Lumen Pay: how a stablecoin issuer moved its reserves out of Europe

Demonstration article. Lumen Pay, the people, documents and figures cited are fictional.

• Between early 2025 and mid-2026, the share of Lumen Pay’s reserves held with European banks fell from 78% to 31%.
• A quarter of reserves is now invested through two affiliated entities set up in 2025, whose assets are not disclosed.
• The issuer remained compliant at every reporting date, but holders were never clearly told about the shift.

When Lumen Pay launched its euro-backed token in early 2025, the company put forward a simple argument: almost all of its reserves were deposited with leading European banks. The first attestation report, published in the spring, confirmed it. 78% of reserves took the form of bank deposits in the Union, 18% treasury bills and 4% other investments.

Eighteen months later, the picture had changed. According to the report for the second quarter of 2026, European bank deposits accounted for only 31% of the total. Treasury bills, now held through a custodian located outside the Union, made up 44%. And a quarter of reserves was invested “via affiliated entities”, a category that did not exist in the first reports.

A shift quarter after quarter

No single quarter marks a break. The share of European deposits falls by seven to twelve points with each report. Taken in isolation, every decline can be explained: the search for yield in a rate environment, diversification of counterparties, rapid growth in the amount outstanding that requires new places to invest.