate and re-register as a DUNA in Wyoming. We allow tax payments to be made with crypto assets; the Secretary of State's office has established a digital asset registration system.

The goal of all this legislation is either to lower the barriers to doing business or to create new revenue sources for the state government. Wyoming is a state that heavily relies on oil and gas. But these resources will eventually run out. So what comes next? Digital assets could be one answer. Especially considering that Wyoming invented the LLC structure back in the 1970s, only to later be overshadowed by Delaware's better market promotion. So, the state has been exploring new entity forms, new registration methods, and the associated registration fees and fiscal revenues.

One important motivation behind the Stable Token Act is to integrate these disparate digital asset systems into a unified vehicle for value transfer. If you earn income through digital assets, register it with the Secretary of State's office, and then pay taxes with that income, it is obviously the smoothest to do all of this with a native, digital, stable asset. That’s the logic behind the existence of a state-level stablecoin.

Anthony Apollo (continued):
Another important point: the Wyoming stablecoin (now called Frontier Stable Token) is backed by a combination of cash and very short-term, conservative U.S. Treasury securities. These assets earn interest. The interest income flows back to the state government and goes directly into the School Foundation Fund as a means of diversifying fiscal revenue.

One last point, returning to the Stable Token Act itself: this is actually Wyoming's second attempt to launch a "100% reserve" financial instrument. Many listeners may be familiar with SPDI (Special Purpose Depository Institutions), such as Custodia, and Kraken has one as well. Caitlin Long, the CEO of Custodia, is very well-known in this field and has been in Wyoming for a long time. SPDI was originally a system that allowed banks or financial institutions to custody digital assets under the premise of 100% or even over-reserve. The state government invested a lot of time and effort into this system: a 770-page regulatory manual and years of system design. But ultimately, during the previous federal administration, this model was directly "squashed" by political pressure. If you look at the documents that were later disclosed, this point becomes very clear. So, the stablecoin is the second attempt: we still believe there is a real market demand for fully reserved financial instruments.

Drew:
From your perspective, you’ve experienced the environment of the previous administration and the changes now. I’ve been listening to Caitlin Long’s podcast for years, and she has repeatedly discussed the difficult journey of SPDI, which is already quite shocking. Can you share from the "frontline" perspective: what has it felt like to transition from the so-called "choke point era" to now? Whether it’s emotions, entrepreneurs, businesses returning, or the overall atmosphere—what have you observed?

Anthony Apollo:
For me personally, it’s been a 180-degree turnaround. The issue of debanking still exists. I mentioned the Solarius project earlier; in early 2018, our CEO went out to open a bank account, and when he returned to WeWork, the account had already been frozen. The account had just been approved and opened, and it was immediately frozen. For the next few months, we had no idea where the money was or if we could use it. If you work at a company that even marginally touches digital assets, you’ve likely experienced: every payment being frozen, every wire transfer being frozen, having to hold conference calls, and the bank not being able to explain why your money can’t move. That’s why stablecoins are an answer.

I want to add one more thing. One of the important reasons I moved to Wyoming to work on the Renza project was the FinTech Sandbox here. This sandbox mechanism allows companies to attempt to issue or test tokens or financial instruments that may or may not have securities characteristics within a certain scope. At the state level, as long as you keep your business within the state, the government will give you a "trial period." I remember it was a two-year period, allowing you to issue assets and test models during that time.

For us, this was very important. Because royalty income is typically not viewed as securities, but if you start to break it down, structure it, and financialize it, it could "mutate" into securities. We hoped to test this within Wyoming's FinTech Sandbox. Ultimately, the project didn’t fully advance because I later took on my current role. But looking back, the atmosphere at that time was cautious and walking on eggshells.

And now? The situation is completely different. From my personal perspective, crypto assets have become a very important variable in the recent U.S. elections. And now, the pendulum of policy has swung completely in the opposite direction. We saw USD1 launch and open for transfers during Labor Day; we began openly discussing that even when banks are closed for holidays, stablecoins can still transfer value.

This is a huge shift. I’m very glad to see that investigations and related documents around debanking are being continuously unearthed. Nick Carter has been talking about this for years, and it has had a huge ripple effect on Silvergate and Silicon Valley Bank (SVB). Caitlin Long has also discussed this for many years. And I have personally experienced all of this in my entrepreneurial journey. So for me, this shift is not abstract; it is very concrete and real.

Anthony Apollo (continued):
What excites me the most right now is that innovation is returning to the U.S., especially in the stablecoin space. Previously, we saw many companies, like Agora and Mountain, having to relocate to places like the Bahamas and Bermuda to issue interest-bearing stablecoins. They were essentially doing something very "twisted": these stablecoins are backed by U.S. Treasuries, and the interest from those Treasuries is paid by U.S. taxpayers, but those returns cannot be distributed to U.S. citizens. This is a very fractured model. I hope this situation can change, and that Frontier Stable Token can be part of that change.

Additionally, I’ve heard some data—though it may be estimates—that over the past ten years, about 2% of developer talent has been lost to overseas markets each year. Compounding that means that 25% to 30% of developers have left the U.S.

We hope these people can return to the U.S. and build here. So I’m very glad to see organizations like the Digital Chamber and Blockchain Association gradually reaping the results of their years of effort. I’m also very much looking forward to the advancement of the market structure bill. I am a strong supporter of the Responsible Financial Innovation Act (RFIA) proposed by Senator Cynthia Lummis, and I hope it can progress as smoothly as the GENIUS Act.

Drew:
Can you elaborate on that bill? I’m not particularly familiar with Senator Lummis's version.

Anthony Apollo:
Sure. The GENIUS Act has passed, but prior to that, there was actually a debate between two routes: whether to pursue specialized legislation for stablecoins or broader market structure legislation. Ultimately, the GENIUS Act won out. But now, what everyone is pushing for is a more comprehensive market structure bill that will do several very key things:

• More clearly define different types of digital assets

• Clarify the regulatory boundaries between the SEC and CFTC

RFIA is something Senator Lummis has been advocating for years. The DLx Law team has also been deeply involved. The securities token project I previously worked on collaborated with them. This bill is well-crafted in terms of language. For example, it distinguishes between primary assets and ancillary assets. I’ve always believed that unified and precise terminology is one of the most important aspects of new industry legislation.

Anthony Apollo (continued):
To give a specific example: many people ask us whether Wyoming will issue interest-bearing stablecoins. Personally, I support it. We have received formal opinions from the state legislature, particularly the Legislative Service Office, stating that under the current legal framework, it is theoretically possible to issue interest-bearing stablecoins. Of course, further research is needed.

The reason I emphasize the importance of the market structure bill is that when I say "interest-bearing stablecoin," many people don’t know what that actually means. It could refer to at least three completely different things:

• The first type: native yield or interest transfer—where we directly distribute a portion of the Treasury interest to token holders. This is the method I personally support.

• The second type: protocol-level yield—such as staking stablecoins to maintain network security and generate yield. We are currently not considering this method at all.

• The third type: a model similar to what I understand of Circle + Coinbase, where USDC is placed in a custody account for investment, then users receive a 4.95% return. This starts to look a bit like the traditional banking model of partial reserves.

So, the precision of language is crucial. I hope the market structure bill can play an important role in this regard.

Drew:
That distinction is very helpful. Language is indeed important. From our position in this industry, we have also been working hard to articulate these matters more clearly and precisely, as these nuances are truly critical.

We just mentioned what the passage of the GENIUS Act has released, but it also seems to leave some uncertainties, especially regarding the yield generation aspect. For state-issued stablecoins like Wyoming's, what details are you currently considering? What does GENIUS cover? What does it not cover? Particularly in terms of the boundaries between state and federal levels, how do you view these boundaries? I think this is important for many states, including Missouri, where we are also repeatedly contemplating these issues.

Anthony Apollo:
Of course. Let’s start with a few key points.

The first point, which is also very important: the Wyoming stablecoin is issued by the state of Wyoming as a sovereign entity. The issuer is the state government itself. It is not a bank, nor a trust, but the state government. This means we are essentially only subject to federal oversight and those federal rules that explicitly apply to state governments.

From the current legal text, we do not believe the GENIUS Act applies to the Wyoming Stable Token Commission or the Wyoming stablecoin. The reason is that the GENIUS Act's definition of "issuer" particularly emphasizes "people," and "people" is defined as banks, trusts, fintech companies, and other commercial entities. The bill does not mention "state" or "sovereign entity" anywhere.

To further clarify this point: Chris Land, the general counsel for Senator Cynthia Lummis, who is also the staff director for the Senate Banking Committee's Digital Assets Subcommittee, testified before the state blockchain special committee overseeing us, clearly stating that the Wyoming Stable Token Commission or the Wyoming stablecoin is not expected to fall under the regulatory scope of the GENIUS Act.

This also means that we must establish an entire set of rules ourselves. Our structure is as follows:

• First, the laws passed by the legislative body (statute)

• Then, the rules we establish (rules)

• Including reserve management rules

• Token management rules

• Next, policies and procedures (policies & procedures)

All of this content is public, open to public comment and review, and we welcome external oversight. Returning to the GENIUS Act itself: while the bill has been signed into law, this is not the end.

Next, there is a very important phase: the rulemaking by regulatory agencies. Particularly the SEC and other named agencies will need to undergo about an 18-month rulemaking cycle to truly refine the principles in the bill into executable regulatory requirements. So, from a time perspective, this is still a matter that is "in progress." But compared to the previous administration, we have made significant strides forward. Overall, this is a clear positive change.

Anthony Apollo (continued):
Of course, I personally have concerns about the prohibition of yield-bearing stablecoins in the GENIUS Act. The current reality is that you can issue a yield-bearing stablecoin backed by U.S. Treasuries overseas; and the interest on U.S. Treasuries is essentially paid by U.S. taxpayers. This creates a very absurd situation: overseas users can receive yields generated by U.S. Treasuries, but U.S. taxpayers themselves cannot receive those yields. I believe this is a fundamental issue. Whether this prohibition will exist long-term remains to be seen.

Drew:
To me, the provision about yields in the GENIUS Act looks like a very clear "statement of position." But I also wonder if this is a strategy to "open the door first." To write something into law, even if it’s not perfect, like signing a framework agreement to kick off a big business collaboration, and then gradually refine and adjust it later. In your view, is focusing first on payment stablecoins and temporarily shelving yield-bearing stablecoins a strategy that makes it easier to advance legislation? How do you see this choice?

Anthony Apollo:
I think your analogy is very accurate. I really like the term you used—"Minimum Viable Legislation."

Drew:
Is that a term you just coined?

Anthony Apollo:
Yes, I just made it up.

Drew:
That’s great.

Anthony Apollo:
But I do believe this is a wise and correct strategy. First of all, there has already been a lot of preliminary work done on stablecoin legislation itself. Patrick McHenry and others have pushed a lot; Senator Lummis previously proposed the Payment Stablecoin Act. There is already consensus, momentum, and a workable scope on this issue. It is a relatively clear and separable legislative issue. Before the passage of the GENIUS Act, I heard some discussions—this is not public information—where some stakeholders hoped to package the market structure bill and the stablecoin bill together or directly insert stablecoin provisions into a larger market structure bill. But that would have been nearly impossible to succeed. Because you’re trying to solve too many problems at once, and the legislative body simply doesn’t have the "appetite" for that. So, passing stablecoin legislation first was the right step.

The second point is that you could also argue that the "prohibition" on yield-bearing stablecoins in the GENIUS Act still leaves some room. This room precisely allows for subsequent regulatory rulemaking. In other words, the legislative body has delegated some interpretive authority to the regulatory agencies, allowing them to formulate more detailed and responsible rules within their jurisdiction.

Drew:
Where exactly do you see that "room"? In the GENIUS Act, what areas are not clear enough, leaving room for potential changes?

Anthony Apollo:
We now refer to it as a "prohibition," but it’s more like a moratorium mechanism found in other provisions. For example, algorithmic stablecoins: they are not permanently banned but are subject to a two-year research period. Yield-bearing stablecoins are treated in a similar manner to some extent. I can’t quote specific provisions verbatim on the spot, but structurally, it is not a completely closed-off state. Meanwhile, banking lobby groups clearly want to completely seal this loophole to ensure that the concept of "yield" is strictly excluded. The rulemaking by regulatory agencies will determine where that line is ultimately drawn.

Drew:
It sounds like the GENIUS Act is not a "completed and closed" matter, but rather an evolving framework. At least compared to the previous state of "nothing," we now have a fairly complete law:

• It defines issuers

• It defines reserve composition

• It defines what a payment stablecoin is

This could also have profound implications for IRS tax rules. For example, if stablecoins are viewed as cash equivalents, then each transaction wouldn’t need to be reported for tax purposes. So yes, things are not over, but we have taken a very significant step.

Drew:
Can you tell us more about the Wyoming Stable Token Commission itself? It sounds like you’ve been "steering the ship" almost single-handedly for a while. How is this agency organized? What is its current status? What is the team composition like? And institutionally, what is the relationship between this commission and the state government? It sounds like there is both a connection and a certain degree of separation of powers and responsibilities.

Anthony Apollo:
Yes, that’s a fair way to understand it. The Stable Token Act was passed in March 2023, and it went through multiple iterations before being passed in its current form. More oversight mechanisms were added later, especially concerning the structure of the commission itself.

The chair of the commission is Wyoming Governor Mark Gordon. Also participating in the commission are:

• State Treasurer Kurt Meyer

• State Auditor Christi Racines

In addition, there are four subject matter expert commissioners:

• Flavia Naves, former General Counsel of Circle

• Jeff Wallace, from Wyoming Bank & Trust, providing a community banking perspective

• Joel Revill, founder of Two Ocean Trust, one of the earliest Bitcoin trusts in the U.S.

• David Pope, founder of DAP CPA, focusing on digital asset taxation and consulting

They were all in place between May and July 2023. I joined in September 2023. So for the next year, I was the only full-time staff member, but I had to report to the seven commission members, one of whom is the governor.

Anthony Apollo (continued):
However, this combination is actually very ideal. The governor himself has an entrepreneurial background; he served as a Class B director at the Kansas City Federal Reserve Bank. He has signed most of Wyoming's digital asset-related laws. So it’s hard to find a more suitable chair for the commission than him. Structurally:

• The commission is a governance and oversight body

• I am responsible for daily operations, which can be understood as the "executive body"

The commission reports to a legislative body called the "Select Committee on Blockchain, Financial Technology and Digital Innovation." This committee is responsible for all digital asset and emerging technology matters in the state legislature. I report to them, and they hold multiple meetings each year, all of which are public. This special committee will meet on the 22nd and 23rd of this month, and I will testify there.

Anthony Apollo (continued):
If we need to amend the Stable Token Act in the future, it will also be initiated by this special committee and then submitted for review by the entire state legislature. As an appointed official, I cannot lobby any legislators. This complicates things to some extent because you have to wait for legislators to come to you with questions before you can formally respond and engage in discussions. So the ideal path is to present complete information through the special committee, allowing them to decide how to communicate it to the legislative body.

As for the team itself: the first year was basically just me. Later, we gradually built the current five-person team.

• Deborah Brooks: Chief Risk and Compliance Officer

• Former Deputy Superintendent of Virtual Currency at NYDFS, regulatory lead

• Joe Saldana: Chief Financial Officer

• Wall Street veteran

• Has held multiple roles including CCO, COO, CIO

• Even built his own oracle due to "not being able to obtain reliable digital asset pricing data"

• Keith Lohorn: Chief Information Security Officer

• Background includes the Department of Homeland Security, Microsoft, and the Federal Reserve System

• Also well-versed in finance, technology, and cybersecurity

• Steph Chan: Senior Business and Project Management Analyst

• Has about 10 years of experience in the crypto industry

Adding me, that makes a total of five people. We are responsible for everything. Most government agencies have multiple departments: technology, HR, finance, operations, each with clear divisions of labor. But we don’t have that. There’s no operations manual. No one puts a document on your desk saying, "This is how the Wyoming state government operates; just follow it." Especially in such a niche agency like ours, many people didn’t even know this commission existed in the first year. So a lot of work has been done on the fly. The challenges are numerous.

Drew:
In such a small team with extremely ambitious goals, what do you think the biggest challenges are? Especially from the perspective of "infrastructure building," what key trade-offs have you made strategically?

Anthony Apollo:
I’m glad you mentioned infrastructure because one of the most typical challenges is procurement. We know that with only five people and a budget of less than $6 million, we cannot hire 20 engineers to write all the code from scratch. And it wouldn’t make sense to do so. So the goal of this project from the beginning has been to bring in existing, verifiable partners and vendors.

Before formally starting the procurement process, we had to tighten the scope. If we didn’t limit which blockchains could be deployed from the outset and just launched procurement, it would essentially turn into a "free-for-all" situation, completely out of control. So the first thing we did—and we welcome external feedback on this step—was the Blockchain Selection Exercise.

We formed a working group: several commission members participated, team members were involved, and several external subject matter experts joined. We listed about 30 candidate blockchains and established 30 evaluation criteria. Among them, five were "hard thresholds" that must be met to enter the scoring phase. For example:

• Is it a public and permissionless network?

• Is there an on-chain access permission mechanism?

• Is there coverage from mainstream on-chain analytics companies?

• Does it support freeze & seize functionality?

This point is crucial because the GENIUS Act has explicit requirements for this. Of course, I personally believe that any form of asset intervention must be based on a legitimate court order; we can elaborate on this topic later, but it is indeed one of the necessary capabilities.

Drew:
Can you briefly explain what freeze & seize means for listeners who may not be familiar with the concept?

Anthony Apollo:
Sure. In simple terms, it refers to whether we have the ability to intervene with tokens.

• Freeze: Prevent tokens from continuing to transfer

• Seize: Extract the corresponding dollar value from a wallet

A few points need to be emphasized:

First, this is explicitly required in the GENIUS Act;
Second, other stablecoin issuers also have similar capabilities.

Some people may worry, "Will the state government arbitrarily seize everyone’s money?" I actually think the opposite. If you look at the service terms of other issuers, there is often a whole list of "prohibited actions" and "transaction restrictions," many of which can change with the current political or ideological shifts. But we have written very clearly in our user agreement: you can use the Wyoming stablecoin for any legal purpose. The definition of legal includes federal law, Wyoming state law, and the laws of your jurisdiction. Of course, activities like human trafficking will never be allowed. But as long as it’s a legal purpose, we will not proactively freeze or seize your assets. Moreover, unless there is a legitimate court order, we have no power to freeze or seize anyone’s tokens.

Drew:
Okay, let’s return to the blockchain evaluation process you mentioned earlier.

Anthony Apollo:
The core purpose of this process is actually to provide a reference for other states on how to evaluate open-source technology. Because traditional state government procurement systems are accustomed to buying 2x4 lumber, paving roads, and building buildings, they are not adept at evaluating open-source blockchain technology.

So what we did was:

• Complete the evaluation in a fully public environment

• Involve multiple parties

• Publicly score

• Allow project parties to provide feedback on the scoring results

Now, this evaluation has become a quarterly routine mechanism to confirm which blockchains are our "Candidate Blockchains."

After confirming the first batch of candidate blockchains that can support retail-level scale and performance, we formally entered the procurement phase. Next, we released various documents: RFQ (Request for Qualifications), RFP (Request for Proposals), clearly stating:

• What capabilities you need to have if you are issuing tokens

• What level of financial institution you need to be if you are managing reserves

These documents are still publicly available on our website (we are in the process of migrating to a new site). The focus is that we must customize a procurement process that ensures fairness while not attempting to evaluate "all blockchain companies in the world." We did tighten the scope in certain areas, but every step was public and approved by the commission.

Drew:
So you ultimately chose Avalanche, right?

Anthony Apollo:
We initially launched on seven chains, and they are interoperable.

Drew:
Oh, which seven are they?

Anthony Apollo:
We are currently deployed on:

• Avalanche

• Ethereum

• Solana

And the following Layer 2 networks:

• Arbitrum

• Base

• Optimism

• Polygon

That makes a total of seven.

Additionally, two more chains passed the first round of evaluation: Stellar and Sui. Once our current partners have the capability to support them, we will integrate them as well.

After that, we also added evaluations for Aptos and Hedera. We will continue to advance according to the process: testing → launching → liquidity assessment → then move on to the next chain. We are working with LayerZero, which supports interoperability across 140 chains, but we cannot launch all 140 chains at once. That would fragment liquidity. So we are very restrained and cautious in our chain selection.

Anthony Apollo (continued):
As a state government agency, we almost "inevitably" have to make choices in procurement. But from a policy perspective, we do not want to "pick winners." Therefore, the state blockchain special committee has given us a clear mandate: multi-chain and tech-agnostic.

Honestly, I initially thought we would launch on one chain first and then gradually expand. But LayerZero’s solution is strong enough that it enabled us to have interoperability from day one. So the current state is: a multi-chain launch from the start, with continuous expansion in the future.

Drew:
Very cool. What other key infrastructure or partners are involved? How has the entire tech stack come together in the actual implementation of the Frontier stablecoin?

Anthony Apollo:
Let me quickly address the vendors and infrastructure side. I typically break the lifecycle of a stablecoin into three phases: development → deployment → ongoing operational management. This covers everything from smart contract issuance to private key management, backend infrastructure, reserve management, compliance, and auditing. In terms of specific roles:

• LayerZero: Responsible for smart contract issuance and cross-chain interoperability

• Fireblocks: Responsible for private key management and backend infrastructure; all management of our smart contracts is done here

• Franklin Templeton: Responsible for reserve management, including custody and investment of dollar funds (mainly in Treasuries)

• Chainalysis and Inca: Responsible for on-chain analysis and open-source intelligence, ensuring that bad actors do not use the Wyoming stablecoin

On the financial side:

• The Network Firm: We hired them as our financial auditing and attestation agency

I actually have high ambitions in this area. I hope we can become the industry benchmark for audit transparency.

Anthony Apollo (continued):
My goal is to push for real-time attestation as soon as possible. The Network Firm has a component that can achieve this:

• Real-time indexing of all blockchains we deploy

• Real-time capturing of the total issuance of Frontier stablecoins

• Directly reading reserve data from the banking side through API

• Checking every 30 seconds whether we are always over-collateralized

I believe this will become the best practice for the entire industry. I also hope we can be one of the first issuers to achieve this.

Drew:
So The Network Firm is your attestation partner, right?

Anthony Apollo:
Yes, that’s correct.

Drew:
That’s very interesting. Because most stablecoin issuers do audits or disclosures either monthly or quarterly. And what you just mentioned is: minute-level or even real-time.

Anthony Apollo:
Why not? Of course, to clarify: this won’t be achieved on day one. We need time to push the token to market and initially release monthly reports at a regular pace. We will do a few things:

• Publish monthly balance sheets

• Publish monthly income statements

• Publish monthly cash flow statements

To be honest, these things are not required of any other agency within the Wyoming state government. But we want to achieve the maximum level of transparency. For the first few months, we will use monthly attestations. But the long-term goal is very clear: real-time attestation. Drew, to be honest, blockchain is real-time, APIs are real-time, what reason is there not to do this? I think people in the industry should start asking these questions more. Because only then will the system be faster, more robust, and more trustworthy.

Drew:
Indeed. This sounds more like an inertia of doing things under an old framework rather than fully leveraging the capabilities of new technology. I will take a closer look at The Network Firm. I am very optimistic about the entire "attestation layer." Especially since the GENIUS Act now explicitly requires attestation, these companies are clearly at the forefront of the wave.

Anthony Apollo:
One more thing to add: they are completely independent third parties from us. Attestation must maintain "arms-length principles." Everyone can conduct their own due diligence.

Drew:
Yes, I also need to add a disclaimer (laughs). What role does Rain play in the entire system? Primarily on the card product side, right?

Anthony Apollo:
Yes. We have officially announced that Rain is one of the early distribution partners for the Frontier stablecoin. I want to particularly emphasize the "terminology" issue here. You may have noticed that I still use the term "Wyoming stablecoin." This is because "Wyoming stablecoin" is legally a type of stablecoin that defines a whole set of:

• Reserve structure

• Reserve management rules

• Token management rules

• Policy processes

• User agreements

Theoretically, there can be multiple "Wyoming stablecoins."

Anthony Apollo (continued):
For example, there may be interest-bearing Wyoming stablecoins in the future. And the Frontier Stable Token is just the first instance we are issuing. We place great importance on the collaboration with Rain and Avalanche because I firmly believe that to scale stablecoins, users must use familiar forms.

Cards are the most mature payment vehicle. Rain’s card product:

• Can be used like a regular Visa card

• Can directly consume Wyoming stablecoins

• Can also connect to the traditional Visa network

This means:

• Access to 150 million Visa terminals

• Direct integration with Apple Pay / Google Pay

Combined with Avalanche’s high performance, low fees, and interoperability with our other chains, this will become a key growth lever in a very short time.

Drew:
We’re down to the last few questions. I feel like we’ve just entered the most interesting part, but time is indeed short. One of the biggest concerns for many state legislators is: what are the actual use cases? Who will use it? Why is it faster? Why is it cheaper? Why is it more convenient? In your view, how will ordinary people and institutions in Wyoming truly participate? How does this actually "land" in reality?

Anthony Apollo:
This is a very important question. First, it should be noted that the Frontier stablecoin is a global product. It is not limited to the population of Wyoming. If it relied solely on the population size of Wyoming, this model would not be economically viable. So this is a product aimed at the U.S., international markets, and DeFi.

Let me give you two specific examples.

The first example is a demonstration project we did with Hashfire. Hashfire is a company registered in Wyoming and built on Avalanche, which automates contracts, similar to DocuSign, but automatically pays vendor invoices once approvals are completed. Currently, the state government’s process for handling invoices has a statutory period of 45 days. Through Hashfire + Frontier stablecoin: the approval process is automated, payments are executed automatically, and the entire cycle can be shortened to 45 seconds. This is just one example of internal use within the state government, not even counting public-level applications.

The second example: after this demonstration, local media Cowboy State Daily reported a potential application scenario—emergency relief fund disbursement. Around this time last year, there were large-scale wildfires in northern Wyoming and Montana, burning approximately 850,000 acres. In a disaster of this scale:

• Rapid deployment of volunteers is needed

• Equipment is needed

• Machinery rentals are needed

• Supplies and water are needed

All of these require contracts and payments from the state government. If we can reduce the "45-day payment process" to "a few minutes," it would be a tectonic shift.

Let me give you one more example. A county treasurer recently contacted me, saying they collected about $3.4 million in taxes last year, and credit card fees amounted to $70,000. If tax payments were moved on-chain, these fees could potentially drop to almost zero. And this doesn’t even mention: transparency, auditability, and real-time capabilities.

Anthony Apollo (continued):
One last point. Since we launched the Frontier stablecoin, we have received a lot of attention from other states, foreign governments, international organizations, and NGOs. But we are never looking to compete with private companies like Circle or Tether. Our goal is not to compete "public vs. private." I believe we can become the preferred stablecoin for the public sector, especially in the area of aid fund disbursement.

Now many aid organizations are starting to contact us. They have found that in the past, only about 12% of funds in U.S. aid projects actually reach the recipients. The rest are consumed at various levels. Through the Frontier stablecoin, 100% of the funds can go directly to the recipients. That is exactly what we hope to achieve.

Drew:
Last question. From your current position, as someone who is truly at the forefront and has already "gone into practice," what would you say to other states, other countries, or even others considering similar initiatives?

Anthony Apollo:
Let me quickly add one piece of information: although the token has been deployed, we have not yet officially opened it for public purchase. Our target date is September 18, which is the date of the next commission meeting. At that time, we hope the token can be officially opened to the public, and some partners will also demonstrate the complete process on-site.

Stepping back, if other states, countries, or international organizations want to do something similar: I would say that Wyoming has taken 10 years of legislation, 2 years of construction, 1 year of procurement, and a lot of rulemaking to get to where we are today. Yes, we are open to building, and theoretically, others can "copy" what we’ve done. But if you want to do it entirely on your own, it’s extremely difficult. You need: a highly supportive legislative body, the right leadership, and the right team.

If you are willing to collaborate with us, we are completely open. We have already made it clear that we are exploring interstate compacts. Just last month on the 19th, we announced this idea, and on the 20th, we started sitting down to talk with various parties.

Drew:
What do interstate compacts specifically refer to?

Anthony Apollo:
It means that multiple states can come together to directly adopt:

• Wyoming’s laws

• Wyoming’s rules

• Wyoming’s policies

• Wyoming’s technology stack

And then quickly deploy their own stablecoins. The names can be different. Frontier is ours, and other states can have their own. We can design: revenue-sharing mechanisms, reserve metrics, governance structures. We have already set up the framework. Why not let more public entities use it? Why not make global aid disbursement: more efficient, more transparent, and fairer? Pick any adjective, and we can likely achieve it.

Drew:
This really reminds me of how LLCs were originally created. "The framework is already there; just use it." Anthony, thank you very much. Thank you for taking the time and for the efforts of your team over the years. This is an exciting juncture, and we will definitely chat again.

Anthony Apollo:
Thank you, Drew. I’m glad to participate. There’s still a lot of progress ahead, so let’s stay in touch.