Issuant Articles

Why a Judge Kept Gemini's $5M CFTC Penalty

Carter Bray — Fri, 16 Oct 2026 16:53:49 GMT

In brief: On October 16, 2026, US District Judge Alvin K. Hellerstein refused to vacate the $5 million settlement that resolved the Commodity Futures Trading Commission's 2022 case against Gemini Trust Company, even though the agency and the firm had jointly asked him to erase it. The ruling establishes that a consent order entered as a court judgment does not disappear simply because the regulator who negotiated it later changes its mind. For institutions, it is a clean illustration that a settled enforcement record is a durable fact, not a position subject to revision.

What did the judge actually decide?

A federal judge kept an enforcement penalty on the books after both sides tried to remove it. On October 16, 2026, Judge Hellerstein of the Southern District of New York denied a joint motion by the CFTC and Gemini to vacate the $5 million consent order the two parties had agreed to in January 2025. The unusual feature here is the alignment: the plaintiff that won the penalty and the defendant that paid it stood together asking the court to undo its own judgment, and the court declined.

A consent order is a negotiated settlement that a court adopts and enters as a binding judgment, which is why it carries more weight than a private agreement between parties. Once a judge signs it, unwinding it requires the court's consent, and that consent was not forthcoming.

The decision matters beyond the parties because it draws a line institutions can rely on: the finality of a court-entered settlement is not contingent on the enforcing agency's continued enthusiasm for the case.

How did the case get here?

The dispute runs back nearly a decade. In June 2022, the CFTC filed a complaint in the Southern District of New York alleging that Gemini, the exchange founded by Cameron and Tyler Winklevoss, made false or misleading statements of material fact, or omitted material facts, to agency staff between roughly July and December 2017. The statements concerned a proposed Bitcoin futures contract that a designated contract market intended to self-certify, a product that would have settled against the spot price produced by the Gemini Bitcoin Auction.

That detail is what made the exchange's representations consequential. Because the contract would have settled on prices from Gemini's own auction, the auction's resistance to manipulation went to the heart of whether the product complied with the Commodity Exchange Act. According to reporting by Reuters at the time, the contract was significant precisely because it would have been among the first digital-asset futures listed on a designated contract market.

In January 2025, Gemini settled. Hellerstein entered a consent order imposing a $5 million civil monetary penalty and enjoining the firm from making false or misleading statements to the CFTC, resolving the matter under Section 6(c)(2) of the Commodity Exchange Act, the provision that bars knowingly making a false statement of material fact to the Commission. As is standard, Gemini consented without admitting or denying the allegations.

Why did the regulator want to drop its own win?

The reversal came from the top of the agency. In May 2026, the CFTC joined Gemini in a motion for relief from judgment, an extraordinary step in which the enforcing body asked a court to undo a penalty it had secured. The agency's position, under new leadership, was that the 2022 complaint should not have been brought. The CFTC pointed to concerns about the reliability of a witness the original case had leaned on, and framed the earlier action as a matter that warranted correction rather than defense.

Gemini, for its part, had already gone on the offensive. In 2025 the firm filed a formal complaint accusing the CFTC of a years-long enforcement campaign it characterized as politically motivated. The joint motion in 2026 was, in effect, both parties arriving at the same destination from opposite directions: the agency conceding error, the firm seeking vindication.

The court was unmoved by the consensus. A settled judgment, in Hellerstein's handling, is not a private matter the parties can cancel at will once the public act of entering it is done.

What does this mean for issuers and the finality of settlements?

The practical lesson is that a consent order is a one-way ratchet in a way many institutions underestimate. Firms often treat settlements as closed chapters that fade with time or with a change in regulatory posture. This ruling says the opposite: the record stands as entered, and a sympathetic future administration cannot reliably erase it. As The Block noted in its coverage, even unanimous agreement between plaintiff and defendant was not enough to move the court.

That durability cuts in more than one direction. For a firm that settles, the penalty and the admission-free resolution remain part of its disclosed history, relevant to counterparties, auditors, and anyone conducting diligence on its regulatory standing. For a firm weighing whether to fight or settle, it sharpens the calculus: a consent order is not a provisional arrangement that a later political wind might reverse, but a judgment with the staying power of any other court order.

There is a governance point here as well. Enforcement priorities shift with each change of administration, and the Gemini episode shows an agency trying to walk back a prior stance. Courts, by contrast, are not instruments of enforcement policy, and a judge asked to vacate a judgment will weigh the integrity of the judicial record rather than the regulator's current preferences. Institutions building programmable, auditable instruments should read that distinction carefully: the regulatory mood may be fluid, but the paper trail a court creates is fixed.

It is a useful frame for how we think about compliance records at Issuant. An auditable history is only as valuable as its permanence, and this ruling is a reminder that the facts of a resolved matter are meant to stay settled.

What to watch next

The open question is procedural but far from academic: whether the CFTC and Gemini appeal the denial, and whether an appellate court would see the standard for vacating a consent judgment any differently. A decision to let the penalty stand without further challenge would cement the reading that regulator remorse, however sincere, does not unwind a court's judgment. An appeal would test exactly how much deference a reviewing court owes to a trial judge who declined to erase his own order.

The broader signal to watch is whether other firms with settled CFTC or SEC matters attempt similar relief now that an agency has shown willingness to disavow a past case. If they do, Hellerstein's ruling gives the courts a recent and pointed precedent for saying no. For institutions, the takeaway holds regardless of what happens on appeal: treat a consent order as permanent, because the one body with the power to make it disappear has just declined to use it.

Why did Standard Chartered push its $2T stablecoin call to 2030?

Carter Bray — Wed, 14 Oct 2026 19:20:33 GMT

In brief: Standard Chartered has pushed its forecast for a $2 trillion stablecoin market from 2028 to 2030, keeping the target intact but adding two years because supply growth stalled near $309 billion over the past year. The bank's research argues the slowdown is cyclical, not structural: while the stock of outstanding stablecoins flatlined, transaction volumes hit a record $19 trillion in May 2026 and average velocity doubled to roughly 30 times, signaling that usage kept climbing even as issuance paused.

What exactly did Standard Chartered change?

Standard Chartered has moved its $2 trillion stablecoin market forecast to 2030, two years later than the end-2028 date it set in April 2025. The dollar figure did not change. The timeline did. In a report published on 14 October 2026, Geoffrey Kendrick, the bank's global head of digital-asset research, told The Block that the bank is keeping its $2 trillion estimate but now expects the market to take two years longer to reach it, because supply growth has stalled this year.

A stablecoin is a privately issued digital instrument designed to hold a fixed value, typically one US dollar, and backed by a reserve of cash and short-dated government paper. The forecast tracks the total value of these instruments outstanding, a measure of how much capital institutions and users have parked in programmable dollar balances.

The original call was aggressive. In April 2025, analysts led by Kendrick wrote in a note cited by CoinDesk that US legislation would push total stablecoin supply from roughly $230 billion to $2 trillion by year-end 2028. Eighteen months on, the destination still looks reachable to the bank. The road just got longer.

Why has the market grown slower than expected?

The core reason is that supply stopped expanding. Stablecoin supply has held between $300 billion and $320 billion over the past twelve months and currently sits around $309 billion, according to Kendrick. For a sector that nearly doubled in the two years prior, a year of flat issuance is a meaningful stall.

Standard Chartered reads this as cyclical rather than structural. The pause arrived during a stretch of weak crypto-market activity, and past periods of flat or falling stablecoin supply were followed by renewed growth once those markets recovered. In other words, the bank is treating the plateau as a function of the broader risk cycle, not as evidence that institutional demand for programmable dollars has topped out.

That distinction matters for anyone underwriting the asset class. A structural ceiling would force a rethink of the entire thesis. A cyclical dip pushes the clock back without changing the endpoint, which is precisely the adjustment the bank made.

If supply stalled, how is usage still a bull case?

Because the two moved in opposite directions. While the stock of outstanding stablecoins flatlined, the flow across them accelerated. Raw transfer value reached a monthly record of $19 trillion in May 2026, and monthly volume has averaged just under $10 trillion so far this year, up from roughly $4 trillion in 2025.

The cleaner signal is velocity, the number of times each stablecoin dollar changes hands in a month. By Standard Chartered's measure, average monthly velocity has doubled to around 30 times this year from about 15 times in 2025. Here is what that divergence looks like in plain terms:

Metric	2025	2026 (so far)
Outstanding supply	growing toward ~$300bn	flat, ~$309bn
Average monthly transfer volume	~$4 trillion	just under $10 trillion
Average monthly velocity	~15x	~30x
Record monthly volume	—	$19 trillion (May)

A doubling in velocity against flat supply tells you the installed base is working harder, not sitting idle. For an institution weighing whether programmable dollars are a settlement rail or a speculative parking lot, rising turnover on a stable base points toward the former. The instruments are being used to move value, not merely to hold it.

Does the regulatory backdrop support the longer runway?

It does, and this is the part of the thesis that has firmed up since the original 2028 call. The United States now has a federal framework. The GENIUS Act was signed into law on 18 July 2025 as Public Law 119-27, establishing the first comprehensive federal regime for payment stablecoins. It defines a payment stablecoin as a digital instrument designed for payment or settlement that the issuer is obligated to redeem at a fixed value.

The reserve rules are strict, and strictness is what makes the instrument institutionally credible. Issuers must hold at least one dollar of permitted reserves for every dollar issued, and eligible reserves are confined to cash, insured demand deposits, short-dated Treasury bills, overnight Treasury-backed repo, and money-market funds invested solely in those assets. The law explicitly bars reserves in corporate debt, commercial paper, or other non-governmental securities. Issuers must also publish monthly reserve-composition disclosures, and those with more than $50 billion outstanding must file annually audited statements.

The framework is not fully live. Treasury and the banking agencies are still writing implementing rules, with a key effective date pointed at January 2027, and FinCEN and OFAC have proposed anti-money-laundering and sanctions requirements for permitted issuers. That rulemaking gap is itself part of why a 2030 target reads more plausibly than a 2028 one: the compliant issuance that drives supply back up cannot fully scale until the rules settle.

Europe got there first on the authorization side. Under the EU's Markets in Crypto-Assets regulation, the stablecoin provisions for e-money tokens and asset-referenced tokens took effect on 30 June 2024, requiring issuers to be authorized and to hold fully segregated, liquid reserves. Two major jurisdictions now impose reserve quality, redemption rights, and disclosure as conditions of market access. That is the auditable foundation large allocators have been waiting for.

What should institutions take from a two-year slip?

The honest read is that the destination held while the schedule moved, and a schedule that moves with the cycle is a more credible forecast than one that pretends the cycle does not exist. For issuers, asset managers, and banks evaluating programmable dollar instruments, the signal worth weighting is not the flat supply line but the doubling velocity beneath it: capital is composable and in motion, settling against reserves that regulation now demands be high quality and continuously disclosed. That combination, auditable backing plus rising real-world use, is exactly the base on which the next trillion gets built, and it is the standard issuers like Issuant are built to meet.

Should the US Scrap the 20-Year Treasury Bond?

Carter Bray — Mon, 12 Oct 2026 21:42:09 GMT

In brief: Wall Street has revived the argument that the US Treasury should scrap the 20-year bond, the maturity it reintroduced in May 2020 to help fund pandemic borrowing. The security consistently trades at a yield premium to where its position on the curve implies it should, a liquidity cost borne by the taxpayer, and Citigroup now expects Treasury Secretary Scott Bessent to trim long-end auctions and possibly cancel the 20-year outright. The counterargument, voiced by BNP Paribas, is that removing it now could unsettle a jittery long-end market and push yields higher still.

The US 20-year Treasury bond is a nominal government security that sits awkwardly between the heavily traded 10-year note and the benchmark 30-year bond, and the debate in autumn 2026 is whether the Treasury should stop selling it. Twenty-five years to the month after the Treasury shocked investors by ending sales of the 30-year bond in 2001, the market is once again asking whether a long-dated maturity has outlived its usefulness. This time the candidate for the chopping block is the 20-year, a security that was absent from the curve for 34 years before its 2020 revival.

Why was the 20-year bond brought back in the first place?

The Treasury resurrected the 20-year in May 2020 for a plain reason: it needed to borrow an extraordinary amount, fast. Facing a record quarterly funding requirement during the first wave of the pandemic, the department wanted to extend the duration of its debt and add a fresh point of issuance capacity. The inaugural auction on May 20, 2020 sold $20 billion, and the Treasury promised to issue the bond in regular, predictable, benchmark size so that it would become a genuine liquidity point on the curve, as the New York Fed noted at the time.

That promise has only been half kept. The 20-year added capacity, but it never earned the deep, reliable demand that the 10-year and 30-year command. Its awkwardness is structural. It overlaps in duration with the long end without being the benchmark there, and many of the natural buyers of long-dated duration, pension funds and insurers, anchor their liabilities to the 30-year. The result is a security that often clears at a yield above what an interpolation between the 10-year and 30-year would suggest, a persistent concession the market demands for holding a less liquid instrument.

How much is the liquidity premium costing the Treasury?

The clearest recent illustration came at the September 15, 2026 auction, where it took a yield of 5.42 percent to place the full $13 billion on offer, the highest level since the maturity returned in 2020. The auction tailed by 2.0 basis points, meaning the bond cleared cheaper (at a higher yield) than the when-issued market had priced moments before, a textbook sign that demand fell short of expectation. By comparison, that same day the 10-year note drew the strongest coverage of the three coupons auctioned.

The climb did not stop there. Federal Reserve H.15 data put the 20-year constant-maturity yield at 5.64 percent on October 8, 2026, well above its trailing twelve-month average near 4.94 percent. Every basis point of concession at a tenor the government must roll indefinitely compounds into real interest expense. That is the heart of the fiscal argument: a security that chronically prices cheap is, in effect, a standing surcharge on federal borrowing.

The case is not new, and it has a notable author. In August 2024, Steven Mnuchin, the Treasury Secretary who created the modern 20-year bond, said it was time to kill it, arguing the maturity costs taxpayers money precisely because it trades at a premium to the rest of the curve. When the official who revived an instrument concludes it should be retired, the structural critique is hard to dismiss as mere market grumbling.

What is Citigroup expecting from Bessent?

The revived speculation has a concrete catalyst: the quarterly refunding cycle. Citigroup told clients in October 2026 that Bessent is likely to reduce long-dated auction sizes and could cancel the 20-year altogether. Jason Williams, the bank's head of US rates strategy, put the base case at a $3 billion cut to each 20-year and 30-year auction, with the shortfall made up by issuing more Treasury bills.

There is a political edge to that forecast. For years, Bessent and his allies criticized the previous Treasury leadership under Janet Yellen for leaning heavily on short-term bill issuance to hold down visible long-end supply. A pivot to the same playbook, cutting coupons and funding the gap with bills, would mark a notable reversal. Whether the 20-year survives as a smaller line item or disappears entirely is the specific question the November refunding is expected to answer.

Why might scrapping it backfire?

The counterargument is about timing and signalling, not structure. BNP Paribas warned in early October that axing the 20-year in the middle of a long-end selloff could exacerbate the very weakness it is meant to address, and the bank held to its forecast that the 30-year yield climbs toward 5.8 percent.

The mechanism runs through perception. Cutting long-dated supply when yields are already rising can read less as housekeeping and more as a flinch, an admission that the Treasury is struggling to place duration at acceptable cost. In a market already primed to watch for signs of fiscal strain, a move intended to save money at the margin risks being interpreted as capitulation to the bond market, which can lift term premiums across the whole long end rather than just at the 20-year point. The cheapness that makes the bond expensive to issue is the same cheapness that, if abruptly removed, could ripple outward.

What should institutions watch next?

The near-term signal is the November quarterly refunding statement, where the Treasury will either confirm the Citigroup thesis, trimming the 20-year or ending it, or leave the structure intact and defer the decision again. Beyond the headline, the detail that matters is the mix: a coupon cut funded by bills shortens the average maturity of the debt and reshapes the supply picture for anyone managing long-dated liabilities or structuring long-duration instruments against a Treasury benchmark.

The open question is whether the Treasury can retire a flawed security without the market reading the retreat as weakness. The 30-year precedent is instructive but inexact. That bond was cut in 2001 amid budget surpluses and brought back in 2006 when deficits returned, a reminder that issuance decisions made for near-term cost reasons can reverse when fiscal conditions turn. For institutions evaluating how programmable, auditable exposure to sovereign duration should be built and maintained, the lesson is that the composition of the benchmark itself is not fixed, and a credible issuance framework has to account for a curve whose constituent points can be added, shrunk, or removed with a single refunding statement. Issuant builds for exactly that kind of change: instruments whose terms and provenance stay legible even as the underlying reference market is redrawn.

Why Is Blockchain.com Seeking a CFTC License?

Carter Bray — Fri, 09 Oct 2026 18:15:27 GMT

In brief: Blockchain.com has applied to the Commodity Futures Trading Commission for two licenses, a designated contract market (DCM) and a futures commission merchant (FCM), that together would let it run a regulated US exchange for event contracts and act as a broker for crypto derivatives. The filing, reported by CNBC on October 9, 2026, places the firm in a crowded queue of applicants chasing a market that cleared more than 25 billion dollars in volume last year. For institutions, the story is less about one company and more about which regulatory framework now governs event-based and derivatives trading in the United States.

What exactly did Blockchain.com apply for?

Blockchain.com told CNBC it has filed for two separate CFTC licenses to offer event contracts and cryptocurrency derivatives to retail and institutional customers in the United States. The first, a designated contract market license, would let the company operate a federally regulated futures exchange. The second, a futures commission merchant registration, would let it act as a broker handling customer orders and funds for derivatives contracts.

A designated contract market is, in plain terms, a CFTC-regulated venue authorized to list and trade futures and event contracts under the Commodity Exchange Act. An FCM is the intermediary that carries customer accounts and routes trades to that venue. Holding both is the structure that lets a single firm run the exchange and serve the customer, rather than relying on a third party for either role.

None of this is live in the US yet. The applications are pending, and Blockchain.com has not announced a launch timeline. The company already offers prediction markets and perpetual futures to some international customers, so the filing is about bringing an existing product set into a US framework rather than building one from scratch. Chief executive Peter Smith framed the move around consolidation, saying users should be able to manage digital assets, trade derivatives, and take positions on real-world events without moving between separate apps.

How does this fit the wider rush for CFTC approval?

Blockchain.com is not acting alone. It joins eleven other companies that filed this year seeking DCM approval, and the CFTC cleared six new designated contract markets in 2026. According to law firm K&L Gates, the agency has cleared twelve new DCMs since the start of 2025, with more applications still pending. Crypto.com, Gemini, and Coinbase are among the other firms pursuing entry.

The pull is obvious once you look at the numbers. Total trading volume across CFTC-registered prediction markets exceeded 25 billion dollars in 2025, according to the agency's own rulemaking documents. Activity has compounded since. One prediction market lifted its daily average from 1,600 event contracts in April 2025 to 162,000 in April 2026. What was a fringe product two years ago now trades at a scale that established brokers cannot ignore.

The template for all of this is Kalshi, which registered as a designated contract market in November 2020 as the first regulated venue for event contracts. The Commission later modified its order to permit intermediated futures trading, and litigation over its political contracts resolved in its favor when the CFTC dropped its appeal in May 2025. That path, from registration to intermediated trading to legal validation, is the one new applicants are now trying to follow.

What do the two licenses actually authorize?

The distinction between the two registrations matters more than the headlines suggest, because they answer different questions about who does what in a trade. The table below separates them.

Dimension	Designated contract market (DCM)	Futures commission merchant (FCM)
Core role	Operates the regulated exchange where contracts are listed and matched	Brokers customer orders and holds customer funds
What it governs	The venue and the products traded on it	The relationship with the end customer
Primary obligations	Market integrity, contract design, surveillance, public-interest review of listings	Customer funds segregation, capital requirements, conduct rules
Analogy	The exchange itself	The broker on the exchange
Why Blockchain.com wants it	To list event contracts and crypto derivatives in the US	To serve retail and institutional customers directly

Holding both licenses lets one firm control the full stack, from listing a contract to carrying the customer account. That is efficient, and it is also why the regulatory bar sits where it does. An exchange that is also the broker concentrates responsibility for market integrity and customer protection in a single entity, which is precisely what the Commodity Exchange Act framework is built to supervise. The prize is a vertically integrated, auditable venue operating inside a recognized federal regime rather than offshore.

What is the regulatory backdrop institutions should weigh?

The framework is still moving. In June 2026 the CFTC issued a notice of proposed rulemaking on public-interest determinations for event contracts, setting out parameters for which listings warrant heightened review. Earlier in the year, staff issued an advisory signaling closer scrutiny of sports-related contracts, a category that dominates current volume. The rules that will ultimately govern a Blockchain.com DCM are being written in parallel with its application.

There is also unresolved tension with the states. A federal appeals court ruled in 2026 that states can regulate prediction-market platforms in ways resembling gambling oversight, and several state regulators have issued cease-and-desist letters to operators. The question of whether the Commodity Exchange Act preempts state gaming law remains contested across jurisdictions, which means a federal license does not, on its own, settle a platform's standing everywhere it operates.

Against that, the institutional direction of travel is clear. Blockchain.com is simultaneously building out adjacent regulated products, including a memorandum of understanding with the NYSE to distribute programmable US stocks and ETFs, alongside its reported plans for a US listing. The CFTC applications are one piece of a broader bid to sit inside recognized market infrastructure rather than beside it.

What should an institution do with this?

Treat the filing as a signal about structure, not a product launch. The practical takeaway is that event-based and derivatives trading is consolidating under the CFTC's DCM and FCM framework, and the firms that will matter are the ones holding both licenses inside a supervised regime. For any institution evaluating counterparties, building exposure, or weighing its own issuance against programmable and auditable instruments, the right move now is to track which venues clear the public-interest rulemaking and secure clean federal registration, and to treat that combination of licenses as the baseline for diligence. At Issuant, that is the same standard we apply to the infrastructure behind composable, auditable assets: the regime a venue operates under is as material as the products it lists.

ESMA Gives EU Platforms 3 Months to Drop Unauthorized Stablecoins

Carter Bray — Thu, 08 Oct 2026 16:11:34 GMT

In brief: On October 8, 2026, the European Securities and Markets Authority (ESMA) told crypto-asset service providers authorized under MiCA to stop offering services tied to stablecoins that lack EU authorization, and to clear remaining client positions no later than three months later, by January 8, 2027. The instruction names dollar tokens such as Tether's USDT and draws a sharp line between issuers that hold an e-money token authorization and those that do not. For institutions, the deadline turns stablecoin selection into a question of verifiable issuer status rather than market share.

What did ESMA actually require?

ESMA published an opinion setting out its supervisory expectations for services involving stablecoins that do not comply with the Markets in Crypto-Assets Regulation. A stablecoin, in the EU's legal vocabulary, is either an e-money token (pegged to a single currency) or an asset-referenced token (backed by a basket), and either one must be issued by an authorized entity to be distributed to clients in the Union. The regulator's language was direct: crypto-asset service providers authorized under MiCA should cease providing services related to non-MiCA-compliant stablecoins to clients in the European Union.

The reasoning rests on where the safeguards sit. ESMA argued that these services expose clients to risks that arise from the absence of issuer-level protections required under Titles III and IV of MiCA, and that a service provider cannot adequately identify, manage, or mitigate those risks on its own. The point is structural. If the issuer has not met the reserve, redemption, and disclosure standards the regulation imposes, no amount of diligence at the trading venue restores the protection the holder would otherwise have.

The three-month window is an outside limit, not a grace period. National regulators were told to resolve remaining customer holdings as soon as possible, and no later than three months after publication, which fixes the hard date at January 8, 2027. Services do not have to remain available for the full quarter. The clock simply caps how long legacy positions can linger while they are wound down.

Which stablecoins does this affect, and which are compliant?

The practical dividing line is authorization. Tokens whose issuers hold an EU e-money token authorization sit on one side; everything else sits on the other. Tether's USDT, the largest dollar stablecoin by circulation, is the headline name on the non-compliant side, and ESMA's opinion specifically flags tokens such as USDT that are offered without that status. Tether has not sought MiCA authorization, a choice its chief executive tied in part to the regulation's reserve composition rules in comments made as the regime came into force.

Circle is the counterexample most often cited. In July 2024 it became the first global stablecoin issuer to secure authorization under MiCA, through a French electronic money institution license, which brought USDC and the euro-denominated EURC inside the compliant set. A growing roster of bank-issued and fintech-issued euro tokens has followed, and ESMA maintains a public register of authorized e-money token issuers. The register, not the brand, is what determines whether a token can lawfully reach EU clients.

None of this arrived without warning. The stablecoin provisions of MiCA, contained in Titles III and IV of Regulation (EU) 2023/1114, became applicable on June 30, 2024, with the broader regime following at the end of that year. ESMA had already issued a statement in January 2025 pressing national authorities to bring providers into line and allowing a sell-only window so holders could convert out of non-compliant tokens. The October 2026 opinion is best read as the enforcement follow-through on a transition that has been under way for more than two years.

Why the issuer-level standard matters to institutions

The substance of MiCA's stablecoin rules explains why ESMA treats the distinction as non-negotiable. An authorized e-money token issuer must hold reserves that fully back the tokens in circulation, segregate and safeguard those assets, and honor redemption at par on demand. An asset-referenced token issuer faces a heavier process still: its white paper must be approved before issuance rather than merely notified, and its application must include a programme of operations, governance arrangements, a reserve description, and a recovery plan. The largest tokens, once they cross defined usage thresholds, graduate to direct oversight by the European Banking Authority.

For an asset manager or treasury function, these requirements are the point. A compliant stablecoin is one whose backing is auditable, whose redemption right is legally enforceable, and whose issuer answers to a named supervisor. Those are the same properties any institution would demand of a money market instrument or a deposit. The programmable settlement layer is attractive, but only when the claim underneath it is as sound as the instruments it aims to sit alongside.

That framing is where the news reaches beyond crypto venues. The qualities ESMA is insisting on, verifiable reserves, a clear redemption path, and a supervised issuer, are the qualities that make any programmable financial instrument fit for institutional balance sheets. Whether the asset is a stablecoin, a tokenized money market fund, or a credit instrument issued on composable infrastructure, the test is the same: can the holder trace the backing and enforce the claim. Infrastructure built around authorization and auditability, rather than around circulation, is the kind that survives a deadline like this one.

What to watch before January 8, 2027

The immediate variable is how national competent authorities interpret ESMA's instruction. Supervision under MiCA runs through member-state regulators, so the pace and strictness of enforcement may vary across jurisdictions even as the January 8 ceiling applies everywhere. Expect venues serving EU clients to accelerate conversions of non-compliant balances into authorized euro and dollar tokens, and to narrow the services, trading pairs, custody, and the like, they attach to names that remain outside the register.

The open question is what happens to liquidity. USDT remains the deepest stablecoin pool globally, and routing EU demand toward compliant alternatives tests whether the authorized market can absorb that flow without wider spreads or fragmentation between EU and non-EU venues. The regulation under which all of this sits is itself under review, with both ESMA and the European Banking Authority having proposed changes, so the reserve and significance rules that shape issuer behavior may yet shift. For now the signal to institutions is unambiguous. In the EU, a stablecoin's standing is decided by its issuer's authorization, and the window to act as though that were optional closes in January.

Why EU Issuers Still Back Dollar Stablecoins

Yonier Bellido — Fri, 02 Oct 2026 20:21:27 GMT

In brief: European issuers are launching regulated dollar-denominated settlement tokens under MiCA because the demand they serve is priced in dollars, not euros. The argument is not that the euro should lose ground at home. It is that a euro-only product cannot clear cross-border business where roughly 90% of stablecoin settlement already runs in US dollars, and that a compliant dollar instrument keeps that activity inside Europe's supervisory perimeter rather than pushing it offshore.

The case European issuers are making is straightforward once you strip out the politics. A dollar-denominated settlement token issued under MiCA is a programmable claim on a US dollar, fully reserved and supervised by an EU authority, built for institutions that invoice, borrow, and settle in dollars. The issuers behind the current wave, Germany's AllUnity and France's SG-Forge among them, are not arguing against the euro. They are arguing that the currency of a payment instrument should follow the currency of the underlying trade, and most of that trade is still denominated in dollars.

That tension came into sharp relief on 2 October 2026, when AllUnity, a joint venture of DWS, Flow Traders and Galaxy, launched USDAU, a dollar-pegged token, across six networks. It was the firm's fourth fiat-backed token, sitting alongside its euro, Swiss franc and Swedish krona instruments. The signal was hard to miss: an issuer with a BaFin e-money licence and a euro product already in market chose to add the dollar, not because the euro had failed, but because its clients needed dollars.

Why would a European issuer choose the dollar over the euro?

Because that is where the volume is. Dollar-pegged tokens account for the overwhelming majority of global stablecoin activity, with USDT and USDC together holding close to 90% of the market and the broader stablecoin sector sitting above $300 billion. Euro-denominated tokens, by contrast, remain a rounding error. One year after MiCA's stablecoin rules took effect, the euro stablecoin market had roughly doubled to about $680 million, according to a Decta study reported in December 2025. Doubling is real growth, but $680 million against a $300 billion-plus dollar market tells you which currency the infrastructure is being built around.

An issuer looking at those numbers reaches a practical conclusion. A euro token serves European domestic use and a specific policy goal. A dollar token serves the global commerce its clients actually conduct: commodities, trade finance, correspondent flows, and treasury operations that have been dollar-denominated for decades. For a business moving money across borders, a euro-only menu is not a neutral choice. It is a product that cannot settle the transaction in front of it.

Does MiCA even allow a dollar stablecoin?

Yes, and this is the part the debate often misses. MiCA was designed to regulate stablecoins by structure, not by flag. The regulation sorts tokens into e-money tokens, which reference a single official currency, and asset-referenced tokens, which reference a basket or other assets, with the detailed rules having applied since 30 June 2024. A dollar-pegged token issued by a licensed EU electronic money institution is a perfectly ordinary e-money token under the framework. SG-Forge, the digital-assets arm of Société Générale, demonstrated exactly this when it launched USDCV, a MiCA-compliant dollar token, and later integrated it into mainstream wallet distribution.

What MiCA does impose on non-euro tokens is a usage ceiling. Where a dollar e-money token is used widely as a means of exchange within the EU, Article 23 caps it at 1 million transactions per day or €200 million in aggregate daily value, at which point the issuer must halt new issuance. The cap was written, as one analysis put it, out of a specific anxiety: the ECB did not want a dollar-pegged token to become the de facto unit of account for European retail payments. That is a constraint on retail displacement, not a prohibition on dollar instruments. For institutional cross-border settlement, which is where issuers are aiming, the structure is both permitted and supervised.

What happens if Europe does not supply this?

The demand does not disappear. It relocates. The clearest illustration is what MiCA did to Tether's USDT, the largest dollar stablecoin in the world. Because Tether chose not to pursue EU authorization, European venues moved to remove it: Coinbase, Binance and others delisted USDT from EU-facing services to comply. The appetite for dollar liquidity did not fall. It simply shifted toward whatever remained accessible, much of it outside direct European oversight.

This is the substance of the issuers' argument, and it is a supervisory one rather than a commercial one. If European institutions need dollar settlement and no compliant European dollar instrument exists, they will source dollars through channels Europe does not regulate. A MiCA-authorized dollar token reverses that. It keeps the reserves under an EU regulator's eye, keeps the issuer accountable to European law, and keeps the activity auditable within the single market. Seen this way, the dollar token is not a concession to American monetary power. It is the mechanism that brings dollar activity back inside the perimeter.

Is this a retreat from the euro, or a parallel track?

A parallel track, and the issuers themselves are explicit that these products are complements, not substitutes. AllUnity did not retire its euro token when it launched USDAU; it added a fourth currency to a shelf that already held three. SG-Forge has elevated and distributed both its euro and dollar CoinVertible lines. The pattern across the market is multi-currency issuance from a single regulated entity, where the euro serves the policy objective of a sovereign European instrument and the dollar serves the operational reality of global trade.

The European Central Bank's broader concern about digital dollarization is legitimate, and the Article 23 cap exists precisely to address it. But the policy question of whether Europe should strengthen the euro's international role and the operational question of whether European businesses need dollar settlement today are different questions. Treating them as the same thing produces a euro-only mandate that does not eliminate dollar demand. It only pushes that demand somewhere less visible.

The single thing that matters most for institutions evaluating this shift is control, not currency. A regulated dollar settlement token is not a bet on the dollar over the euro. It is a decision to keep dollar-denominated activity programmable, reserved, and auditable under European supervision rather than conducting it through instruments Europe cannot see. For issuers building on composable, compliant infrastructure, the lesson of this moment is that the currency follows the customer, and the supervisory framework should follow the currency, which is exactly the problem a platform like Issuant is built to solve.

What Is in the SEC's New Exam Handbook?

Juan Sanchez — Thu, 01 Oct 2026 18:40:09 GMT

In brief: On October 1, 2026, the SEC's Division of Examinations published The SEC Exam Handbook: A Practical Guide on Process and Engagement, replacing the older EXAMS Brochure. The handbook lays out, in plain terms, how the Division conducts examinations and what a registered firm should expect at each stage. For asset managers, advisers, and broker-dealers, it turns a process that often felt opaque into a documented roadmap.

The SEC Exam Handbook is a published guide, issued by the Division of Examinations on October 1, 2026, that explains the examination process from first contact to close and sets out what registered firms can expect at each stage. It replaces the Division's previous EXAMS Brochure and, in the Division's words, offers "more insight and detail about what to expect during an examination." For institutions that hold securities registrations, it is the clearest statement yet of how an exam actually runs.

Why did the SEC publish a new exam handbook now?

The Division framed the handbook around transparency and consistency. According to the SEC's announcement, the document "provides a clear roadmap of the process used by division examiners across the country to help ensure consistency" and reflects a commitment to approach each examination "with an accessible and collaborative mindset."

SEC Chairman Paul S. Atkins tied the release to the agency's core mandate. "The Division's new handbook clarifies the examination process, offering regulated entities greater insight into what to expect during an exam and establishing clear expectations," Atkins said in the announcement, adding that the added transparency would "make examinations more effective."

The timing was signaled in advance. Speaking at the Investment Company Institute's Compliance, Risk, and Legal Conference in Nashville on September 16, 2026, Division Director Keith Cassidy previewed the handbook, describing it as "a modern and expanded replacement to our previous EXAMS Brochure" that would be "clearer, more practical, and built around the questions we hear most often from our registrants." On publication, Cassidy added that the Division's goal of being more accessible "provides registrants and the Commission with a more efficient and effective examination program."

Who does the Division of Examinations examine?

The Division runs the SEC's National Exam Program, and its reach is broad. It examines SEC-registered investment advisers, investment companies such as mutual funds and exchange-traded funds, broker-dealers, transfer agents, municipal advisors, securities-based swap dealers, clearing agencies, and self-regulatory organizations. The Division is staffed by more than 1,100 people working out of Washington and eleven regional offices, a scale reported by Holland & Knight in its coverage of the program.

Formed in 1995, the Division marked its thirtieth year in 2025. Its stated mission, set out on the SEC's own pages, is to protect investors, ensure market integrity, and support responsible capital formation. The findings from its exams feed directly into rulemaking, risk monitoring, and, where warranted, referrals to the Division of Enforcement. That last point matters: an examination is not an enforcement action, but it can become the trigger for one.

How does an SEC examination actually work?

This is the question the handbook exists to answer, and it is the one institutions ask most. An examination is a structured review of a firm's books, records, and practices to test compliance with the federal securities laws. Firm selection is risk-based rather than random, meaning the Division targets practices, products, and services it judges to present heightened risk to investors or to market integrity.

The handbook organizes the engagement into recognizable stages. In practice, an exam moves from notification and an initial document request, through staff review and on-site or remote fieldwork, to communication of findings and a closing. Cassidy described the document at the Nashville conference, per reporting of the speech, as "designed to align expectations and create predictability" and "filled with helpful resources for registrants to consult before and during their exams." The practical value for a compliance team is that the sequence, and the firm's obligations at each point, are now written down rather than inferred from experience.

The handbook does not change the law, and it does not expand the Division's authority. What it changes is the information asymmetry. A first-time registrant and a seasoned multi-strategy manager now work from the same published description of the process.

How does the handbook fit with the 2026 exam priorities?

The handbook is the "how," while the annual examination priorities are the "what." Each autumn the Division publishes its priorities for the coming fiscal year, signaling the areas it intends to scrutinize. The 2026 priorities, announced in November 2025, continued the Division's focus on fiduciary duty, standards of conduct, and risk areas spanning advisers, broker-dealers, and other registrants. Firms should read the two documents together.

Document	What it tells you	Cadence
SEC Exam Handbook	The process: how an exam is initiated, conducted, and closed	Published once, updated as needed
Examination Priorities	The focus: which practices and risks the Division will target	Published annually

Treading the process guide alongside the priorities lets a firm prepare on two fronts at once: knowing how the Division will engage, and knowing what it is likely to ask about.

What should institutions do with it?

The straightforward answer is to treat the handbook as a baseline for examination readiness. A firm that maps its own books, records, and controls against the stages the handbook describes can close gaps before a notification arrives rather than after. Because the Division's findings can inform policy and, where appropriate, enforcement referrals, the cost of being unprepared is not purely administrative.

The deeper point is cultural. An examination tests whether a firm's records are complete, consistent, and capable of being produced on request. Institutions that treat their records as programmable and auditable by design, rather than reconstructing them under deadline pressure, are the ones that handle an exam as routine. That is the posture the handbook rewards, and it is the posture Issuant is built to support for firms whose assets and records need to be verifiable on demand.

Frequently asked questions

Is the SEC Exam Handbook legally binding on firms?

No. The handbook is a descriptive guide to the examination process, not a rule or regulation. It does not create new obligations or expand the Division's authority. Firms' legal duties continue to flow from the federal securities laws and existing SEC rules. The handbook's purpose is to make the existing process transparent and predictable.

Does an SEC examination mean my firm is suspected of wrongdoing?

Not necessarily. The Division selects firms on a risk basis, and examinations are a routine part of oversight that serve to improve compliance, monitor risk, and inform policy. An exam is distinct from an enforcement action. That said, where staff identify serious issues, the Division can refer a matter to the SEC's Division of Enforcement, so firms should take the process seriously.

How does the handbook differ from the old EXAMS Brochure?

The handbook replaces and expands upon the previous brochure. Per the SEC, it offers more detail and insight into what to expect, and Director Keith Cassidy described it as a "modern and expanded" version built around the questions registrants ask most often. In short, it is longer, more practical, and more explicitly organized around the stages of an actual examination.

Why Did the 30-Year Treasury Yield Hit a 2002 High?

Carter Bray — Tue, 29 Sep 2026 20:44:50 GMT

In brief: The US 30-year Treasury yield rose to roughly 5.6% on September 29, 2026, its highest level since 2002, according to Bloomberg. The move is driven less by expectations for the Federal Reserve's policy rate and more by a rebuilt term premium, record Treasury issuance, and persistent deficits. For institutions issuing debt or holding long-duration assets, it raises the cost of long-term capital and repriced the anchor against which most long-dated liabilities are valued.

The long end of the US government curve has reset to a level not seen in more than two decades. On September 29, 2026, the 30-year Treasury yield climbed to about 5.6%, the highest reading since 2002, as CNBC and Bloomberg both reported. The 30-year yield is the benchmark against which long-term borrowing across the economy is priced, so a fresh multi-decade high is not a curiosity for rates traders alone. It changes the arithmetic for anyone raising capital over a long horizon or carrying long-dated obligations on a balance sheet.

What actually moved, and by how much

The repricing was steady rather than sudden. The 30-year yield stood near 4.75% in September 2025, per data compiled by Advisor Perspectives, and climbed above 4.8% by December. Through 2026 the ascent accelerated: the yield topped 5.31% in August, a 19-year high at the time, according to CNBC, before pressing on to the 2002 milestone in late September. By the September 28 close the curve read 4.94% at two years, 5.24% at ten, and 5.56% at thirty, StreetStats data shows. That shape matters: the long end is rising faster than the short end, a bear steepening that tends to punish the longest-duration holdings hardest.

Why are long-term Treasury yields rising?

The short answer is that the move is being priced off the deficit, not the Fed. Truist Wealth put term premium at the heart of it: the additional compensation investors demand for holding a long-maturity bond rather than rolling short-term paper. After more than a decade in negative territory, the New York Fed's ACM term premium turned positive in late 2023 and has stayed there, and it sat near 0.76% at the ten-year point in August 2026 by Federal Reserve Bank of New York estimates. A positive, rising term premium is the market charging more to warehouse duration risk, and it lands most heavily on the 30-year.

Supply is the second force. The federal deficit reached roughly $1.8 trillion over the first ten months of fiscal 2026, the Committee for a Responsible Federal Budget confirmed, and financing that gap means heavier issuance of longer-dated debt into a market with fewer captive buyers. Interest on the national debt alone reached about $857 billion over the first nine months of the fiscal year, up 13% from a year earlier, according to JPMorgan Chase, a figure that now tops what Washington spent on Medicare over the same stretch. Chase attributes the yield climb to inflation expectations, firm economic data, growing deficits, and rising issuance, a combination that has pushed investors to demand more for holding the long end.

The buyer base has thinned at the same time. Foreign official holders have stepped back, with Japan and China cutting exposure and price-insensitive holders now owning a smaller share of the market than they did two decades ago, as CNBC reported. Reduced official demand leaves more of the debt to be absorbed by price-sensitive private investors, who set their own terms.

What a higher 30-year yield means for issuers

For any institution funding at the long end, the direct effect is a higher cost of capital. The 30-year yield is the reference point for long-dated corporate debt, project finance, and infrastructure funding, so a benchmark near 5.6% lifts the all-in coupon on new long-term issuance even before credit spreads are added. The US Treasury itself is now set to pay the most on 30-year debt in a quarter of a century, which frames the environment every other long-term borrower faces.

The pressure carries into the real economy through mortgage rates, which track long-term Treasury yields closely. When yields jumped in late September, Zillow noted the move threatened to erode the affordability that fall buyers had been counting on. For issuers of mortgage-backed and asset-backed paper, that link feeds directly into funding economics and origination volumes.

There is a partial offset on the liability side. Higher long-term discount rates lower the present value of long-dated obligations, which improves the funded status of defined-benefit pension plans, a dynamic Mercer tracks through its pension discount yield curve. Plan sponsors whose liabilities are valued against high-grade long-term rates see those liabilities shrink as yields climb, even as the same move marks down the long-duration bonds held to match them.

What it means for long-duration portfolios

For asset managers, the bear steepening is a duration event. Rising yields at the long end mean falling prices on the longest bonds, and the further out the maturity, the sharper the mark-to-market hit. Morningstar has framed the steepening curve as a signal to reconsider where on the maturity spectrum a portfolio takes its interest-rate exposure. Managers who reached for yield at the 30-year point now hold instruments whose prices are most exposed to any further repricing of term premium.

The flip side is entry level. Long Treasuries at 5.6% offer a starting yield unavailable for most of the past twenty years, and BNY Investments has argued the reset presents opportunities for buyers willing to lock in income at these levels. The judgment for allocators is whether the term premium has finished rebuilding or has further to run, and whether the deficit dynamics driving supply persist. The Congressional Budget Office estimate is sobering on that point: each percentage point that rates run above the projected path would add roughly $3.2 trillion to cumulative federal interest costs over the coming decade, a figure cited by the Financial Times that suggests the supply pressure is structural rather than transitory.

What this reset ultimately underscores is that the risk-free rate is doing more work than it has in a generation. When the 30-year prices the deficit rather than the policy path, every long-dated cash flow, whether a coupon owed, a liability discounted, or an asset valued, is being measured against a moving and more demanding benchmark. Institutions that price, issue, and value long-horizon exposures against clean, auditable reference rates will be better placed to act as that benchmark keeps shifting, which is precisely the discipline Issuant is built to support.

What Does the SEC Expect on Private Asset Valuation?

Carter Bray — Mon, 28 Sep 2026 20:17:33 GMT

In brief: On September 28, 2026, the staff of the SEC's Office of the Chief Accountant and Division of Investment Management issued what Bloomberg called a “critical” reminder that funds holding hard-to-value private assets must measure fair value rigorously and disclose the risks plainly. The statement adds no new rules. It signals that examiners will scrutinize how firms mark illiquid holdings and how those marks reach investors, as private credit in registered funds has grown to $270 billion.

What did the SEC actually say?

The SEC statement is a reminder, not a rule. Signed by Chief Accountant Kurt Hohl and Division of Investment Management Director Brian Daly, it restates that registrants already required to measure private assets at fair value must do so with discipline, and must disclose the assumptions and risks behind those measurements. Bloomberg reporter Nicola M White summarized the message plainly: the agency is spurring the industry to put more effort into valuing private assets as those holdings become harder to sell and redemption requests rise.

The substance rests on an existing framework. Fair value measurement is the process of estimating what an asset would fetch in an orderly sale when no active market price exists, and for registered funds it is governed by Rule 2a-5 under the Investment Company Act of 1940, adopted in December 2020. That rule requires funds to assess and manage valuation risks, select and test their methodologies, and oversee any pricing services they rely on. The September statement is the staff pointing back at those obligations and telling the market it intends to check the work.

Why is the SEC pressing on this now?

The timing tracks a structural shift in where capital sits. The staff observed that private credit inside registered fund portfolios has grown nearly 60 percent, from $170 billion in December 2020 to $270 billion in December 2025. That figure covers the vehicles most exposed to retail money: registered closed-end funds, interval funds, tender offer funds, and business development companies. The wider market is larger still. Cleary Gottlieb notes that direct lending now matches the syndicated loan market at $1.5 to $2 trillion and is forecast to reach $3 trillion by 2028.

Two pressures converge. First, retail access is widening. An August 2025 executive order directed regulators to open 401(k) plans to alternative assets, and the Department of Labor advanced a proposed rule in March 2026 to that end. Second, liquidity is tightening: McKinsey reports that private equity distributions relative to assets under management fell to around 6 percent, a multi-year low, which means more assets are being held and marked rather than sold and priced. When more households own instruments that trade rarely, the integrity of the mark carries more weight.

How does fair value guidance compare across the relevant frameworks?

Institutions holding private assets answer to more than one authority, and the obligations differ by vehicle and by source. The table below sets out the main reference points an issuer or manager should map against its own book.

Framework or source	Who it binds	Core valuation obligation
Rule 2a-5, Investment Company Act (Dec 2020)	Registered funds and BDCs	Assess and manage valuation risk, select and test methodologies, oversee pricing services, keep records under Rule 31a-4
September 2026 staff statement	Registrants measuring private assets at fair value	No new duty; a reminder to apply Rule 2a-5 rigorously and disclose assumptions and risks
2026 Division of Examinations priorities	Investment advisers and funds under exam	Fair value and disclosure of illiquid and hard-to-value holdings flagged as a focus area
ASC 820 fair value hierarchy (accounting)	Any entity reporting fair value	Classify inputs as Level 1, 2, or 3; private assets typically fall to Level 3, requiring disclosure of unobservable inputs

The table makes the pattern clear. No single rule was introduced in September 2026. Instead, the staff statement, the examination agenda, and the underlying accounting standard point in one direction: private-asset marks that rest on Level 3 unobservable inputs must be defensible, tested, and legible to the investor and the examiner alike. The gap the SEC is probing is not whether firms have a policy, but whether the policy holds up when the asset cannot be sold and the redemption queue is growing.

What separates a defensible mark from a fragile one?

The difference is traceability. A defensible valuation shows its inputs, records who reviewed them, and explains why the chosen methodology fits the instrument. A fragile one leans on a stale comparable or a manager's judgment that cannot be reconstructed after the fact. The SEC has been circling this distinction for more than a year. In October 2024, top regulators publicly called out valuation risks in private credit, and by April 2026 the agency was monitoring emerging pressures in the space. The September reminder is the next step in that sequence, moving from concern to expectation.

Disclosure is the second half of the test. It is not enough to arrive at a number. Funds must convey to investors how the number was reached and what could move it, particularly the liquidity risk that a stated value may not be realizable on demand. That is precisely the friction the statement addresses: values that look firm on a statement but soften the moment an investor asks to redeem.

What should an institution do with this?

Treat the statement as a preview of the exam, not a footnote. Map every private-asset position to its governing framework, confirm that the methodology behind each Level 3 mark can be reconstructed by someone other than the person who set it, and check that investor disclosures name the liquidity and valuation risks rather than gesturing at them. Where the underlying record is thin, rebuild it before an examiner asks. The institutions that fare best under this scrutiny will be those whose valuations are programmable in their logic, composable across systems, and auditable end to end, which is the standard Issuant is built to support and the direction the SEC has now made unmistakable.

Why Tokenization Is Outpacing US Regulators

Carter Bray — Fri, 25 Sep 2026 20:10:50 GMT

In brief: Asset tokenization is expanding faster than United States rulemaking can keep pace. The market for programmable, real-world assets grew from roughly $6 billion in early 2025 to more than $30 billion by April 2026, according to analytics provider RWA.xyz, yet the federal framework remains a patchwork of stablecoin law, agency guidance, and temporary exemptions rather than a single statute. Institutions that treat this gap as a reason to wait risk ceding ground to peers already issuing against clear rules abroad.

Tokenization is the practice of recording ownership of a financial asset, a Treasury bill, a money market fund share, a bond, as a programmable digital record that settles and transfers on shared infrastructure. The technology has moved well past pilot stage. The pace of adoption now runs ahead of the pace of federal legislation, and that mismatch is the defining feature of the current market.

The scale is no longer trivial. Tokenized US Treasuries and money market products dominate current volumes because liquid, low-volatility instruments tokenize most cleanly, as Investax noted in its 2026 outlook. BlackRock's tokenized money market vehicle, the USD Institutional Digital Liquidity Fund issued through transfer agent Securitize, crossed $1 billion in assets within a year of launch and has since grown into the billions. When the largest asset manager in the world builds a franchise on programmable fund shares, the question for other institutions is no longer whether to engage but under which rules.

What has Washington actually delivered?

More than critics allow, but less than a full framework. The single most concrete piece of legislation is the GENIUS Act, signed into law in July 2025, which established the first federal regime for payment stablecoins. Guidance from Mayer Brown describes it as the first comprehensive federal stablecoin statute, and implementing rules followed, including an OCC proposed rule and an FDIC rulemaking in 2026. Stablecoins, the settlement layer for much of this activity, now have statutory footing.

Securities are a different story, and here the guidance arrives without new law. In early 2026 the SEC and CFTC issued a joint interpretation on crypto asset classification, and SEC staff separately made clear that, as Morgan Lewis put it, a tokenized security is still a security. Under Chairman Paul Atkins the agency launched an initiative it calls Project Crypto, and in September 2026 it approved an Innovation Exemption permitting limited trading of tokenized National Market System stocks on qualified on-chain venues. The CFTC, for its part, launched a tokenized collateral initiative in late 2025.

The common thread is that almost none of this is durable statute. Exemptions can be withdrawn, joint interpretations can be revised, and a temporary framework is by definition temporary. That is the substance behind the observation, made in a September 2026 CoinDesk opinion piece, that tokenization is moving faster than Washington: the market is building on scaffolding that Congress has not yet turned into a building.

How do the major frameworks compare?

The cleanest way to see the gap is to line up what governs each layer of a tokenized issuance today, its legal status, and how settled it is.

Layer	Governing instrument	Type	Durability
Payment stablecoins	GENIUS Act (2025) plus OCC and FDIC rules	Federal statute with rulemaking	Settled
Tokenized securities classification	SEC and CFTC joint interpretation (2026)	Agency guidance	Interpretive, revisable
Tokenized equity trading	SEC Innovation Exemption (Sept 2026)	Temporary conditional exemption	Time-limited
Tokenized collateral in derivatives	CFTC initiative and staff guidance (2025 to 2026)	Agency guidance and pilot	Developing
Comprehensive market structure	CLARITY Act and related bills	Pending legislation	Unresolved

What the table makes plain is that only the stablecoin row rests on firm statutory ground. Everything above the settlement layer, the actual issuance and trading of programmable securities, currently depends on interpretation, exemption, or pilot. For an issuer, that distinction matters more than any headline growth figure, because it determines whether a structure built today survives a change of Commission or a court challenge tomorrow.

The contrast with other jurisdictions sharpens the point. The European Union has a common framework operating across 27 member states, while the United States, as the CoinDesk piece observed, has yet to reconcile competing bills between two houses of Congress. Capital and issuance activity are mobile. A framework that is comprehensive, even if imperfect, can attract business away from one that is faster on the technology but slower on the law.

Where do the real gaps sit for an issuer?

The gaps are not where casual observers assume. The technology works, and settlement and custody solutions exist. The unresolved questions are legal and operational, and three stand out.

The first is market structure. There is no single statute defining when a programmable instrument is a security, a commodity, or something else, and how it moves between venues. The pending CLARITY Act would address this, but as of its progress through Congress it remained unresolved. Until then, classification rests on interpretation that a future Commission could revisit.

The second is the durability of the exemptive relief now enabling much of the equity activity. The Innovation Exemption is real and useful, but conditional. Firms building distribution on it should assume conditions may tighten and should structure accordingly.

The third is the persistent distance between adoption in liquid instruments and everything else. Tokenized equity trading volumes still sit below 1 percent of conventional market activity, per market data reported by Parameter, even as tokenized Treasuries and commodities scale rapidly. The composable, auditable rails are proven; the depth of use beyond cash-like assets is not yet there.

What should an institution do with this?

Treat the regulatory gap as a design constraint, not a reason to sit out. The prudent path is to build where the law is settled, stablecoin-based settlement and tokenized cash-equivalent instruments, while structuring securities issuance so it survives the shift from exemption to statute. That means insisting on the same investor rights a traditional share carries, auditable smart contracts on public infrastructure, and governance that can absorb a change in agency posture without unwinding the instrument. Programmable and composable assets reward issuers who make auditability a first principle rather than an afterthought, which is precisely the discipline Issuant is built to support. The institutions that win the next phase will be those that moved deliberately while the rules were still forming, not those that waited for a certainty Washington has not yet supplied.

What Are Tokenised Deposits? UK Bank First

Carter Bray — Thu, 24 Sep 2026 16:06:34 GMT

In brief: On 24 September 2026, seven of the UK's largest banks completed the world's first interbank customer transactions using tokenised sterling deposits, moving money between institutions on a shared platform. A tokenised deposit is a claim on commercial bank money recorded on programmable infrastructure, spendable at par and carrying deposit protection. The live transactions covered remortgaging and digital asset settlement, and mark the point where the UK's tokenised-deposit work crossed from experiment into production.

A tokenised deposit is a claim on commercial bank money, held at a regulated bank, that is recorded and moved on programmable ledger infrastructure while remaining spendable at par and eligible for deposit protection. On 24 September 2026, that definition stopped being theoretical. According to CoinDesk, the UK's largest banks executed the world's first customer transactions using tokenised sterling deposits that moved between separate institutions on a shared platform. The distinction that matters for institutions is the word interbank: earlier trials kept the money inside one bank, while this run proved that programmable commercial bank money can settle across firms.

The transactions were delivered through the Great British Tokenised Deposit (GBTD) initiative, convened by UK Finance. Barclays, HSBC UK, Lloyds Banking Group, Monzo, Nationwide, NatWest, and Santander took part. The platform was built by Quant, project management came from EY, and the legal framework and rulebooks were drafted by Linklaters. Two remortgage transactions were carried out by Lloyds Banking Group, NatWest, and Barclays, with funds locked during the property process and released automatically on completion, and the pilots explored connecting to HM Land Registry to speed future conveyancing.

How is a tokenised deposit different from a stablecoin?

Both instruments promise digital pounds that move on programmable rails, but they sit on different balance sheets and answer to different rulebooks. That difference determines whether a treasury team can hold the instrument as ordinary cash or must treat it as a separate exposure. The comparison below sets out the distinctions that shape how each is used in wholesale and retail settings.

Feature	Tokenised deposit	Stablecoin
Issuer	A regulated commercial bank	A payment or crypto firm, sometimes a bank subsidiary
What it represents	A claim on your existing bank deposit	A separate liability backed by a reserve of assets
Deposit protection	Covered by the Financial Services Compensation Scheme, up to the standard limit	Not a protected deposit, holder relies on the quality of the reserve
Redemption	At par, as normal money in an account	At par in principle, subject to the issuer's reserve and terms
UK regulatory home	Existing bank prudential regime	The joint Bank of England and FCA framework for systemic issuers, set out in the July 2026 consultation
Effect on bank funding	Money stays as a deposit on the bank's balance sheet	Money can leave the banking system for the reserve

The last row explains why the Bank of England has leaned toward the deposit model. Governor Andrew Bailey has repeatedly voiced caution about banks issuing their own stablecoins, warning in comments reported by CoinDesk in July 2025 that stablecoins could pull funding out of the banking system and weaken credit creation. A tokenised deposit keeps the money where it already is, which is precisely why the GBTD design appeals to a central bank protective of monetary and financial stability.

Why does the interbank milestone matter?

The leap from single-bank pilots to cross-institution settlement is the whole point. A programmable pound that only works inside one bank is a closed loop. A programmable pound that can move between Barclays, NatWest, and Lloyds while preserving the singleness of money, the principle that a pound is a pound wherever it is held, is the foundation of a national payment system.

The path here was deliberate. UK Finance ran the Regulated Liability Network experimentation phase in 2024, when eleven institutions including Barclays, Citi UK, HSBC UK, Lloyds, Mastercard, NatWest, Nationwide, Santander UK, Standard Chartered, Virgin Money, and Visa tested tokenised deposits across five use cases and concluded, per Ledger Insights, that the network was a viable innovation platform. The live GBTD pilot followed in September 2025, targeting three use cases: marketplace person-to-person payments, remortgaging, and digital asset settlement, with the programme scheduled to run until mid-2026. Monzo joined as the seventh participant in January 2026. The September 2026 transactions are the payoff from that sequence.

For issuers, the digital asset settlement use case is the one to watch. A tokenised deposit that settles atomically against a programmable security removes the settlement lag and counterparty risk that sit between trade and finality today. That is the mechanism by which delivery-versus-payment becomes instant rather than aspirational, and it is why the same infrastructure that clears a remortgage is relevant to anyone issuing or raising capital against programmable instruments.

Where do UK regulators stand?

The supervisory backdrop has moved in step with the industry. In May 2026 the FCA and the Bank of England set out a shared vision for tokenisation in UK wholesale markets, signalling that programmable settlement infrastructure has official backing rather than mere tolerance. The Digital Securities Sandbox continues to admit new participants, giving firms a supervised venue to run tokenised securities and settlement together.

The deposit route also has a legal skeleton, not just working code. Linklaters drafted the GBTD rulebooks, which matters because programmable money without an enforceable framework governing who owes what to whom is an operational novelty rather than a settlement asset. That rulebook work, combined with the ISO 20022 messaging standard underpinning the Quant-built platform, is what lets the output plug into existing payment infrastructure rather than sit alongside it.

What should an institution do now?

Treat this as a signal to prepare, not to wait. Map where your own settlement, treasury, and issuance workflows carry lag, counterparty exposure, or reconciliation cost, because those are the points a tokenised deposit is built to compress. Read the GBTD use cases as a preview of what your counterparties will soon expect, and read the FCA and Bank of England wholesale tokenisation vision as the direction of the rulebook you will operate under. The banks have proven that programmable commercial bank money can move between institutions and settle against digital assets. The open question for issuers and asset managers is whether their instruments are composable and auditable enough to meet that money when it arrives, which is exactly the readiness Issuant is built to support.

Why Does the ECB Want to Change MiCA's Stablecoin Deposit Rule?

Carter Bray — Tue, 22 Sep 2026 17:44:00 GMT

In brief: The European Central Bank and the national central banks that form the European System of Central Banks want Brussels to replace MiCA's minimum bank-deposit requirement for stablecoin reserves with liquidity thresholds. In its response to the European Commission's targeted review of MiCA, published on 22 September 2026, the ESCB argues that forcing issuers to park large shares of their reserves in bank deposits concentrates risk in the banking system rather than removing it, and that a redemption rush could drain those deposits at the worst possible moment.

The supervisors that write the rules for the euro now want to rewrite one of them. According to Cointelegraph, the ECB and EU central banks are asking the European Commission to scrap the fixed bank-deposit floors that MiCA imposes on stablecoin reserves and put liquidity requirements in their place. The concern is not that issuers hold too little at banks. It is that they may hold too much, and that a sudden wave of redemptions could pull those deposits out of lenders precisely when funding is scarce.

What does MiCA currently require issuers to hold at banks?

MiCA, formally Regulation (EU) 2023/1114, came into force on 31 May 2023, with its stablecoin provisions applying from 30 June 2024. The regulation splits payment-style stablecoins into two categories: e-money tokens, which reference a single official currency such as the euro or the dollar, and asset-referenced tokens, which track a basket or other values.

The deposit rules sit inside the reserve regime. Under Article 54, funds received in exchange for e-money tokens must be safeguarded, and at least 30 percent of those funds must always be deposited in separate accounts at credit institutions, as Crypto Times sets out in its reading of the text. For tokens the European Banking Authority classifies as significant, the floor is higher still: the additional rules drawn from the asset-referenced chapter can require a deposit floor no lower than 60 percent of the amount referenced in each official currency. The EBA's technical standards layer concentration limits on top, capping any single credit institution at 25 percent of the cash reserve for ordinary tokens and 10 percent for significant ones.

Put plainly, the design assumes that the safest home for a large slice of stablecoin reserves is a bank. The central banks now dispute that assumption.

Why do the ECB and EU central banks want the rule changed?

The central banks want mandatory deposit thresholds replaced with liquidity requirements because the current design pushes stablecoin risk into the banking system rather than away from it. Their argument, filed in the ESCB response to the Commission's MiCA review, runs on two fronts.

The first is concentration. Requiring issuers to place a fixed, large portion of reserves in bank deposits makes lenders reliant on a funding source that behaves nothing like ordinary retail money. Stablecoin reserves can move fast, in size, and in one direction. The second is the run problem. If holders lose confidence and redeem at once, the issuer has to pull its deposits to meet them, withdrawing wholesale funding from banks exactly when the system is under stress. In the ESCB's framing, a rule meant to protect stability could instead transmit it.

The proposal fits a longer line of ECB commentary. In its Financial Stability Review coverage, the bank warned that significant growth in stablecoins could cause retail deposit outflows, diminishing an important source of bank funding and leaving lenders with more volatile balance sheets. The primary vulnerability, the ECB has said repeatedly, is that investors lose confidence they can redeem at par. ECB board member Piero Cipollone has made the deposit-erosion point directly, arguing that stablecoin adoption weakens the banking deposit base, per Cointelegraph's reporting of his remarks.

How large is the risk the ECB is worried about?

In the euro area, the exposure is still modest, but the trajectory is what alarms supervisors. Global stablecoin capitalisation has roughly doubled since 2023 to around 300 billion dollars, with dollar-denominated instruments accounting for close to 99 percent of the market, according to Ledger Insights. Euro-denominated issuance sits near 395 million euros against that backdrop, a rounding error by comparison.

Scale matters because the largest issuers are no longer peripheral. The ECB has noted that major stablecoin issuers now hold reserve portfolios comparable to the world's biggest money market funds and rank among the top recent buyers of US Treasury bills. A disorderly redemption at that size would not stay contained to crypto markets; it would ripple into short-term funding and sovereign debt. The European Systemic Risk Board reinforced the point in its October 2025 recommendation, flagging systemic risk from stablecoins and, in particular, from multi-issuance schemes where the same token is issued by both EU and non-EU entities.

How would liquidity thresholds differ from deposit floors?

Feature	Current MiCA deposit rule	Proposed liquidity approach
Anchor	Fixed percentage of reserves held as bank deposits (30 percent, or 60 percent for significant tokens)	Liquidity thresholds calibrated to redemption behaviour
Primary aim	Ensure safeguarded, segregated backing at credit institutions	Ensure issuers can meet redemptions without draining bank funding
Side effect flagged by ESCB	Concentrates issuer risk in the banking system	Reduces the channel through which a run hits banks
Flexibility	Rigid floor regardless of reserve mix	Tied to how quickly reserves can be converted under stress

The distinction is between a static rule and a dynamic one. A deposit floor asks where reserves sit. A liquidity threshold asks how fast they can be turned into cash to honour redemptions, and whether meeting that demand forces destabilising withdrawals from lenders. The central banks argue the second question is the one that actually maps to the risk.

What happens next in the MiCA review?

The request lands inside a live process. The European Commission opened a targeted consultation on the MiCA review earlier in 2026, with the response window extended to 30 September 2026, as Norton Rose Fulbright has documented. The ESCB submission is one input among many, and any change to Article 54 or the significant-token regime would require legislative amendment rather than a supervisory notice. Nothing shifts overnight.

What institutions can take from this is a signal about direction. Reserve composition, redemption mechanics, and the interplay between issuer liquidity and bank funding are moving to the centre of the European debate, and the fixed-percentage deposit rule that has anchored compliance since June 2024 is no longer treated as settled. For issuers building programmable, redeemable instruments against real reserves, the premium is increasingly on demonstrable liquidity and transparent, auditable backing rather than on a single deposit ratio, which is precisely the ground Issuant is built to serve.

ECB to Buy Tokenized Bonds With Its Own Funds

Carter Bray — Mon, 21 Sep 2026 16:05:33 GMT

In brief: On 21 September 2026 the European Central Bank said it will invest a small portion of its own funds in tokenized securities, with settlement in central bank money through its newly launched Pontes platform. The initial focus is euro-denominated euro area public sector and European supranational debt. The move makes the ECB an investor in the same programmable instruments it wants private markets to adopt, not merely a plumber providing the settlement rails.

The European Central Bank has decided to put its own balance sheet behind the technology it has spent two years testing. In a press release dated 21 September 2026, the ECB confirmed it has begun preparatory work to invest a small portion of its own funds in tokenized securities, with those transactions settling in central bank money on Pontes. The first purchases will concentrate on euro-denominated euro area public sector and European supranational securities, the safest and most liquid corner of the market. It is a modest allocation in size and a large statement in intent.

Tokenized securities, in the ECB's usage, are conventional debt instruments issued and recorded on distributed-ledger infrastructure so they can be transferred, settled, and serviced programmatically. The significance of the announcement is that the central bank will hold them as an investor. The stated purpose is practical: to build institutional expertise and gain firsthand experience of what it is like to buy, settle, and hold a programmable bond rather than simply to run the pipes underneath it.

What is Pontes and why does it matter?

Pontes is the settlement bridge that makes the investment possible. Launched the same day, it is described by the ECB as the first initiative under a broader Eurosystem programme to make central bank money fit for a digital future, and it went live at 9:15 a.m. Central European Time on Monday, 21 September, according to reporting from CoinLaw. The platform connects distributed-ledger platforms to the Eurosystem's existing TARGET Services, so that the cash leg of a wholesale trade in tokenized assets settles in central bank money rather than in a stablecoin or a commercial-bank deposit. CoinDesk framed it plainly: Pontes offers an alternative to private settlement assets for wholesale transactions.

That distinction carries real weight for institutions. Settlement in central bank money is the safest form of settlement available, because it carries no issuer credit risk. By routing programmable securities through TARGET rather than through a private stablecoin, the ECB is trying to preserve that safety while letting the instruments themselves become composable and auditable. Pontes currently operates on a limited window, roughly 8 a.m. to 4 p.m. Central European Time, with the ECB signalling a move toward continuous operation by 2028.

How did the ECB get here?

The launch did not appear from nowhere. Between May and November 2024 the Eurosystem ran an extensive round of exploratory work, testing the settlement of distributed-ledger transactions in central bank money across three interoperability solutions. That programme drew 64 participants across central banks, market firms, and platform operators, and ran more than 50 trials and experiments. The Eurosystem processed over 200 transactions worth a combined 1.59 billion euros during the exercise, according to the ECB's December 2024 summary.

The three tested approaches came from national central banks: the Deutsche Bundesbank's Trigger Solution, which links ledger platforms to TARGET2 through a trigger chain and a transaction coordinator; the TIPS Hash-Link from Banca d'Italia; and a Full DLT Interoperability solution from the Banque de France. The Bundesbank's own Trigger Solution documentation describes the aim as settling ledger-based wholesale transactions directly on participants' existing accounts in central bank money, without minting a new digital currency.

In July 2025 the Governing Council settled on a two-track path, and Pontes is the near-term track. The longer-horizon track is Appia, an integrated ledger-native settlement ambition set out in the Appia roadmap the Eurosystem published in March 2026. Where Pontes bridges new market platforms to legacy Eurosystem infrastructure, Appia looks toward a more fully integrated European ecosystem for programmable finance, tied explicitly to the bloc's ambitions for a savings and investments union and greater strategic autonomy.

Why is the ECB investing rather than just settling?

The own-funds decision is what separates this from earlier plumbing work. The ECB maintains a non-monetary policy portfolio, its own funds, which generates income to help cover operating expenses outside its supervisory tasks. By channelling part of that portfolio into tokenized public sector and supranational debt, the central bank becomes a live participant in the market it is trying to seed. Piero Cipollone, the executive board member who has led the Eurosystem's digital-money agenda, has repeatedly argued that tokenized central bank money is central to an efficient digital finance system, and as Ledger Insights reported ahead of the launch, he has coupled that push with calls for harmonized European securities law to remove the legal fragmentation that still slows issuance.

The investor role matters for a reason institutions will recognise. A settlement rail with no assets flowing across it proves little. By committing capital, even a small amount, the ECB creates demand, tests the full lifecycle from purchase through custody, and signals to issuers and asset managers that the infrastructure is more than a pilot. It also positions the euro's public money as a settlement anchor at a moment when dollar-referenced private settlement assets are expanding, part of the wider European effort to reduce dependence on foreign infrastructure that ran through the Appia work covered by CoinDesk.

What to watch next

The near-term questions are concrete. The first is scale: the ECB has described its allocation as small, and the pace at which it grows, or does not, will tell markets how much conviction sits behind the announcement. The second is participation. Reporting around the launch pointed to major banks preparing to transact through Pontes, and the breadth of issuers willing to bring euro area public and supranational debt onto ledger platforms will determine whether Pontes becomes a venue or stays a demonstration. The third is the operating window. A platform that runs only during business hours cannot yet support the continuous, atomic settlement that programmable finance promises, and the 2028 target for extended operation is the milestone to track.

The larger open question is legal rather than technical. Cipollone's call for harmonized securities law points to the gap that remains: the rails and the central bank money are now in place, but the rulebook governing issuance across twenty jurisdictions is not uniform, and Appia's fuller vision depends on closing it. For institutions weighing whether to issue or hold programmable, auditable instruments in euros, the ECB has just removed one of the oldest objections, that public money would never touch the new infrastructure. What remains is to see whether the law, the liquidity, and the operating hours catch up to the ambition. For issuers building on programmable and composable assets, that is the ground worth watching, and the ground Issuant is built to serve.

What Does the SEC 24-Hour Trading Roundtable Mean?

Carter Bray — Thu, 17 Sep 2026 18:20:01 GMT

In brief: The U.S. Securities and Exchange Commission convened a public roundtable on September 17, 2026, to plan for around-the-clock equity trading, the schedule that foreign exchange, gold, and crypto markets already run. Chair Paul Atkins told participants that clearing, market data, and price-protection plumbing are being rebuilt to support overnight sessions, and that DTCC has already gone live with a 23-hours-a-day, five-days-a-week clearing model. The direction of travel is a near-continuous U.S. equity market, and the open question is how far it goes before the last gaps in oversight and liquidity are closed.

The SEC has begun formally preparing for a market that never closes. On September 17, 2026, the regulator hosted a roundtable on preparations for 24-hour trading, a day-long session that gathered exchanges, clearing houses, asset managers, and trading firms to work through what it takes to run U.S. equities overnight. The framing was deliberate. Continuous trading is already the norm in foreign exchange, gold, and digital-asset markets, and the Commission is now studying how to align listed equities with what it calls an always-on global economy.

Twenty-four-hour equity trading means investors can buy and sell exchange-listed shares and funds at almost any hour of the day, five days a week, rather than only during the traditional 9:30 a.m. to 4:00 p.m. Eastern session. That is the destination the industry is building toward, and the roundtable was the point at which the SEC put its own name on the process rather than leaving it to individual exchange filings.

Why is the SEC holding a roundtable now?

The timing follows a run of concrete steps, not a sudden shift. In February 2025 the SEC granted accelerated approval to NYSE Arca to lengthen its trading sessions, clearing the path to roughly 22 hours a day for listed equities and funds. Later that year, 24X National Exchange opened as the first SEC-approved 23/5 stock exchange, beginning its first stage of operation in October 2025. Nasdaq then filed to extend its own U.S. equities trading to 23 hours a day, five days a week, a proposal the SEC approved in April 2026, with the exchange later setting a December launch for the near-continuous schedule.

Those approvals created a policy problem the SEC could no longer route around. Once multiple venues are matching trades at 3:00 a.m., the supporting infrastructure, the clearing, the consolidated market data, and the safeguards against runaway prices, has to keep pace. The roundtable was the Commission's attempt to coordinate that build-out in public rather than approve it piece by piece.

Chair Paul Atkins had already signaled the direction a year earlier. In a September 2025 joint statement with the acting head of the CFTC, Atkins wrote that the two regulators should "collaborate to consider the possibility of further expanding trading hours, where appropriate," citing operational feasibility and liquidity alongside investor protection. The statement named foreign exchange, gold, and digital assets as markets that already trade continuously, and argued that longer hours could better align U.S. markets with a global economy.

What did SEC officials say about the plumbing?

The most substantive material came from the officials describing the infrastructure. In his remarks at the roundtable, Atkins said the settlement layer is already moving. The Depository Trust and Clearing Corporation, he noted, has gone live with 23-by-5 trade-capture systems to support clearance and settlement, a claim confirmed by DTCC's own announcement that its National Securities Clearing Corporation extended clearing hours to a 24x5 model in June 2026. That matters because a trade executed overnight is not truly complete until it can be cleared and settled through the same pipes that handle daytime volume.

Atkins also pointed to two other pieces. The industry has adopted a plan to establish overnight price bands, requiring every trading center active during overnight hours to maintain written policies and procedures that prevent trades outside those bands, a guardrail against the thin-liquidity air pockets that can send an overnight quote wildly off fair value. And work is ongoing to prepare the Securities Information Processor plans, the systems that publish a consolidated national price, for overnight dissemination. Without a reliable overnight tape, an investor trading at 2:00 a.m. cannot see where the whole market is, only where one venue is.

Commissioner Hester Peirce struck a measured tone in her own remarks, observing that the equity market is "not breaking new ground" and can learn from markets that already run through the night. She noted that certain index options trade overnight and that futures markets generally follow a 23/5 schedule close to where equities are headed. The message was that the model is proven elsewhere, and the task now is disciplined translation rather than invention.

Who was in the room?

The panelist list read as a cross-section of the market's core operators, which is itself a signal of how seriously the industry is taking the shift. According to the SEC's agenda and panelist announcement, the sessions drew NYSE, Nasdaq, Cboe, and MEMX among the exchanges, BlackRock, State Street, and Invesco on the asset-management side, and Citadel Securities, Virtu, and Jane Street among the market makers, alongside DTCC, FINRA, and retail-facing firms including Robinhood, Charles Schwab, and Interactive Brokers. Jamie Selway, director of the SEC's Division of Trading and Markets, joined Atkins in opening the day.

That breadth reflects the reach of the change. Extended hours touch execution venues, the firms that price risk into overnight quotes, the custodians and clearers that settle the trades, and the platforms where retail orders originate. Getting the schedule right requires all of them to move together.

What does this mean for institutions?

For asset managers and issuers, the practical stakes are less about the headline hours and more about the machinery underneath. A near-continuous market changes how net asset values are struck, how corporate actions and news are absorbed, and how operational teams staff a trading day that no longer has a clean close. Firms preparing for 24x5 equities in 2026 have flagged the loss of the overnight maintenance window as a genuine technology and controls problem, since systems that once relied on a quiet period now have to run and be supported around the clock.

The move also sharpens a longer argument about programmable and composable market infrastructure. The appeal of a market that settles and reprices continuously is that assets become easier to move, finance, and audit across time zones without waiting for a bell. The risk, which the roundtable exists to manage, is that liquidity and oversight thin out precisely when a retail investor is least equipped to notice. That tension is why investor-protection advocates have pressed the SEC to pair any expansion with strong disclosure and safeguards, and why the price-band and market-data work Atkins described is not a footnote but the substance.

What to watch next

The near-term markers are concrete. Nasdaq's move to a near-23-hour schedule is the next major venue to go live, and how its overnight sessions trade, whether spreads hold and volumes materialize, will shape how quickly other exchanges follow. The SIP overnight tape and the industry-wide price bands are the load-bearing pieces to track, because a continuous market without a consolidated overnight price and without protection against off-band trades is a market with visible gaps. And the SEC's own posture matters: the roundtable produced a supporting-data memorandum and a public comment file, and the Commission's read of that record will influence whether it lets the venue-by-venue expansion continue or moves toward a more unified framework.

The open question is where the line finally settles. Nearly every proposal on the table stops just short of a true 24/7 market, leaving a short daily pause for maintenance and reconciliation. Whether U.S. equities close that last gap, and on what terms, is the decision the September roundtable set in motion rather than resolved. For institutions building toward programmable, composable, and auditable assets, the direction is now clear enough to plan around, and Issuant is watching the same infrastructure signals that will determine how far the always-on market extends.

What does the CLARITY Act Senate vote mean for issuers?

Carter Bray — Tue, 15 Sep 2026 16:51:52 GMT

In brief: The Digital Asset Market Clarity Act (CLARITY) faces a Senate cloture vote scheduled for September 15, 2026, and its fate turned on eleventh-hour Democratic demands that Republicans and industry allies characterized as moving the goalposts. The bill would split federal oversight of digital assets between the Commodity Futures Trading Commission and the Securities and Exchange Commission, but it needs 60 votes to advance, and the late wrangling over ethics language and consumer protections leaves institutional issuers facing continued uncertainty about the rulebook they will operate under.

The most consequential piece of U.S. digital-asset legislation in a generation reached a procedural cliff this week, and the negotiating dynamics around it tell institutions more about the timeline than any single vote will. The Digital Asset Market Clarity Act would create the first comprehensive federal framework for classifying, issuing, and trading digital assets, dividing supervision between the Commodity Futures Trading Commission and the Securities and Exchange Commission. Hours before a key Senate cloture vote set for September 15, Senate Democrats pressed a fresh set of demands, a move Republican staff and industry groups described as shifting the terms of a deal they thought was largely settled.

What is the CLARITY Act, and what would it actually do?

The CLARITY Act is a federal bill that establishes a comprehensive regulatory framework for the classification, offering, trading, and supervision of digital assets. That single sentence is the substance institutions need, and the mechanics follow from it. The bill replaces the current patchwork, in which the boundary between a security and a commodity has been litigated case by case, with a defined structure: a three-category classification system, a test for whether a network is sufficiently decentralized, and registration requirements for exchanges and intermediaries, as BIT's explainer lays out.

Under that structure, assets whose value is intrinsically linked to the use of a blockchain fall to the CFTC as digital commodities, a category that the Congressional Research Service notes would exclude securities, derivatives, and stablecoins. Tokens sold through fundraising rounds, where a centralized team raises capital against a promise to build, remain investment contracts under SEC jurisdiction. Payment stablecoins sit with banking regulators, complementing the separate GENIUS Act regime. For an issuer, the practical value is a graduation pathway: a project that begins as an SEC-supervised investment contract can migrate to commodity treatment once the underlying network reaches what the bill calls blockchain maturity, a threshold that Arnold & Porter's analysis describes as removing security status once an asset trades in genuine secondary markets rather than being distributed by the issuer.

How did the bill get to a Senate floor vote?

The path has been long and unusually bipartisan by the standards of the sector. The House passed H.R. 3633 by a vote of 294 to 134 on July 17, 2025, with more than 70 Democrats crossing over, making it the most bipartisan digital-asset measure to clear a chamber to that point, according to a legislative timeline maintained by eco.com. The Senate then took its own route. Chairman Tim Scott and Digital Assets Subcommittee Chair Cynthia Lummis circulated discussion drafts through the second half of 2025, and after roughly a year of delays the Senate Banking Committee advanced the bill on May 14, 2026, by 15 to 9, with two Democrats joining all Republicans, per the Latham & Watkins U.S. Crypto Policy Tracker.

That committee vote came with a caveat that matters now. The Democrats who supported it signaled that their committee votes did not guarantee floor support without further movement on outstanding issues, chiefly an ethics provision addressing government officials' ties to the digital-asset industry. In August the Senate opened the first procedural stage of floor consideration, setting up the September test. The bill needs 60 votes to clear cloture, which means Republican leadership must find a handful of Democrats, and that arithmetic is precisely what gave the minority its leverage this week.

What did Democrats change at the last minute?

The flashpoint was ethics language and, secondarily, consumer-protection provisions. In the run-up to the vote, the White House agreed to stricter rules restricting government officials' financial ties to digital-asset ventures, a concession The Washington Post reported was intended to win Democratic support. Republicans then released what they called a final draft incorporating most of those provisions, as The Block described.

E what happened next is the story in the headline. With the concessions apparently banked, Democrats pressed additional demands hours before the vote, and Senator Elizabeth Warren prepared to argue against the bill on the Senate floor ahead of the preliminary tally. To supporters, agreeing to the ethics package and then raising the bar again looked like negotiating in bad faith. To the bill's critics, the additional asks reflected legitimate gaps in a framework that will govern trillions in eventual activity. Either reading leaves the same operational fact for institutions: the text was still moving the day before the vote, and prediction markets tracked by Forbes put passage odds well short of a coin flip even after the ethics deal.

Why does the outcome matter for issuers and asset managers?

Because almost every downstream decision an institution makes depends on which regulator holds the pen. The classification of an instrument determines its disclosure regime, its custody requirements, the venues on which it can trade, and the capital treatment it receives. Without the CLARITY Act, that classification remains a matter of enforcement posture and litigation rather than statute, which is a poor foundation for a product roadmap or a capital raise. The bill's appeal to established finance is that it makes programmable, composable instruments auditable against a defined federal standard rather than an inferred one.

The stakes are concrete. A missed cloture vote does not kill the bill outright, but it compresses an already tight calendar, and several trackers have warned that a failure here pushes meaningful action well into the future, with crypto.news noting the risk that the window closes for this Congress. For issuers weighing whether to structure a new instrument under a coming statutory regime or under today's uncertain caselaw, the difference between passage this autumn and a multi-year delay is the difference between planning and guessing.

What should institutions watch from here?

Three things. First, the cloture count itself: 60 votes advances the bill, anything less sends negotiators back to the table and resets the timeline. Second, the final ethics and consumer-protection text, because the provisions that secured Democratic votes will shape how supervisors and issuers read the rest of the framework. Third, the graduation mechanism, since the maturity threshold that moves an asset from SEC to CFTC oversight is where most issuer economics will ultimately be decided, and late amendments to definitions can quietly reshape it.

For now, the prudent posture is to build for the framework's logic without betting the calendar on any single vote. Institutions that design instruments to be classifiable, auditable, and portable across the SEC and CFTC boundaries will be ready whichever way the count falls, and that readiness, rather than a headline, is what turns a contested Senate vote into a manageable planning input.

Anchorage Digital adds fUSD access for institutions

Yonier Bellido — Fri, 11 Sep 2026 17:38:06 GMT

In brief: On September 11, 2026, Anchorage Digital opened institutional access to Frgmnt's fUSD and its staked variant sfUSD, letting clients hold, mint, redeem, stake and unstake the yield-bearing dollar instrument from within a federally regulated custody platform. Frgmnt is a stablecoin protocol built on Base that issues fUSD one-for-one against USDC and routes the backing into audited dollar-lending strategies. The arrangement removes the need for a separate wallet or protocol relationship, folding a programmable yield instrument into workflows a regulated institution already recognizes.

Anchorage Digital has begun offering institutional clients direct access to Frgmnt's fUSD, a yield-bearing dollar instrument, through its custody platform. The integration, announced on September 11, 2026, covers both fUSD and its staked counterpart sfUSD, and it lets clients hold, mint, redeem, stake and unstake the asset without standing up a separate custody arrangement. That single sentence carries the weight of the deal: a federally chartered bank has wrapped a programmable yield product in the operational controls an asset manager or treasury desk is already permitted to use.

What exactly did Anchorage Digital agree to support?

The support is practical rather than promotional. Rather than requiring institutions to manage wallets, key material and interactions with several separate protocols, Frgmnt packages access to dollar-lending markets inside a stablecoin structure that can plug into existing institutional workflows, according to a report published the same day. Custody, minting, redemption and staking all sit behind one regulated counterparty.

That matters because the friction in composable dollar instruments has rarely been the yield. It has been the plumbing. A treasury team that wants exposure to a programmable dollar has historically had to accept direct wallet management, bespoke legal review of an unfamiliar protocol, and a custody question with no clean answer. Anchorage Digital's proposition is to collapse those steps into an account relationship that already clears internal risk committees.

What is Frgmnt, and how is fUSD constructed?

Frgmnt is a stablecoin protocol built on Base, Coinbase's Ethereum layer-2 network, that issues fUSD against USDC and deploys the backing across audited dollar-lending strategies. Put plainly, fUSD is a dollar-denominated instrument minted one-for-one against USDC whose reserves are put to work rather than left idle. The protocol describes fUSD as pegged to the US dollar and backed by a diversified reserve of audited stablecoins, an approach it says reduces dependence on any single asset while preserving liquidity. On DeFiLlama's protocol page, Frgmnt is characterized as a multi-collateralized stablecoin on Base, with fUSD minted one-for-one against USDC and reserves routed into dollar-yield strategies.

The motivating premise is a familiar inefficiency. Frgmnt's own materials note that more than 60% of stablecoins sit idle in wallets, generating nothing for their holders while centralized issuers capture the return on the underlying reserves. That gap is not trivial. Traditional stablecoins pay holders nothing even as short-term dollar rates hover near 4 to 5%, a spread that left holders forgoing an estimated $9 billion in annual yield, by one 2025 estimate. Tether alone earned more than $13 billion across 2024 and 2025, largely on the spread between its reserves and what it pays out, which is to say nothing. fUSD's design is a wager that institutions will increasingly decline to leave that money on the table.

Why does the custodian carry as much weight as the instrument?

The distributor here is not incidental. Anchorage Digital is home to Anchorage Digital Bank, N.A., which on January 13, 2021 became the first digital-asset firm to receive a national trust bank charter from the Office of the Comptroller of the Currency. As a condition of that approval it entered an operating agreement covering capital, liquidity and risk-management expectations, and it has remained the only crypto company holding a full federal banking charter. In August 2025 the OCC terminated a 2022 consent order tied to anti-money-laundering controls, a step the firm framed as moving from first-chartered to fully proven.

Founded in 2017 by security engineers Nathan McCauley and Diogo Monica, Anchorage Digital provides custody, trading, settlement and staking to institutions, and is backed by investors including Andreessen Horowitz, Goldman Sachs, KKR and Visa. Its recent activity has clustered around exactly this kind of role. In October 2025, U.S. Bank was selected to custody the reserves backing Anchorage Digital Bank's payment stablecoins, and in August 2025 the bank positioned itself as the first federally chartered stablecoin issuer under the newly enacted GENIUS Act. Adding fUSD extends a deliberate pattern: the bank is assembling itself as connective tissue between regulated balance sheets and programmable dollar instruments.

How does fUSD sit against the wider yield-bearing dollar market?

fUSD arrives in a segment that has stopped being a curiosity. Yield-bearing stablecoins grew from roughly $1 billion in supply in 2023 to more than $19 billion by September 2025, according to the Bank for International Settlements, with instruments such as Ethena's sUSDe, Sky's sUSDS and BlackRock's tokenized liquidity fund together accounting for over half the category.

The instruments are not interchangeable, and the distinctions are what an institution actually underwrites. A conventional payment stablecoin like USDC holds its backing in a government money-market fund and bank deposits and passes the holder no yield; a fund-based instrument such as BlackRock's BUIDL, which crossed roughly $2.5 billion in assets in late 2025, is a registered securities wrapper over short-dated Treasuries. fUSD sits in a third bucket: a minted dollar whose return comes from lending strategies rather than a passive Treasury portfolio. Higher potential yield, different risk. The question a diligence team will ask is not whether fUSD pays, but what it is lent against, how the reserve is audited, and what a redemption looks like under stress. Anchorage Digital's role answers the custody piece of that question. It does not answer the credit piece.

What should institutions watch from here?

The near-term signal to watch is uptake through the regulated channel: whether treasury desks and asset managers who were structurally blocked from composable dollar instruments actually mint at scale now that the custody and operational objections are gone. A second signal is regulatory. The GENIUS Act drew a sharp line on stablecoins that pay interest directly, and the boundary between a payment stablecoin and a yield-bearing instrument routed through a separate staking wrapper like sfUSD is precisely where supervisory attention is likely to land. How that line is drawn in practice will shape which structures survive.

The open question is durability. A programmable, composable dollar becomes genuinely institutional only when its yield source is as auditable as its custody, and when redemption holds in a drawdown rather than only in calm markets. Anchorage Digital has supplied the regulated wrapper. Whether fUSD earns a permanent line on an institutional balance sheet, or remains a tactical allocation, will be settled by the quality of what backs it. For issuers weighing how to bring programmable, auditable dollar instruments to institutions, that is the standard worth building toward, and the one Issuant keeps in view.

Why Are EU Groups Fighting the Tokenized Securities Cap?

Carter Bray — Thu, 10 Sep 2026 18:50:55 GMT

In brief: A coalition of European exchanges, banks, and market operators is pressing the EU to remove the volume cap on digital securities under the DLT Pilot Regime, or to raise it to at least 1.5 trillion euros. Roughly 40 firms, including Nasdaq and Boerse Stuttgart, argue that the current 6 billion euro ceiling is too small to justify institutional participation and risks pushing digital-securities activity toward the United States. The request lands as the European Commission negotiates a broad overhaul that would lift the cap to 100 billion euros.

The DLT Pilot Regime is the EU framework that lets exchanges and settlement systems trade and settle securities that qualify as financial instruments on distributed-ledger infrastructure. It began applying on 23 March 2023 under Regulation (EU) 2022/858, and it was designed as a temporary sandbox so that regulators and market operators could gain experience with programmable, ledger-based securities before writing permanent rules. Three years in, the industry's verdict is blunt: the sandbox is too small to be useful, and a group of about 40 firms has now asked Brussels to say so in law.

What are the DLT Pilot Regime caps, and why do they matter?

The binding constraint is a set of volume limits. Under the regime as it stands, digital securities admitted to a single venue cannot collectively exceed 6 billion euros in market value, and once that figure reaches 9 billion euros an exit threshold forces the operator to wind activity down. On top of the aggregate ceiling, each instrument must clear per-issuance thresholds: shares are eligible only where the issuer's market capitalisation is below 500 million euros, bonds only where the issue size is below 1 billion euros, and fund units only where assets under management sit below 500 million euros.

Those numbers were meant to contain risk while the experiment ran. In practice they excluded the instruments institutions most want to issue and settle on a ledger: large sovereign and corporate bonds, blue-chip equities, and money-market instruments at scale. As Ledger Insights put it, large incumbents chose to sit out the regime because the caps were prohibitively small for institutional usage. A framework that cannot accommodate a single benchmark government bond issue is not a framework a bank builds a business on.

Who is asking for the change, and what exactly do they want?

The signatories run to roughly 40 organisations and read like a cross-section of European market plumbing rather than a crypto lobby. They include Nasdaq, Boerse Stuttgart, and other exchanges and financial-market infrastructures, alongside trade bodies. Their ask is twofold and deliberately sequenced. The first-best outcome is to remove the volume cap entirely, on the logic that a permanent, credible market cannot operate under a ceiling that triggers forced wind-downs. Failing that, they want the starting threshold set at no less than 1.5 trillion euros, a figure they argue reflects the real size of the markets the technology is meant to serve.

The competitive argument sits underneath the numbers. Tokenization firms have warned that the pilot's constraints risk pushing markets to the US, where digital-securities activity faces a different regulatory posture. For issuers weighing where to build programmable, composable instruments, a jurisdiction with a hard 6 billion euro ceiling is a difficult sell against one without.

How does this fit the Commission's own reform plan?

The request is not arriving in a vacuum. In December 2025 the European Commission launched the Market Integration and Supervision Package, a broad set of financial-legislative proposals that includes a section on the DLT Pilot Regime. As Taylor Wessing summarised, the package would make the regime permanent and materially expand it, lifting the 6 billion euro cap to 100 billion euros and widening the range of eligible instruments beyond the current shares, bonds, and funds.

That is a large increase, and it moves in the industry's direction. But 100 billion euros still sits well below the 1.5 trillion euro fallback the coalition is requesting, which is the crux of the disagreement. The firms are effectively telling Brussels that its own proposed expansion, though welcome, does not go far enough to make Europe a serious venue for institutional digital securities. The proposals now enter trilogue negotiations between the Commission, the European Parliament, and the Council, a process Bird & Bird expects to run through 2026, with any adopted rules potentially applying after a transitional period of 12 to 24 months.

Threshold on digital-securities value	Source and status
6 billion euros aggregate (9 billion euro exit trigger)	Current law under Regulation 2022/858, in force
100 billion euros	European Commission proposal, MISP, December 2025
Remove cap, or at least 1.5 trillion euros	Industry request, roughly 40 firms, September 2026

What has the regulator itself said?

The supervisory view is closer to the industry's than the current statute suggests. In a June 2025 report on the functioning and review of the regime, the European Securities and Markets Authority recommended making the regime permanent and proposed more flexible thresholds, acknowledging that the design as written had produced limited uptake. National regulators have pushed in the same direction: the French and Italian authorities published a joint position paper in April 2025 arguing for a more competitive European pilot. When the regulator, two national supervisors, and 40 market participants all say the same thing, the caps look less like prudent risk management and more like a ceiling the market has outgrown.

For institutions, the substance underneath the lobbying is what matters. The DLT Pilot Regime is Europe's live attempt to give securities the properties that ledger-based infrastructure makes possible: programmable settlement, composable instruments, and auditable records that reconcile in near real time. The cap fight is really a question of whether that infrastructure can carry meaningful size. The direction of travel, from a 6 billion euro sandbox toward a 100 billion euro floor and an industry ask measured in trillions, tells issuers where this is heading, even if the final number is unsettled.

Frequently asked questions

What is the current cap on digital securities under the DLT Pilot Regime? Digital securities on a single venue cannot collectively exceed 6 billion euros in market value, with a 9 billion euro exit threshold that forces the operator to wind down. Per-instrument limits also apply, including a 500 million euro market-capitalisation ceiling for shares and a 1 billion euro issue-size ceiling for bonds, under Regulation (EU) 2022/858.

Has the EU agreed to remove or raise the cap? Not yet. The European Commission proposed raising the cap to 100 billion euros in its December 2025 Market Integration and Supervision Package, but that proposal is still in trilogue negotiations expected to run through 2026. The industry's request to scrap the cap or set it at 1.5 trillion euros goes further than the Commission has committed to.

Why does the cap matter for issuers evaluating digital securities in Europe? The thresholds exclude large bond and equity issues from the regime, which is why major institutions have largely stayed out. A higher or removed cap would let issuers place benchmark-sized instruments on programmable, auditable infrastructure inside a regulated EU framework rather than routing that activity to other jurisdictions. This is precisely the institutional gap Issuant is built to serve.

Tether, Fasanara Launch $400M Private Credit Fund

Yonier Bellido — Wed, 09 Sep 2026 18:00:46 GMT

In brief: On 9 September 2026, Tether and Fasanara Capital launched StableFund, an evergreen private credit vehicle anchored by $400 million of co-investment from both sponsors and targeting up to $3 billion in third-party institutional capital. The fund lends to small businesses and consumers through fintech platforms in more than 60 countries, and it uses Tether's USDT as settlement infrastructure so loans can move across borders faster than traditional banking rails allow. It is one of the clearest signs yet that programmable settlement is being wired into an established institutional asset class rather than a speculative one.

What is StableFund, in one sentence?

StableFund is a jointly sponsored, evergreen private credit fund that directs institutional capital into short-duration, asset-backed lending to real-economy borrowers, with loan disbursements and repayments settled on stablecoin rails instead of correspondent banking. The launch was announced by Tether on 9 September 2026. The two firms bring complementary roles. Fasanara Capital, a London-based specialist manager the FCA authorises and regulates, manages the fund's investments and originates the underlying loans, drawing on a book that already spans SME loans, consumer credit, trade receivables, and supply chain finance. Tether acts as originator and advisor, sourcing USDT-linked financing opportunities and, crucially, supplying the settlement plumbing: on-ramp and off-ramp connectivity plus treasury rails that let capital cross borders more efficiently than legacy systems.

The fund is aimed at a specific gap. Its stated purpose is to channel institutional money toward small and medium-sized businesses, a segment Tether estimates faces a $5.7 trillion global financing shortfall. That is the demand side. The supply side is a private credit market that has grown into one of the largest destinations for patient institutional capital.

Why does a $3 billion target matter to private credit?

Because the pool it draws from is now enormous, and still expanding. The Alternative Credit Council, the private credit affiliate of AIMA, put the global market at roughly $3.5 trillion in its 2025 review, while Morgan Stanley pegged it near $3 trillion at the start of 2025 and projects roughly $5 trillion by 2029. A $3 billion raise is a modest slice of that, which is the point: StableFund is not trying to reinvent private credit, it is trying to attach a faster settlement layer to a mature one.

What separates this vehicle from a conventional direct-lending fund is not the credit itself but how money moves through it. In a traditional structure, a cross-border disbursement to a borrower in an emerging market can wait on correspondent banks, cut-off times, and multiple currency legs. Here, a loan can be funded and repaid on USDT rails, compressing settlement from days to near-immediate and giving the manager tighter control over working capital. The credit exposure, the underwriting, the covenants, and the recovery process remain recognisably private credit. The rails are the variable that changes.

How does StableFund compare with the structures institutions already know?

The table below sets StableFund against a conventional direct-lending fund and a bank trade-finance facility on the dimensions that matter to an allocator: who bears the credit, how settlement clears, and how the exposure is governed.

Feature	StableFund (Tether / Fasanara)	Conventional direct-lending fund	Bank trade-finance facility
Structure	Evergreen, jointly sponsored	Typically closed-end, fixed term	On balance sheet
Anchor capital	$400M sponsor co-investment	LP commitments	Bank capital
Underlying assets	SME loans, consumer credit, trade receivables, supply chain finance	Middle-market corporate loans	Receivables, letters of credit
Settlement rail	USDT, on and off-ramp connectivity	Correspondent banking	SWIFT and correspondent banking
Cross-border speed	Near-immediate	Days	Days
Manager	FCA-regulated (Fasanara)	Registered fund manager	Regulated bank

The comparison surfaces a point the table cannot fully carry on its own: sponsor co-investment changes the alignment. In a standard direct-lending fund, the manager earns fees on committed capital and may hold little of the risk. Here, both Tether and Fasanara have put $400 million of their own money alongside third-party investors, which ties the sponsors' outcome to the fund's rather than merely to its size. That does not eliminate risk. Private credit's rapid growth has drawn scrutiny, and the IMF has flagged the asset class for opacity in valuations and interconnection with the wider financial system. Faster settlement does not change underwriting discipline, and a stablecoin rail is only as sound as the reserves and controls behind it.

On that last point, the counterparty is more legible than it once was. Tether reported a record $187.3 billion USDT market cap in the fourth quarter of 2025, and it completed its first full financial audit, signed by KPMG, on its 2025 statements. For an allocator weighing a settlement dependency, an audited, Treasury-heavy reserve base is a materially different proposition than an unaudited one.

Where this fits in Tether's wider strategy

StableFund is not an isolated experiment. Tether has been redeploying the profits from its reserve base into hard assets and infrastructure, from a $23 billion gold stockpile it is lending against to stakes in energy, mining, and AI. Private credit is the logical extension of that arc: it puts the settlement network to work inside an asset class institutions already understand and allocate to at scale. Fasanara, for its part, has been building toward programmable finance from the other direction, having earlier launched a money-market fund on public infrastructure and partnered with the IFC to expand receivables finance in emerging markets. The two sides meet at the same conclusion: composable, auditable rails belong inside real-economy lending, not adjacent to it.

What an institution should do with this

Treat StableFund less as a headline and more as a template worth evaluating. If your mandate already includes private credit, the questions to ask are familiar ones applied to a new settlement layer: how is the underlying loan book underwritten and valued, what recourse exists if a fintech originator fails, and how are the stablecoin rails governed, reserved, and audited. If you issue or raise capital yourself, the more useful takeaway is directional. A regulated manager and an audited stablecoin issuer have shown that programmable settlement can sit under an institutional credit strategy without diluting its discipline, which lowers the bar for the next issuer to do the same. That is the shift worth tracking, and the one Issuant is built to help institutions act on: the moment programmable, composable, auditable assets stop being a category apart and become simply a faster way to run the strategies you already trust.

Why Is Circle Buying Tazapay for $400 Million?

Yonier Bellido — Tue, 08 Sep 2026 16:08:15 GMT

In brief: Circle Internet Group has agreed to acquire Singapore-based cross-border payments firm Tazapay for approximately $400 million in an all-stock deal, its largest acquisition since 2018. The purchase gives the USDC issuer a licensed payments platform processing more than $25 billion in annualized volume across 100-plus markets, and is expected to close in 2027 pending regulatory approvals, including from the Monetary Authority of Singapore.

Circle Internet Group (NYSE: CRCL) has signed a definitive agreement to acquire Tazapay, a Singapore-headquartered cross-border payments company, for roughly $400 million in stock, according to CoinDesk, which reported the deal on September 8, 2026. The transaction is Circle's largest since it bought crypto exchange Poloniex in 2018, and it moves the dollar-backed payment issuer from minting a regulated digital dollar into owning the rails that move money across borders. In plain terms: Circle is buying distribution and licenses rather than building them.

Tazapay is a business-to-business payments infrastructure provider that supplies collection, holding, and payout services to payment firms and financial institutions. That is the self-contained definition worth holding onto: it is a licensed money-movement layer, not a consumer app, and it is the piece Circle has been missing.

What exactly did Circle agree to buy?

The headline number is about $400 million, paid entirely in Circle stock. Per a regulatory filing summarized by CoinDesk, Circle will set the share count using its volume-weighted average closing price over the 20 trading days before closing, with the consideration adjusted for Tazapay's debt, cash, and transaction costs. Roughly 5 percent of the shares will be held back for indemnities, with a further 3 percent reserved for the same purpose, a structure that spreads risk on both sides of a deal that will not close until 2027.

What Circle gets for that price is scale it did not have. Tazapay processes more than $25 billion in annualized payment volume, works with over 60 banks and fintech partners, and maintains local payout rails across more than 100 markets, according to reporting by YourStory. Its coverage spans alternative payment methods, cards, virtual bank accounts, payouts, and stablecoin settlement, as the company described when Circle and Ripple first took strategic stakes in it, per a PRNewswire release.

Why does the regulatory footprint matter more than the volume?

The volume is the story that makes headlines. The licenses are the story that makes the deal. Tazapay holds a Major Payment Institution licence (No. PS20200638) issued under Singapore's Payment Services Act 2019 and regulated by the Monetary Authority of Singapore. That licence authorizes account issuance, merchant acquisition, domestic and cross-border money transfer, and e-money issuance, and it carries MAS obligations on safeguarding customer funds, anti-money-laundering controls, and operational resilience, as set out on Tazapay's licenses page.

For an issuer whose entire proposition rests on being the compliant, auditable dollar, acquiring a regulated payments entity is the point. Building a comparable licensing footprint market by market is slow and uncertain. Buying one that already clears MAS scrutiny compresses years of regulatory groundwork into a single transaction, which is why the deal is best read as a licensing acquisition wearing a volume acquisition's price tag.

How does Tazapay fit Circle's payments ambitions?

Circle spent the past year positioning the Circle Payments Network as connective tissue for institutional dollar settlement, and it has paired USDC issuance with distribution deals such as its arrangement with Nium to power global payouts. Tazapay slots directly into that plan, extending Circle's reach across the Asia-Pacific region and emerging markets where local payout infrastructure is the hardest part to replicate.

The two companies were already entangled. In March 2026, Tazapay closed a $36 million Series B extension led by Circle Ventures, which the firm said would fund licensing expansion, per Crowdfund Insider. The acquisition converts that strategic stake into outright ownership, a familiar pattern in which an investor buys the company it already knew from the inside.

It also fits a broader buying streak. Circle paid roughly $100 million for Hashnote, the issuer behind money-market instrument USYC, in 2025, and $209.9 million for Coinbase's remaining half of the Centre Consortium that controlled USDC's intellectual property, according to CoinDesk. The Tazapay deal is larger than any of them, and it points outward toward payments rather than inward toward the token.

What does the deal signal for institutions?

The signal is that regulated digital-dollar issuers now compete on distribution and licenses, not just on reserves. Founded in April 2020 by Rahul Shinghal, Saroj Mishra, and Arul Kumaravel, Tazapay built its network around payment protection and counterparty verification for cross-border commerce, according to a company profile. That programmable, verifiable approach to moving money is precisely what a composable settlement layer needs, and it explains why an issuer would pay a premium for it.

For asset managers, banks, and issuers weighing how programmable dollars fit their operations, the read-through is concrete. Settlement infrastructure is consolidating around entities that can prove their licensing and their controls, and the firms that own both the unit of value and the rails beneath it are assembling something closer to an end-to-end financial utility.

What happens next?

The near-term picture is stable and slow. Tazapay's services, pricing, and support are expected to remain unchanged while the transaction is pending, per CoinDesk, and closing is not expected until 2027, subject to regulatory approvals that include MAS. That long runway is itself worth watching, because a payments acquisition of this size will draw scrutiny across every jurisdiction where Tazapay is licensed.

The open question is whether MAS and other regulators view a stablecoin issuer owning a Major Payment Institution as a natural evolution of dollar settlement or as a concentration that warrants conditions. The answer will shape not only this deal but the template for how the next issuer tries to buy its way into regulated payments. For institutions evaluating where programmable, auditable dollars actually settle, that ruling matters as much as the price. It is the kind of structural shift that firms building against composable, compliant assets, Issuant among them, will be tracking closely as the timeline unfolds.

How Did HDFC and ICICI Buy REC's Digital Bond?

Carter Bray — Mon, 07 Sep 2026 16:22:34 GMT

In brief: REC Limited, India's state-owned power financier, sold the country's first programmable corporate bond in early September 2026, raising 5 billion rupees (about $52.9 million) at a 7.30% coupon on notes maturing in May 2028. HDFC Bank and ICICI Bank were among roughly 20 buyers that included mutual funds and corporates, according to Bloomberg. The issue ran under a SEBI regulatory sandbox, cleared through the NSE electronic bond platform, and marks the first live test of India's plan to modernize its corporate debt market on distributed-ledger rails.

India's largest private-sector lenders have now bought a corporate bond that exists as a programmable, ledger-native security rather than a conventional paper-and-depository instrument. That single fact, more than the deal's modest size, is why the sale matters to anyone issuing or holding debt in one of the world's larger fixed-income markets.

What exactly did REC issue?

A programmable corporate bond is a debt security whose ownership, transfer, and lifecycle events are recorded and executed on a distributed ledger, while remaining a fully regulated instrument under existing securities law. REC's version is not a crypto product. It is a rupee-denominated bond with a fixed coupon, a defined maturity, and named institutional buyers, issued inside a supervised regulatory perimeter.

The economics were conventional. REC raised 5 billion rupees, roughly $52.9 million, on notes due in May 2028 at a 7.30% coupon, Bloomberg reported. The structure comprised a 100 crore rupee base issue with a 400 crore rupee greenshoe option, and the tenor ran one year and nine months, according to Indian PSU. Demand outpaced the paper on offer: the sale drew bids worth about 796 crore rupees against the 500 crore rupee ceiling, a comfortable oversubscription for a first-of-its-kind instrument.

The issuer is well chosen for a debut. REC Limited is a New Delhi-based state-owned lender to the power sector, and its domestic paper carries top-tier ratings, reaffirmed by ICRA and CRISIL in early 2026. Using a familiar, highly rated name removes credit uncertainty from a transaction whose real purpose was to prove the plumbing.

Which institutions bought it, and why does that matter?

About 20 investors took part, spanning banks, mutual funds, and corporates, with HDFC Bank and ICICI Bank among the buyers, per people familiar with the deal cited by Bloomberg. The participation of India's two largest private lenders is the signal here. When systemically important banks are willing to hold a ledger-native bond on their own books, the instrument stops being a lab experiment and starts looking like a fixture that treasury and fixed-income desks may need to accommodate.

Broad buyer diversity matters for a second reason. A pilot bought only by a single sponsor bank proves little about market appetite. A book of around 20 accounts across three institution types demonstrates that the settlement model, the custody arrangements, and the legal treatment were acceptable to a cross-section of the market at once.

How is the deal regulated and settled?

The sale was executed under the SEBI regulatory sandbox and routed through the NSE electronic bond platform (EBP), the same venue institutions already use for primary debt issuance, Indian PSU reported. Running the pilot on established market infrastructure, rather than a parallel system, is a deliberate choice that keeps the transaction inside familiar compliance and reporting channels.

The pilot is a joint effort between the Reserve Bank of India and the Securities and Exchange Board of India, Crypto Briefing noted. It also arrived alongside SEBI's broader "Demat 2.0" modernization push, which the REC issue was slated to help launch, according to Business Standard. The regulatory groundwork is not new. India's depositories, NSDL and CDSL, have run blockchain-based security and covenant monitoring since a 2021 SEBI circular, a starting point most jurisdictions attempting the same modernization simply do not have, as Blockhead observed.

Settlement is where India's approach becomes distinctive. The pilot was designed to use the RBI's wholesale digital rupee, its central bank digital currency, as the cash leg, Business Standard reported. That pairing lets both the security and the payment move as programmable objects, enabling delivery-versus-payment on a shared ledger and cutting the settlement lag and counterparty exposure that persist in conventional processing. The RBI has been building toward this for years, having launched wholesale digital rupee pilots in the call money market in 2023 and later expanding its e-rupee experiments into tokenized deposits.

How does India's model compare to a conventional bond issue?

The REC pilot keeps the parts of the market that work and replaces the parts that create friction. The table below sets the two approaches side by side.

Feature	Conventional corporate bond	REC programmable bond
Record of ownership	Depository book entry (NSDL / CDSL)	Distributed ledger under SEBI sandbox
Primary venue	NSE electronic bond platform	NSE electronic bond platform
Cash settlement	Interbank funds, T+1 cycle	Wholesale digital rupee (RBI CBDC)
Lifecycle events	Manual, intermediary-driven	Programmable on the ledger
Regulatory status	Established SEBI framework	Same framework, sandbox pilot

The point of the comparison is continuity. The issuer, the platform, and the legal character of the security are unchanged. What shifts is the settlement asset and the programmability of the record, which is precisely where auditability and operational efficiency improve.

What comes next for India's debt market?

The strategic prize dwarfs the pilot. Coverage of the sale framed it against India's roughly $624 billion corporate debt market, a market that a programmable settlement layer could make deeper and more liquid, as TechTimes reported. If ledger-native issuance moves from sandbox to standard, the addressable scope is the entire corporate bond stack, not a single 500 crore rupee test.

SEBI has signaled that tokenization and DLT settlement remain firmly on its agenda, with the regulator confirming its corporate bond pilot was actively moving through 2026, per Ledger Insights. For issuers, the near-term takeaway is that a credible, regulated path to programmable debt now exists in a major emerging market, validated by the buy-side names that matter most.

Frequently asked questions

Is REC's bond a regulated security or a crypto asset? It is a regulated rupee corporate bond. It was issued under a SEBI regulatory sandbox, cleared on the NSE electronic bond platform, and carries a fixed 7.30% coupon and a May 2028 maturity. The distributed ledger changes how ownership is recorded and settled, not the legal nature of the instrument.

How was the cash leg settled? The pilot was structured to settle in the RBI's wholesale digital rupee, the central bank's CBDC, allowing the security and the payment to move together on a shared ledger. That design supports delivery-versus-payment and reduces settlement lag relative to conventional interbank funding.

Can other issuers replicate this structure now? Not yet at scale. The REC sale ran inside a joint RBI and SEBI sandbox rather than an open, generally available framework. For issuers evaluating programmable, composable, and auditable debt, the deal is best read as proof that the model works in a major market. Building issuance infrastructure that can move from pilot to production is where the next round of work sits, and where firms such as Issuant focus.