25 frameworks across 5 jurisdictions. The SEC and FINRA in the US, MiCA in the EU, the FCA's sandbox in the UK, MAS in Singapore. Each one shapes what's permissible to issue, distribute, and custody onchain.
Listed only when a player on the map is licensed under, registered with, or named in. Reference, not advice.
Last updated May 2026·All entries verified against primary sources
FINRA approved Securitize Markets' Continuing Membership Application (CMA), authorizing it to custody tokenized securities, run atomic settlement between tokenized securities and stablecoins onchain, and act as underwriter and selling-group participant for tokenized offerings. tZERO had custody approval previously but only via a special-purpose broker-dealer; Securitize is the first regular broker-dealer with the full stack.
First end-to-end IPO infrastructure onchain inside one regulated broker-dealer. Tokenized issuance, custody, trading, and atomic settlement now consolidate at Securitize without the special-purpose carve-out tZERO needed.
DTCC announced a 50+ firm Industry Working Group to design tokenization standards for US capital markets. Participants include BlackRock, Goldman Sachs, JPMorgan, Franklin Templeton, Morgan Stanley, Bank of America, Citadel Securities, NYSE Group, Circle, Fireblocks, Robinhood, and Ondo. Limited production trades targeted July 2026; full DTC tokenization service launch October 2026.
DTCC custodies $114T and clears $4.7Q annually. Bringing that core onchain with this group of TradFi + DeFi firms designing the rules is the canonical 'tokenization at scale' moment. Ondo is the only crypto-native token issuer in the inner circle.
BlackRock submitted a 17-page comment letter on OCC Docket OCC-2025-0372 (NPRM published March 2, 2026), asking the agency to drop the proposed 20% cap on tokenized reserve assets for payment stablecoin issuers. Filed on the May 1 deadline. The letter coincides with two BlackRock SEC filings (BSTBL, BRSRV) for tokenized MMFs designed to serve as GENIUS Act eligible reserves.
Direct lobby by the largest tokenized-MMF issuer to remove a quantitative ceiling on the demand category they're building product into. 'Build the product. Remove the cap. Capture the flow.'
First SEC guidance on tokenized securities written for the post-Atkins era. The headline is that token format does not create a new asset class. A tokenized stock is a stock. A tokenized fund share is a fund share. The interesting work is in the taxonomy. Issuer-sponsored, custodial, synthetic. Each carries different rights and obligations. BUIDL is issuer-sponsored. xStocks are third-party custodial. Synthetic perp tokens are something else again. The SEC is signaling that it sees the architecture, not just the marketing. That is a meaningful upgrade from the prior posture.
Joint statement issued January 28, 2026 by SEC's Division of Corporation Finance, Division of Investment Management, and Division of Trading and Markets clarifying the application of federal securities laws to tokenized securities. Elaborates the Token Taxonomy framework set out by SEC Chair Paul Atkins in November 2025. Distinguishes issuer-sponsored tokens from third-party-sponsored tokens (custodial and synthetic).
Applies to
Issuers, sponsors, and trading venues offering tokenized representations of US securities
ii.Issuer-sponsored model: the underlying issuer authorizes and structures the token (e.g. BUIDL via Securitize)
iii.Third-party-sponsored custodial model: a third party tokenizes wrapping shares it holds in custody
iv.Third-party-sponsored synthetic model: a third party issues a derivative token referencing the underlying security
v.The format in which a security is issued does not change applicable federal securities laws
vi.The method of tokenization can affect what rights and privileges (voting, dividends, governance) the token actually conveys
vii.Reaffirms positions from Commissioner Peirce (July 2025) and Chair Atkins (November 2025 speech)
Compliance
Categorize the tokenized product as issuer-sponsored or third-party-sponsored (custodial or synthetic). Apply the same registration, disclosure, and intermediary requirements that apply to the underlying security. Document which rights and privileges the token preserves and which it does not.
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.
Applies to
US issuers selling tokenized securities to accredited investors
Key provisions
i.Rule 506(b): unlimited raise from accredited investors, no general solicitation
ii.Rule 506(c): allows general solicitation but requires verification of accredited status
iii.No SEC registration required, but must file Form D within 15 days of first sale
iv.Securities are restricted with a 6-12 month holding period before resale
v.No limit on the amount of capital that can be raised
Compliance
File Form D with the SEC, restrict sales to accredited investors (or verify accreditation under 506c), and enforce transfer restrictions during the holding period.
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.
Applies to
US-based issuers selling tokenized securities to non-US investors
Key provisions
i.Offering must occur outside the United States with no directed selling efforts in the US
ii.Category 1 securities (foreign issuers, no US market interest) have minimal restrictions
iii.Category 2 and 3 securities require a 40-day or 1-year distribution compliance period
iv.Resale to US persons during the compliance period is prohibited
v.Must include contractual transfer restrictions to prevent flowback into the US
Compliance
Structure the offering entirely offshore, implement transfer restrictions preventing US person participation, and observe the applicable distribution compliance period.
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.
The Innovation Exemption is the missing complement to the DTC tokenization pilot. DTC handled custody-side legitimacy with its December 2025 no-action letter. This handles issuer and trading-side legitimacy. If both pilots run their course, the US has a complete tokenized-securities framework end-to-end. Right now the catch is it's a political announcement, not a rule. Until the White House clears it and the Division of Trading and Markets publishes implementation guidance, no one can apply.
SEC Chair Paul Atkins announced the Innovation Exemption on April 21, 2026 at the Economic Club of Washington. The framework creates a 12-to-36-month regulatory sandbox allowing market participants to issue and trade tokenized securities onchain without full registration, subject to volume caps, whitelisting, and periodic SEC reporting. As of announcement, the proposal is a political signal under White House review, not a binding rule.
Applies to
Issuers of tokenized securities, ATSes and exchanges trading tokenized securities, broker-dealers facilitating tokenized security transactions
Key provisions
i.12-to-36 month regulatory sandbox period
ii.Tokenized securities can be issued and traded onchain without full registration during the sandbox
iii.Volume caps on participants to limit systemic exposure
iv.Whitelisting requirements for eligible participants
v.Periodic SEC reporting on issuance, trading, and custody activity
vi.Sandbox graduation pathway tied to compliance track record
Compliance
Apply for sandbox participation through the SEC Division of Trading and Markets. Submit periodic reports on volume, holders, and trading activity. Maintain whitelisted-only participant lists per the framework. Sandbox terms convert to permanent registration upon graduation.
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. The three-year tokenization pilot now lets tokenized stocks trade on the same exchange order book as traditional ones, using the same CUSIP. 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's umbrella program for tokenized securities. Two tracks: T+0 settlement modernization (Smart NAV pilot, tokenized collateral), and the three-year tokenization pilot allowing tokenized Russell 1000 stocks plus major-index ETFs to trade on US equity exchanges. SEC approved Nasdaq's rule change March 2026, approved NYSE's rule change April 17, 2026 (filed April 9). May 4, 2026: DTCC convened a 50+ firm Industry Working Group (BlackRock, Goldman Sachs, JPMorgan, Franklin Templeton, Morgan Stanley, Bank of America, Citadel Securities, NYSE Group, Circle, Fireblocks, Robinhood, Ondo, and others) to design tokenization standards. Limited production trades targeted July 2026, full service launch October 2026.
Applies to
DTCC member firms, custodian banks, broker-dealers, and infrastructure providers participating in the pilot
Key provisions
i.Smart NAV pilot validates onchain fund data using blockchain as a golden record
ii.Exploring tokenized collateral management for same-day settlement
iii.Partnership with major custodian banks and broker-dealers for pilot testing
iv.Integration with existing DTCC settlement infrastructure (DTC, NSCC, FICC)
v.Targeting T+0 settlement for tokenized securities by 2026
vi.Three-year tokenization pilot allows tokenized Russell 1000 stocks and major-index ETFs (S&P 500, Nasdaq-100) to trade on US equity exchanges
vii.Tokenized securities must share CUSIP, ticker, rights, and privileges with traditional counterparts; trade on the same order book with same execution priority; T+1 settlement via DTC
viii.SEC approved Nasdaq's tokenized securities rule change March 2026; NYSE filed its rule change April 9, 2026
Compliance
Participate as a DTCC member or pilot partner. No new regulatory requirements yet, but pilot participants must meet existing DTCC membership and operational standards.
The Act took six months to translate from statute into product. In May 2026, BlackRock filed BSTBL + BRSRV (the explicit GENIUS Act stablecoin reserve fund) and JPMorgan followed four days later with JLTXX. The eligible-reserve-asset slot is the new competitive product category, and the largest US asset manager and largest US bank are both racing to fill it.
The Guiding and Establishing National Innovation for US Stablecoins Act. House passed July 17, 2025; Trump signed July 18, 2025. First standalone US crypto bill ever signed into law. Establishes federal framework for payment stablecoins: 100% liquid-asset reserves, monthly public reserve disclosures, Bank Secrecy Act compliance. Permitted payment stablecoins are explicitly NOT securities. Stablecoin holder claims prioritized over all other creditors in issuer insolvency.
Applies to
Stablecoin issuers operating in or serving US users
Key provisions
i.Payment stablecoin issuers must maintain 100% reserves in U.S. dollars or short-term Treasuries
ii.Federal registration required for issuers above $10B; state charter permitted below
iii.Monthly public reserve disclosures composition required
iv.Stablecoin issuers explicitly subject to the Bank Secrecy Act (AML and sanctions compliance)
v.Permitted payment stablecoins are not securities under federal securities law
vi.In issuer insolvency, stablecoin holder claims are prioritized over all other creditors
vii.Treasury proposed implementation rule for illicit-finance provisions in 2026
viii.Eligible reserve assets may include tokenized money market funds that meet specified custody and segregation requirements. BlackRock's BRSRV (May 8, 2026) is the first product explicitly built for this slot.
Compliance
Register with the OCC or a state banking regulator, maintain 1:1 reserves in eligible liquid assets, publish monthly attestations, and comply with BSA-grade AML, KYC, and sanctions programs.
GENIUS handled stablecoins. CLARITY is the larger fight: who regulates the rest of crypto. The bill splits SEC and CFTC jurisdiction, defines digital commodities, and finally answers the question every issuer has been waiting on for a decade. The Senate compromise on stablecoin yield was the gating issue. With Tillis-Alsobrooks now aligned and Coinbase, Circle, and the trade groups backing the deal, the markup window opened. Polymarket has 61% odds the bill becomes law in 2026. If it does, the SEC's 'regulation by enforcement' era ends.
Digital Asset Market Clarity Act (H.R. 3633). Passed the US House July 2025 (294-134). Senate Banking Committee compromise reached May 2026 between Senators Tillis and Alsobrooks on stablecoin yield, with markup expected as soon as the week of May 11, 2026. Would split crypto oversight between SEC and CFTC, define digital commodities, and ban deposit-equivalent stablecoin yield while preserving activity-based platform rewards.
Applies to
Crypto issuers, exchanges, stablecoin issuers, and trading platforms operating in the US
Key provisions
i.Splits digital asset oversight between SEC (securities) and CFTC (commodities)
ii.Defines digital commodities and creates a path for token classification
iii.Section 404 bans interest or yield economically equivalent to a bank deposit
iv.Preserves activity-based rewards tied to bona fide platform usage
v.Extends stablecoin prohibitions beyond the GENIUS Act baseline
vi.Tillis ethics provision proposed: restrict White House officials from promoting or issuing digital assets
vii.Tillis-Alsobrooks compromise text released May 1-2, 2026
Compliance
Pending Senate passage. If enacted, register with the appropriate regulator (SEC or CFTC) per token classification, conform stablecoin yield programs to Section 404, and apply ethics restrictions for federal officials.
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.
Applies to
Banks, trust companies, and regulated custodians holding digital assets for clients
Key provisions
i.SAB 121 (2022) required custodied crypto to appear as liabilities on bank balance sheets
ii.This made crypto custody prohibitively expensive for regulated banks under Basel capital rules
iii.Congress passed a repeal in 2024 but Biden vetoed it
iv.SAB 122 (2025) reversed SAB 121, removing the on-balance-sheet requirement
v.Banks can now custody digital assets using standard off-balance-sheet safekeeping treatment
Compliance
Follow standard custodial accounting treatment for digital assets. The punitive on-balance-sheet requirement from SAB 121 no longer applies under SAB 122.
The pair of EOs set the tone for the 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 passage, the SEC's posture shift on enforcement. All of it traces back to these executive orders creating the political cover for regulators to move. The Reserve itself languished for a year waiting on Congress to codify it. ARMA is the bill that would make it permanent.
Two related executive orders. EO 14178 'Strengthening American Leadership in Digital Financial Technology' signed January 23, 2025: directs agencies to build supportive crypto framework, bans CBDC, creates Presidential Working Group. EO 14233 signed March 6, 2025: establishes the Strategic Bitcoin Reserve and US Digital Asset Stockpile. As of May 2026, the Reserve holds the federal government's ~328,372 BTC (mostly forfeited assets) but full operationalization awaits congressional action via the proposed American Reserves Modernization Act (ARMA).
Applies to
All federal agencies, financial regulators, and digital asset market participants
Key provisions
i.EO 14178 (Jan 23 2025): directs all federal agencies to develop supportive digital asset frameworks
ii.EO 14178: prohibits the development or issuance of a US central bank digital currency (CBDC)
iii.EO 14178: explicitly states US policy is to promote dollar-backed stablecoins worldwide
iv.EO 14178: created a Presidential Working Group on Digital Asset Markets
v.EO 14233 (Mar 6 2025): establishes the Strategic Bitcoin Reserve, capitalized with forfeited federal BTC
vi.EO 14233: creates a US Digital Asset Stockpile holding seized SOL, ADA, XRP, ETH (no new purchases authorized)
vii.EO 14233: BTC in the Reserve cannot be sold; other assets may be sold but not purchased
viii.Begich's American Reserves Modernization Act (ARMA) proposed to codify the Reserve into law
Compliance
No direct compliance requirements for private entities. The EOs direct agencies to create supportive frameworks. Reserve operations are internal Treasury policy.
BitLicense was the headline. The trust charter was the better deal. Gemini and Paxos figured that out in 2015 and built their entire stacks around it. The trust charter gives you fiduciary authority, money transmission, and crypto activities under a single regulator. Now everyone wants the federal version. Anchorage already has the OCC charter. Paxos and Coinbase are applying. The NYDFS framework is what proved the legal architecture works. The OCC version is what scales it nationally.
New York State limited purpose trust company charter approved by the NYDFS, granting fiduciary powers and money transmission rights without a separate BitLicense or money transmitter license. Higher bar than BitLicense (requires NY Banking Board approval) and grants stronger powers. Gemini received the first one in October 2015. Paxos became the first blockchain/tokenization company to hold one in 2015. Many holders are now seeking to convert to OCC national trust charters.
Applies to
Digital asset custodians, issuers, and stablecoin operators serving New York residents
Key provisions
i.Limited purpose trust charter from NYDFS approved by the New York Banking Board
ii.Holds fiduciary authority that BitLicense holders cannot exercise
iii.Permits money transmission in New York without a separate money transmitter license
iv.Higher capital, governance, and audit requirements than BitLicense
v.Direct supervision by NYDFS, including periodic examinations
vi.Holders include Gemini (Oct 2015), Paxos (2015, first crypto-native), several others
Compliance
Apply through the NYDFS and the New York Banking Board, meet capital and governance requirements, submit to ongoing supervision. Many holders are now pursuing OCC national trust charters as a federal complement or replacement.
The 40 Act is what most retail investors actually own. ETFs, mutual funds, and 401(k) holdings all run under it. BENJI is the only tokenized 40 Act fund of meaningful scale because the structure was designed for transfer agents, custodians, and broker-dealers running on traditional rails. Tokenizing within a 40 Act wrapper is harder than tokenizing under Reg D, but the upside is retail access. If the SEC's tokenization statement and the Innovation Exemption stick, the next wave of tokenized RWA may come through 40 Act wrappers, not just Reg D.
US federal law governing mutual funds, ETFs, and registered closed-end funds. Highest level of SEC fund regulation: daily NAV, transparent holdings, board oversight, custody segregation, and broad retail access. BENJI (Franklin Templeton's tokenized money market fund) is the only tokenized 40 Act fund on the map; tokenized 40 Act funds remain rare because the structure was designed for traditional rails.
Applies to
Issuers of mutual funds, ETFs, and closed-end funds offered to US investors
Key provisions
i.Daily NAV calculation and disclosure
ii.Strict custody requirements: assets held by qualified custodian segregated from issuer
iii.Board of directors oversight, including independent directors
iv.Liquidity requirements and concentration limits
vi.Available to all investors including retail (subject to suitability)
Compliance
Register the fund with the SEC under the 1940 Act, appoint a qualified custodian and board, comply with daily NAV and disclosure requirements, file periodic reports.
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.
Applies to
Any entity issuing, trading, or providing services for crypto-assets in the EU
Key provisions
i.Crypto-asset issuers must publish a whitepaper approved by national authority
ii.CASPs (Crypto-Asset Service Providers) need authorization in at least one EU member state
iii.Stablecoin issuers must maintain adequate reserves and comply with redemption rights
iv.Market abuse rules apply to all crypto-assets admitted to trading
v.Passporting allows EU-wide operations from a single member state authorization
Compliance
Obtain authorization from a national competent authority, publish a compliant whitepaper, and implement governance, reserve, and disclosure requirements per asset type.
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 feeds into the ECB's Pontes program (Q3 2026 launch) for wholesale DLT settlement in central bank money, with the longer-term Appia blueprint due 2028. Today, it is still 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.
Applies to
Market operators, CSDs, and investment firms seeking to run DLT-based trading and settlement infrastructure in the EU
Key provisions
i.Creates three new market infrastructure types: DLT MTF, DLT SS, and DLT TSS (combined trading and settlement)
ii.Allows exemptions from CSDR and MiFIR requirements that assume traditional settlement infrastructure
iii.Caps total value of tokenized securities at EUR 9 billion per operator during the pilot
iv.Pilot runs until 2026, with possible extension based on outcomes
v.Operators must have existing MiFID authorization or apply for the new DLT-specific license
Compliance
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.
ECB stops being a spectator in tokenized finance. Pontes is the bridge: settle a tokenized bond or fund share in central bank money by Q3 2026, on either the DLT platform or T2. Appia is the bigger move, a ground-up redesign of how European tokenized markets work, due 2028. The DLT collateral acceptance (March 2026) is the first concrete unlock.
Eurosystem dual-track strategy for wholesale central bank money settlement on DLT, approved by the ECB Governing Council on 1 July 2025. Pontes (short-term, Q3 2026 launch) provides a Eurosystem DLT platform that can settle tokenized asset transactions in central bank money via cash tokens or T2 RTGS. Appia (long-term, blueprint due H2 2028) defines the architecture of a European tokenized financial system.
Applies to
EU central banks, financial market participants, and DLT platform operators settling tokenized securities in euro central bank money
Key provisions
i.Pontes launches Q3 2026 with dual settlement (DLT cash tokens or T2 RTGS)
ii.Appia blueprint due H2 2028 covering full tokenized finance value chain
iii.From 30 March 2026, marketable assets issued in CSDs using DLT-based services accepted as eligible Eurosystem collateral
iv.Approved by ECB Governing Council 1 July 2025
v.Built on 2024 exploratory work with 64 participants and 50+ trials
Compliance
Connect to Pontes via the Eurosystem DLT platform for cash-token settlement, or via T2 RTGS for traditional rails. Participate in Appia working groups to shape the long-term framework.
France is the EU jurisdiction that turned UCITS and ELTIF into a tokenization opportunity without writing a tokenization law. The 2024 ELTIF 2.0 update made retail access to long-term private assets easier, and tokenized share classes plug into the same wrapper. SG-FORGE issuing tokenized bonds, AMF authorizing tokenized UCITS, MiCA covering crypto-assets separately. The result is the most coherent EU stack for an asset manager that wants to tokenize without leaving the regulated fund world.
Autorité des marchés financiers, France's securities regulator. Authorizes UCITS funds (the EU retail fund standard) and ELTIFs (European Long-Term Investment Funds, revised under ELTIF 2.0 effective January 10, 2024). France is among the most active EU jurisdictions for ELTIF launches: 10 of the 55 new ELTIFs in 2024 were French-domiciled. EU fund managers have begun issuing tokenized UCITS and AIF units under existing wrappers without requiring a new tokenization regime.
Applies to
Asset managers issuing UCITS or ELTIF funds in France, including tokenized share classes
Key provisions
i.UCITS: harmonized retail fund framework across the EU, available cross-border under passport
ii.ELTIF 2.0 effective January 10, 2024: revised European Long-Term Investment Fund regime
iv.AIF that meets ELTIF requirements (55%+ in long-term assets) may apply to AMF for authorization
v.Tokenized UCITS and AIF units permitted under existing frameworks without separate tokenization license
vi.France-domiciled accounted for 10 of 55 new ELTIF launches in 2024
Compliance
Apply to the AMF for UCITS or ELTIF authorization. Comply with UCITS Directive (or AIFMD plus ELTIF 2.0). Tokenized share classes use existing fund frameworks; no separate tokenization-specific license required.
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 (FCA + Bank of England) opened September 2024 and specifically covers 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.
Applies to
Fintech firms and digital asset businesses seeking to operate in the UK
Key provisions
i.Firms can test innovative products with real customers under FCA supervision
ii.Sandbox participants receive restricted authorization for a limited testing period
iii.Digital Securities Sandbox (DSS) specifically covers tokenized securities and FMI
iv.Participants must demonstrate genuine innovation and consumer benefit
v.Post-sandbox path to full FCA authorization or graceful exit
Compliance
Apply to the FCA sandbox program with a demonstrable innovation, meet consumer protection requirements, and transition to full authorization after the testing period.
Hong Kong moved from VASP retail trading to its own onshore stablecoin regime in less than two years. The HKMA gave 36 applicants one license slot each in the first batch and approved 2: HSBC and a Standard Chartered + Animoca-led consortium. HSBC issuing a HKD stablecoin is a different signal than Tether or Circle. It is the local clearing bank deciding the rails are real enough to put their balance sheet on. The HKD stablecoin is also a hedge against USD-stablecoin dominance in Asia, with Hong Kong positioning itself as the regulated anchor.
HKMA-administered licensing regime for fiat-referenced stablecoin issuers, effective 1 August 2025. First two licenses granted 10 April 2026 to HSBC and Anchorpoint Financial (a Standard Chartered + Animoca Brands-led consortium). 36 applicants by the September 2025 deadline; 2 licenses granted in the first batch. Both initial licensees plan to issue HKD-referenced stablecoins.
Applies to
Entities issuing fiat-referenced stablecoins in or from Hong Kong
Key provisions
i.Stablecoin issuance is a regulated activity under the Stablecoins Ordinance
ii.Issuers must hold full reserves in high-quality liquid assets in segregated accounts
iii.HKMA licensing regime, capital requirements, governance, and disclosure obligations apply
iv.First two licenses granted to HSBC and Anchorpoint Financial in April 2026
v.Both initial licensees focused on HKD-referenced stablecoins, with HSBC launch targeted H2 2026
Compliance
Apply for a stablecoin issuer license from the HKMA. Hold full reserves in segregated high-quality liquid assets. Meet ongoing capital, governance, audit, and disclosure requirements set out in the Ordinance.
Project Guardian is the most credible institutional tokenization pilot in the world. JPMorgan, Citi, Goldman Sachs, Standard Chartered, HSBC, Apollo, Franklin Templeton, Hamilton Lane, Ant Group, DBS, OCBC, UBS are all running real experiments under MAS oversight. Tokenized bonds, FX swaps, structured products, fund operationalization. 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.
MAS-led global asset tokenization initiative across asset and wealth management, fixed income, and FX. Live use cases with Apollo, Ant Group, DBS, Franklin Templeton, Hamilton Lane, JPMorgan, Citi, Goldman Sachs, Standard Chartered, HSBC, OCBC, UBS. ICMA published Fixed Income deliverables November 2025 (DvP guide and custody lessons). IMAS (Singapore) and the UK's Investment Association joined August 5, 2025. Operational roadmap for tokenized funds released 2025.
Applies to
Financial institutions and fintechs operating tokenized asset services in Singapore
Key provisions
i.Project Guardian tests asset tokenization across FX, bonds, and funds with major banks
ii.Capital Markets Services (CMS) license required for dealing in securities
iii.Payment Services Act covers digital payment tokens and stablecoin issuance
iv.Recognized Market Operator (RMO) status for tokenized asset exchanges
v.MAS provides no-action letters for sandbox participants during testing
Compliance
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 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. April 2026 added the secondary trading rails: licensed VATPs can now offer secondary trading for SFC-authorized tokenized open-ended funds, starting with money market funds. With $1.4B in tokenized share class AUM and 7x annual growth, the supply is real, the framework is the first of its kind, and the pilot is the path to 24/7 tokenized fund liquidity onshore.
Hong Kong Securities and Futures Commission framework for virtual asset trading platforms and tokenized securities. April 20, 2026: SFC issued a circular establishing the first dedicated regulatory framework for secondary trading of SFC-authorized tokenized open-ended funds on licensed VATPs. As of March 2026, 13 tokenized products were authorized for public offering with HK$10.7B (~$1.4B USD) in tokenized share class AUM, up roughly 7x year-over-year.
Applies to
Virtual asset trading platforms, tokenized securities issuers, and custodians operating in Hong Kong
Key provisions
i.Virtual Asset Trading Platform (VATP) licensing regime under Securities and Futures Ordinance
ii.Retail investors can trade on SFC-licensed platforms (not just professional investors)
iii.Tokenized securities fall under existing SFO requirements for Type 1 and Type 9 licenses
iv.Custody requirements mandate segregation of client assets and insurance coverage
v.Anti-money laundering and counter-terrorism financing obligations apply
vi.April 2026 secondary trading pilot: VATPs may offer secondary-market trading for SFC-authorized tokenized open-ended funds subject to fair pricing, orderly trading, liquidity provision, and disclosure requirements
vii.Initial scope of secondary trading framework: tokenized money market funds, with expansion path to all SFC-authorized tokenized products
Compliance
Apply for a VATP license from the SFC, implement custody segregation and insurance requirements, and comply with AML/CTF obligations. To offer secondary trading of tokenized open-ended funds, comply with the April 2026 circular's fair-pricing, orderly-trading, liquidity, and disclosure standards.
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 JVCEA membership, and strict capital requirements. The 2023 stablecoin framework was the first major economy to regulate fiat-pegged tokens specifically. The 2025 Amendment Act broadened that with intermediary registration and a 50% cap on bond-backed reserves. Now the FSA is openly exploring a bigger move: shifting more of crypto out of payments and into securities law. If that happens, Japan's STO and exchange regimes converge, and the country becomes one of the few jurisdictions with a unified securities-grade framework for digital assets.
JFSA regulation for crypto-asset exchanges and security token offerings under amended FIEA. Stablecoins regulated under Payment Services Act since June 2023 (banks, fund transfer service providers, trust banks only). 2025 Amendment Act enacted May 2025: introduced Crypto Asset Intermediary Service Business (ECISB) registration, allows up to 50% of trust-type stablecoin reserves in short-term government bonds. FSA opened public consultation January-February 2026 on bond eligibility for stablecoin reserves. Regulators are exploring shifting more crypto activity into the securities (FIEA) framework.
Applies to
Crypto-asset exchanges, STO issuers, stablecoin issuers, and crypto intermediaries operating in Japan
Key provisions
i.Crypto-asset exchange service providers must register with the JFSA
ii.Security token offerings (STOs) regulated under the amended Financial Instruments and Exchange Act
iii.Cold wallet storage required for 95%+ of customer crypto assets
iv.Mandatory participation in a self-regulatory organization (JVCEA)
v.Stablecoin framework under Payment Services Act (effective June 2023) limits issuance to banks, FTSPs, and trust companies
vii.Up to 50% of trust-type stablecoin reserves may be invested in short-term government bonds or callable term deposits
viii.January 2026 FSA consultation on eligible bond types for stablecoin collateral
Compliance
Register as a crypto-asset exchange with the JFSA, join the JVCEA self-regulatory body, comply with 95% cold storage and customer asset segregation. Stablecoin issuers register under PSA as a bank, FTSP, or trust company. Intermediaries register as ECISBO under the 2025 Amendment Act.
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.
Applies to
Virtual asset service providers operating in or from Dubai
ii.Mandatory compliance officer and MLRO (Money Laundering Reporting Officer) appointments
iii.Minimum capital requirements vary by license category
iv.Technology governance and cybersecurity standards mandated
v.Marketing and advertising restrictions for virtual asset services
Compliance
Obtain a VARA license for each relevant activity category, appoint required compliance officers, meet minimum capital requirements, and implement technology governance standards.
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.
Applies to
Banks, securities firms, and DLT trading facilities operating in Switzerland
Key provisions
i.DLT Act (2021) creates a new license category for DLT trading facilities
ii.Tokenized securities recognized as ledger-based securities (Registerwertrechte) under Swiss law
iii.FINMA banking license holders can custody and trade digital assets
iv.No separate crypto-specific license needed; existing financial market laws apply
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.
BVI built the dual track: VASP for crypto-native businesses, SIBA for the fund-wrapper world. BUIDL is a BVI fund. Many tokenized treasury and private-credit products are too. The 2022 Act made the crypto side explicit, the regulatory sandbox makes early-stage testing possible, and CRS 2.0 closed the tax-transparency gap. Quietly one of the most-used regulatory homes for tokenization.
British Virgin Islands FSC oversight under the Virtual Assets Service Providers Act 2022 (in force February 2023) and Securities Investment Business Act (SIBA). VASP regime covers exchanges, custody, transfers, and admin of virtual assets. SIBA covers fund management, dealing, and arranging deals. BVI is one of the most popular offshore domiciles for crypto funds, and most BVI crypto funds are now Reporting Financial Institutions under the updated Common Reporting Standard (CRS 2.0).
Applies to
Virtual asset service providers and investment funds operating in or from the BVI
Key provisions
i.Virtual Assets Service Providers Act 2022 (in force Feb 2023): VASP licensing for exchange, custody, transfer, admin
ii.Regulatory Sandbox: 18 months of testing before full licensing
iii.Securities Investment Business Act (SIBA): licensing for investment business including fund management
iv.AML/CTF Travel Rule applies to virtual asset transactions of $1,000+
v.CRS 2.0: relevant crypto-assets explicitly within tax transparency scope
vi.Most BVI crypto funds now classified as Reporting Financial Institutions
Compliance
Apply for a VASP license under the 2022 Act or operate via the Regulatory Sandbox. Investment funds register under SIBA. Comply with AML/CTF Travel Rule and CRS 2.0 reporting.
Bermuda built the world's first dedicated digital asset business regime in 2018, before MiCA, before VARA, before Hong Kong. Now they're going further: the Premier says Bermuda will be the first fully on-chain national economy, with USDC for everyday payments. The SCPS Guidance and Custody Rules are the technical foundation. The political commitment is the real signal. Small jurisdiction, large ambition, and the regulatory infrastructure to back it up.
Digital Asset Business Act 2018, one of the world's first dedicated digital asset business regimes. Covers issuing, selling, and redeeming tokens, payment services using digital assets, and digital asset custody. 2024 SCPS Guidance specifically governs single-currency-pegged stablecoins. 2025 Custody of Client Assets Rules added formal custodial wallet requirements. Bermuda has publicly committed to becoming the world's first fully on-chain national economy, with USDC adoption in everyday payments.
Applies to
Digital asset businesses operating in or from Bermuda
Key provisions
i.Digital Asset Business Act 2018 (DABA) is the statutory basis for digital asset business in Bermuda
ii.Licensing covers issuance, sale, redemption of tokens, payment services using digital assets, and custody
iii.2024 SCPS Guidance: full reserve backing in HQLA, monthly attestation, redemption rights for single-currency stablecoins
iv.2025 Custody of Client Assets Rules: formal custodial wallet requirements for licensees
v.Public commitment from Bermuda Premier (WEF Davos): first fully on-chain national economy
vi.USDC integrated for everyday payments in the local economy
Compliance
Apply for a DABA license from the BMA. Stablecoin issuers comply with SCPS Guidance (full reserves, monthly attestations, redemption rights). Custodians comply with the 2025 Custody of Client Assets Rules.
Six places the regulatory regimes don't align. Each one is a practical cost for cross-jurisdictional players, and the cost is not going down.
01
The same wrapper has three different legal homes
A tokenized treasury fund is a “security” to the SEC, an asset-referenced token (or e-money token) to MiCA depending on yield mechanics, and a “specified investment” to the FCA. Three different regulatory homes for the same product, each with its own custody, disclosure, and trading-venue rules. The smart contract is identical across jurisdictions. The legal wrapper is not. A multi-jurisdictional rollout means three filings, three sets of approvals, three lawyers.
02
Custody regulation has forked the universe
SEC qualified-custodian rules want a DTCC-equivalent or a bank. FCA wants a UK FSMA-licensed firm. MAS wants a Capital Markets Services license. Anchorage, Coinbase Custody, Komainu, BitGo — none are cross-licensed in all three. A fund tokenized under SEC rules cannot settle into an FCA-licensed custodian without an intermediary, and the intermediary reintroduces the counterparty risk that tokenization was supposed to remove. The rails the regulators built around custody don't connect.
03
The stablecoin issuer must be a bank. Or not.
The GENIUS Act says bank charter for payment stablecoins. MiCA says e-money institution license, no bank charter required. MAS says payment services license, also no bank. The two largest stablecoins, USDT and USDC, are not banks. Under GENIUS, both would have to restructure to operate in the US — or stop. The bar between “bank” and “regulated payment institution” is the deepest fault line in stablecoin policy, and the EU and US are on opposite sides of it.
04
Europe and Asia built sandboxes. The US didn't.
FCA Sandbox, MAS Sandbox, EU DLT Pilot, Switzerland's FINMA-light path. Four explicit “test the new tech under relaxed rules” tracks. The SEC has no equivalent. The result is geographic: the experimental edge of tokenized issuance moves to where the experimental track is. American firms tokenize via Singapore, Switzerland, or BVI to stay legal. The “deeper US capital markets” advantage erodes when capital has to follow the issuer instead of the regulator.
05
Every regulator wants its own reporting pipeline
SEC's Consolidated Audit Trail. EU's MiFID II Approved Reporting Mechanisms. UK's FCA Transaction Reporting. MAS's MAS-ICAP. A token issued and traded across multiple jurisdictions needs simultaneous reporting in each format. Practical effect: most tokens choose one jurisdiction and accept the others as no-go markets. Cross- border issuance, the supposed promise of tokenization, is mostly theoretical at the regulatory layer.
06
The foundational question has two camps
The SEC frames tokenization as same security, different wrapper. Howey applies. The existing rules follow. MiCA frames it as a new asset class with new rules — bespoke regime, bespoke gatekeepers. Every secondary rule (custody, reporting, trading venues, market manipulation) is downstream of which framing you pick. The two camps are not converging. Cross-jurisdictional players have to operate under both ontologies simultaneously, and that's the cost.
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