Regulation determines who can issue, who can buy, and where capital can flow. Every player on the map operates under at least one of these frameworks. This page maps the ones that matter.
United States
SEC Regulation D
US issuers selling tokenized securities to accredited investors
// Reg D is how BUIDL, OUSG, BENJI, USTB, and every other tokenized fund on the map exists in the US. Securitize, Ondo, Franklin Templeton, Superstate. All of them. 61 players on this map operate under it. The exemption works, but it walls off retail completely. Only accredited investors, 12-month hold periods, no public marketing under 506(b). That ceiling is why the entire industry watches the SEC for broader reform. If Reg D is the only path, tokenization stays institutional forever.
Exemption allowing sale of securities without registration to accredited investors. Primary path for RWA token offerings in the US.
- •Rule 506(b): unlimited raise from accredited investors, no general solicitation
- •Rule 506(c): allows general solicitation but requires verification of accredited status
- •No SEC registration required, but must file Form D within 15 days of first sale
- •Securities are restricted with a 6-12 month holding period before resale
- •No limit on the amount of capital that can be raised
File Form D with the SEC, restrict sales to accredited investors (or verify accreditation under 506c), and enforce transfer restrictions during the holding period.
SEC Regulation S
US-based issuers selling tokenized securities to non-US investors
// Reg S is the other half of the equation. Ondo runs USDY under Reg S for non-US investors while OUSG runs under Reg D domestically. Securitize does the same split with BUIDL and ACRED. Every serious issuer pairs D and S together to cover both sides of the Atlantic. The hard part is enforcing it onchain. Blocking US persons from touching a Reg S token requires compliance middleware, which is exactly why Securitize's DS Protocol and Tokeny's ERC-3643 exist. The regulation created the middleware market.
Exemption for offshore offerings of securities. Used by US issuers to sell tokens outside the United States.
- •Offering must occur outside the United States with no directed selling efforts in the US
- •Category 1 securities (foreign issuers, no US market interest) have minimal restrictions
- •Category 2 and 3 securities require a 40-day or 1-year distribution compliance period
- •Resale to US persons during the compliance period is prohibited
- •Must include contractual transfer restrictions to prevent flowback into the US
Structure the offering entirely offshore, implement transfer restrictions preventing US person participation, and observe the applicable distribution compliance period.
SEC Spot Bitcoin/Ethereum ETF
ETF issuers, authorized participants, custodians, and exchanges listing spot crypto ETFs
// BlackRock's iShares Bitcoin Trust pulled in $10B+ within months. Grayscale converted GBTC. Fidelity, VanEck, Bitwise, Invesco, WisdomTree all launched. Coinbase became the custodian for most of them. The ETF approvals did not just legitimize crypto as an asset class. They proved the SEC would let traditional wrappers hold digital assets. That precedent is why the industry now expects tokenized RWA ETFs next. The wrapper is what TradFi trusts, and now the wrapper exists.
Approval of spot Bitcoin and Ethereum ETFs, legitimizing crypto as an asset class for traditional investors.
- •Spot Bitcoin ETFs approved January 2024 under Securities Exchange Act Rule 19b-4
- •Spot Ethereum ETFs approved May 2024 with similar structure
- •Custodians must meet SEC custody requirements for digital assets
- •Authorized participants handle creation/redemption via in-kind or cash models
- •Daily NAV calculation and transparency requirements apply
File 19b-4 rule change with the exchange and S-1 registration with the SEC. Appoint a qualified custodian and establish NAV methodology.
DTCC Tokenized Settlement Initiative
DTCC member firms, custodian banks, broker-dealers, and infrastructure providers participating in the pilot
// DTCC processes virtually all US securities settlement. When they pilot onchain settlement, it is not an experiment. It is the roadmap for the entire post-trade stack. BlackRock, JPMorgan, Goldman Sachs, Citi, State Street, BNY Mellon, Morgan Stanley, Fidelity, Nasdaq, ICE/NYSE are all in the pilot. The Smart NAV pilot already validates fund data onchain. If T+0 settlement works here, every custodian, broker-dealer, and clearinghouse on the map has to adapt. This is the single most consequential initiative for whether tokenization becomes infrastructure or stays a sideshow.
DTCC pilot program for settling tokenized securities onchain, targeting T+0 settlement by 2026.
- •Smart NAV pilot validates onchain fund data using blockchain as a golden record
- •Exploring tokenized collateral management for same-day settlement
- •Partnership with major custodian banks and broker-dealers for pilot testing
- •Integration with existing DTCC settlement infrastructure (DTC, NSCC, FICC)
- •Targeting T+0 settlement for tokenized securities by 2026
Participate as a DTCC member or pilot partner. No new regulatory requirements yet, but pilot participants must meet existing DTCC membership and operational standards.
GENIUS Act (US Stablecoin Legislation)
Stablecoin issuers operating in or serving US users
// GENIUS passed the Senate. That is further than any US crypto bill has ever gotten. The framework is straightforward. 1:1 reserves, monthly attestations, federal oversight above $10B. Circle is already positioned. They have the reserves, the audits, the state licenses. Paxos too. Tether is the wildcard. $184B in circulation, offshore issuance, and a federal regime that would require them to either come onshore or lose US market access. PayPal's PYUSD already meets most proposed requirements. The $10B threshold is the dividing line. Below it, state charter works. Above it, you answer to the OCC.
The GENIUS Act (Guiding and Establishing National Innovation for US Stablecoins) passed the Senate in 2025. The House companion bill, STABLE Act, covers similar ground. Together they represent the first federal framework for payment stablecoins.
- •Payment stablecoin issuers must maintain 1:1 reserves in high-quality liquid assets
- •Federal registration required for issuers above $10B; state charter permitted below
- •Monthly reserve attestations by registered public accounting firms
- •Prohibition on algorithmic stablecoins without full collateral backing
- •Reciprocal recognition framework for foreign stablecoin issuers
Register with the OCC or a state banking regulator, maintain 1:1 reserves in eligible assets, publish monthly attestations, and comply with AML/KYC requirements.
SEC SAB 121 / SAB 122 (Crypto Custody)
Banks, trust companies, and regulated custodians holding digital assets for clients
// SAB 121 was the single biggest blocker to institutional crypto custody. It forced banks to put custodied crypto on their own balance sheets, which triggered massive capital requirements under Basel rules. BNY Mellon, State Street, and every other custody bank froze. Congress passed a repeal. Biden vetoed it. The SEC finally reversed course with SAB 122 in January 2025. That reversal is why the map now shows custody banks re-entering the space. Without SAB 122, half the institutional infrastructure layer on this map would still be on the sidelines.
Staff Accounting Bulletin 121 (2022) required banks to record custodied crypto as liabilities on their balance sheets, effectively blocking bank custody of digital assets. SAB 122 (2025) reversed this, removing the balance sheet treatment and unblocking institutional custody.
- •SAB 121 (2022) required custodied crypto to appear as liabilities on bank balance sheets
- •This made crypto custody prohibitively expensive for regulated banks under Basel capital rules
- •Congress passed a repeal in 2024 but Biden vetoed it
- •SAB 122 (2025) reversed SAB 121, removing the on-balance-sheet requirement
- •Banks can now custody digital assets using standard off-balance-sheet safekeeping treatment
Follow standard custodial accounting treatment for digital assets. The punitive on-balance-sheet requirement from SAB 121 no longer applies under SAB 122.
Executive Order on Digital Assets (2025)
All federal agencies, financial regulators, and digital asset market participants
// This EO set the tone for the entire current regulatory posture. The CBDC ban, the Strategic Bitcoin Reserve, the directive to support stablecoins globally. It is policy, not law, so it can be reversed by the next administration. But it gave the industry the clearest signal it has ever received from a US president. The practical effect is upstream. SAB 122, the GENIUS Act momentum, the SEC's posture shift on enforcement. All of it traces back to this executive order creating the political cover for regulators to move.
Executive order signed January 2025 establishing the Strategic Bitcoin Reserve, directing agencies to develop a supportive regulatory framework for digital assets, and prohibiting the creation of a central bank digital currency (CBDC).
- •Established a Strategic Bitcoin Reserve using seized government BTC holdings
- •Directed all federal agencies to develop regulatory frameworks that support digital asset innovation
- •Prohibited the development or issuance of a US central bank digital currency (CBDC)
- •Created a Presidential Working Group on Digital Asset Markets
- •Explicitly stated US policy is to promote dollar-backed stablecoins worldwide
No direct compliance requirements for private entities. The EO directs agencies to create supportive frameworks rather than imposing new rules.
European Union
Markets in Crypto-Assets Regulation
Any entity issuing, trading, or providing services for crypto-assets in the EU
// MiCA is the reason Circle opened a Paris office, Coinbase got a European license, and Societe Generale launched SG-FORGE. Before MiCA, every EU country had its own interpretation. Now one license covers 27 countries. The passporting mechanism is what makes it work. Backed Finance, Spiko, STOKR, Bitpanda, Flow Traders all operate under it. For EU-based issuers, this is the first time the rules are clear enough to actually build on.
Comprehensive EU framework for crypto-asset issuers and service providers, covering transparency, disclosure, and authorization requirements.
- •Crypto-asset issuers must publish a whitepaper approved by national authority
- •CASPs (Crypto-Asset Service Providers) need authorization in at least one EU member state
- •Stablecoin issuers must maintain adequate reserves and comply with redemption rights
- •Market abuse rules apply to all crypto-assets admitted to trading
- •Passporting allows EU-wide operations from a single member state authorization
Obtain authorization from a national competent authority, publish a compliant whitepaper, and implement governance, reserve, and disclosure requirements per asset type.
EU DLT Pilot Regime
Market operators, CSDs, and investment firms seeking to run DLT-based trading and settlement infrastructure in the EU
// MiCA covers crypto-assets. The DLT Pilot Regime covers tokenized traditional securities. Different animals. This is the framework that lets European exchanges and CSDs experiment with onchain settlement for bonds, equities, and fund shares without needing to comply with rules designed for legacy infrastructure. The EUR 9 billion cap per operator keeps it contained. The pilot runs until 2026 and will either become permanent law or get absorbed into a broader framework. For now, it is the legal basis for tokenized securities infrastructure in the EU.
EU regulation creating a sandbox for DLT-based market infrastructures to trade, settle, and record tokenized securities. Separate from MiCA, which covers crypto-assets. The DLT Pilot Regime covers tokenized versions of traditional financial instruments.
- •Creates three new market infrastructure types: DLT MTF, DLT SS, and DLT TSS (combined trading and settlement)
- •Allows exemptions from CSDR and MiFIR requirements that assume traditional settlement infrastructure
- •Caps total value of tokenized securities at EUR 9 billion per operator during the pilot
- •Pilot runs until 2026, with possible extension based on outcomes
- •Operators must have existing MiFID authorization or apply for the new DLT-specific license
Apply for a DLT market infrastructure license through your national competent authority. Must hold or obtain MiFID authorization. Subject to volume caps and reporting requirements during the pilot phase.
Swiss FINMA Digital Assets Framework
Banks, securities firms, and DLT trading facilities operating in Switzerland
// Switzerland took the opposite approach from most countries. Instead of creating a new crypto regime, it adapted existing financial law. The 2021 DLT Act created a legal concept for ledger-based securities and a new license for DLT trading facilities. Sygnum Bank holds a full FINMA banking license and offers tokenized assets. Taurus provides custody infrastructure under FINMA oversight. Backed Finance issues tokenized stocks from here. The framework is mature because it was never separate from traditional finance. No regulatory theater. Just law.
Swiss regulatory framework for digital assets under DLT law. FINMA oversees tokenized securities and crypto-friendly banking.
- •DLT Act (2021) creates a new license category for DLT trading facilities
- •Tokenized securities recognized as ledger-based securities (Registerwertrechte) under Swiss law
- •FINMA banking license holders can custody and trade digital assets
- •No separate crypto-specific license needed; existing financial market laws apply
- •Swiss DLT trading facility license enables integrated trading, settlement, and custody
Operate under existing FINMA banking or securities dealer licenses, or apply for a DLT trading facility license. Tokenized securities are issued as ledger-based securities under the DLT Act.
United Kingdom
FCA Innovation Sandbox
Fintech firms and digital asset businesses seeking to operate in the UK
// Post-Brexit, the UK needed its own regulatory identity for digital assets. The FCA sandbox is the result. Archax got a full FCA license and now operates a regulated tokenized securities exchange. Copper runs custody under FCA oversight. Schroders and HSBC have sandbox exposure. The Digital Securities Sandbox goes further, specifically covering tokenized securities and financial market infrastructure. The UK is betting that letting firms ship under supervision beats the US approach of regulation by enforcement.
UK Financial Conduct Authority sandbox allowing fintech firms to test products in a controlled environment.
- •Firms can test innovative products with real customers under FCA supervision
- •Sandbox participants receive restricted authorization for a limited testing period
- •Digital Securities Sandbox (DSS) specifically covers tokenized securities and FMI
- •Participants must demonstrate genuine innovation and consumer benefit
- •Post-sandbox path to full FCA authorization or graceful exit
Apply to the FCA sandbox program with a demonstrable innovation, meet consumer protection requirements, and transition to full authorization after the testing period.
Asia-Pacific
Singapore MAS / Project Guardian
Financial institutions and fintechs operating tokenized asset services in Singapore
// Project Guardian is the most credible institutional tokenization pilot in the world. JPMorgan, Citi, Goldman Sachs, Standard Chartered, HSBC are all running real experiments under MAS oversight. Tokenized bonds, FX swaps, structured products. Not whitepapers. Actual transactions. Paxos has a Singapore entity. OpenEden operates under MAS. Clearpool got its license here. When the biggest banks in the world want to test tokenized finance without regulatory ambiguity, they come to Singapore. The city-state punches above its weight because MAS actually engages with the industry instead of issuing warnings from a distance.
Monetary Authority of Singapore sandbox for tokenized asset experimentation, part of Project Guardian.
- •Project Guardian tests asset tokenization across FX, bonds, and funds with major banks
- •Capital Markets Services (CMS) license required for dealing in securities
- •Payment Services Act covers digital payment tokens and stablecoin issuance
- •Recognized Market Operator (RMO) status for tokenized asset exchanges
- •MAS provides no-action letters for sandbox participants during testing
Obtain a CMS license or sandbox approval from MAS, participate in Project Guardian pilots where applicable, and comply with Payment Services Act for token-related activities.
Hong Kong SFC Virtual Asset Framework
Virtual asset trading platforms, tokenized securities issuers, and custodians operating in Hong Kong
// Hong Kong did something almost no other jurisdiction has done. It opened retail access to digital assets under a proper licensing regime. This is a bigger deal than it sounds. Most countries restrict crypto to accredited or professional investors only. The SFC framework lets licensed platforms serve everyone. HSBC and Standard Chartered already operate here. Hex Trust runs custody under SFC oversight. The bet is that regulated retail access is safer than pretending retail does not already hold crypto through unregulated channels.
Hong Kong Securities and Futures Commission framework for virtual asset trading platforms and tokenized securities.
- •Virtual Asset Trading Platform (VATP) licensing regime under Securities and Futures Ordinance
- •Retail investors can trade on SFC-licensed platforms (not just professional investors)
- •Tokenized securities fall under existing SFO requirements for Type 1 and Type 9 licenses
- •Custody requirements mandate segregation of client assets and insurance coverage
- •Anti-money laundering and counter-terrorism financing obligations apply
Apply for a VATP license from the SFC, implement custody segregation and insurance requirements, and comply with AML/CTF obligations.
UAE VARA Framework
Virtual asset service providers operating in or from Dubai
// Dubai moved faster than anyone expected. VARA built a full licensing regime while the US was still arguing about whether tokens are securities. Binance set up here. Tether got recognized. The zero income tax draws attention, but the real value is regulatory clarity. Seven license categories, clear capital requirements, defined compliance roles. For players that need a home jurisdiction and cannot wait for the US or EU to figure it out, Dubai is the answer. The question is whether speed came at the cost of rigor.
Virtual Assets Regulatory Authority framework in Dubai for licensing and regulating virtual asset service providers.
- •Seven activity-based license categories: advisory, broker-dealer, custody, exchange, lending, transfer, and management
- •Mandatory compliance officer and MLRO (Money Laundering Reporting Officer) appointments
- •Minimum capital requirements vary by license category
- •Technology governance and cybersecurity standards mandated
- •Marketing and advertising restrictions for virtual asset services
Obtain a VARA license for each relevant activity category, appoint required compliance officers, meet minimum capital requirements, and implement technology governance standards.
Japan FSA Crypto-Asset Framework
Crypto-asset exchanges, STO issuers, and stablecoin issuers operating in Japan
// Japan was forced to regulate crypto after Mt. Gox collapsed in 2014. The result is one of the most mature frameworks in the world. The JFSA requires 95% cold wallet storage, mandatory membership in the self-regulatory body (JVCEA), and strict capital requirements. It is hard to get licensed here. Binance did it anyway because the Japanese market is worth the compliance cost. The STO framework under the amended FIEA is also live, making Japan one of the few countries where tokenized securities have a defined legal path to retail investors.
Japan Financial Services Agency regulation for crypto-asset exchanges and security token offerings under amended FIEA.
- •Crypto-asset exchange service providers must register with the JFSA
- •Security token offerings (STOs) regulated under the amended Financial Instruments and Exchange Act
- •Cold wallet storage required for 95%+ of customer crypto assets
- •Mandatory participation in a self-regulatory organization (JVCEA)
- •Stablecoin framework under Payment Services Act requires banking or trust license
Register as a crypto-asset exchange with the JFSA, join the JVCEA self-regulatory body, and comply with cold storage and customer asset segregation requirements.
Frameworks are assigned only when a player is directly licensed, registered, or a named participant. Inclusion does not imply endorsement or legal advice.