A wave of regulatory activity on both sides of the Atlantic is reshaping how digital assets are issued, traded, and held, pushing cryptocurrencies and tokenised securities closer to the standards that govern traditional financial markets.
The shift, years in the making, accelerated sharply in 2025.
Landmark legislation, revised enforcement postures, and a surge of institutional activity have together moved digital assets from the regulatory grey zone toward something more closely resembling a structured financial ecosystem.
The U.S. Makes a Sharp Turn
For much of the past decade, the U.S. approach to digital assets was defined by enforcement rather than rules. That changed in 2025.
The Securities and Exchange Commission dropped nearly all of the enforcement actions it had filed against crypto firms under the previous administration cases built on allegations of unregistered broker-dealer activity rather than fraud.
The most consequential development was the passage of the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act, signed into law in July 2025.
The legislation created the first comprehensive federal framework for payment stablecoins.
It established baseline reserve requirements, mandatory monthly disclosures, and a licensing pathway administered primarily through the Office of the Comptroller of the Currency.
The law also clarified that stablecoins are not securities, commodities, or bank deposits, a distinction that matters enormously for how they are regulated and by whom.
Almost immediately, the OCC received a wave of applications for new national bank charters, particularly from firms seeking to provide custody services for digital assets.
In December 2025, the OCC granted conditional approval for five such charter applications.
Congress is now considering a second piece of legislation, the Digital Asset Market Clarity Act of 2025, or CLARITY Act, which passed the House in July 2025 with bipartisan support.
The bill is designed to resolve a long-running jurisdictional dispute between the SEC and the Commodity Futures Trading Commission by defining most digital assets as commodities subject to CFTC oversight.
Passage in the Senate has stalled, though negotiations have continued into 2026.
Europe Moves to Full Enforcement
Across the Atlantic, the European Union’s Markets in Crypto-Assets Regulation, or MiCA, is moving from transition to full enforcement.
The regulation, the EU’s first comprehensive framework for crypto-assets, entered full application in December 2024.
All crypto-asset service providers operating in the bloc must now obtain authorisation, with a final transitional deadline of 1 July 2026 for those that had been operating under national regimes.
The regulation sets uniform requirements for disclosure, governance, capital adequacy, anti-money laundering controls, and consumer protection across all 27 EU member states.
Firms that miss the July deadline face licence revocations, fines of up to 12.5% of annual turnover, and potential personal liability for executives.
The results so far have been significant. More than 40 licences have been issued since December 2024, with Germany and the Netherlands leading the way.
The ECB has reported a 60% reduction in crypto fraud cases since MiCA enforcement began.
The regulation is also beginning to reshape the industry’s structure.
SwissBorg, a Swiss crypto platform with $1.3 billion in assets under management, recently secured a MiCA licence and is repositioning its European operations through a newly authorised French entity.
Its COO, Jeremy Baumann, said MiCA is raising the bar for firms serving European clients and that some global platforms are already reassessing their EU footprint.
Gemini has exited the bloc entirely.
“MiCA raises the regulatory and operational standards required to serve European clients,” Baumann said, “which may reduce the number of lightly structured players.”
Banks and Asset Managers Move In
Perhaps the clearest sign of the regulatory shift is what the world’s largest financial institutions are now doing in digital asset markets openly and at scale.
JPMorgan launched its first tokenised money-market fund on the Ethereum blockchain in December 2025.
The vehicle, called the My OnChain Net Yield Fund (MONY), was seeded with $100 million in JPMorgan capital and made available to qualified investors through the bank’s Kinexys Digital Assets platform.
“There is a massive amount of interest from clients around tokenisation,” said John Donohue, head of global liquidity at JPMorgan Asset Management.
“Tokenization can fundamentally change the speed and efficiency of transactions.”
The bank also arranged a landmark commercial paper issuance for Galaxy Digital on the Solana blockchain, one of the first such transactions in the U.S. settled using Circle’s USDC stablecoin.
Coinbase and Franklin Templeton were among the buyers.
BlackRock, the world’s largest asset manager, has made tokenisation a strategic priority. Its USD Institutional Digital Liquidity Fund (BUIDL) has accumulated more than $2.5 billion in assets.
In its 2026 Thematic Outlook, the firm’s investment team named crypto and tokenisation among the themes shaping markets this year, noting that access to a broader range of assets via blockchain will grow as tokenisation rises.
Goldman Sachs and Bank of New York Mellon have also announced a partnership to tokenise money-market fund shares for institutional investors.
Visa, meanwhile, has launched a stablecoin settlement pilot allowing U.S. banks to settle transactions using USDC.
Why Tokenisation Is Gaining Ground
The appeal of tokenisation representing real-world assets like bonds, equities, and money-market funds as digital tokens on a blockchain is rooted in practical efficiency rather than novelty.
Conventional securities settlement typically takes one to two business days after a trade. Tokenised instruments can settle in hours or minutes.
Collateral that previously took days to move between custodians can be transferred in seconds.
JPMorgan demonstrated this directly when BlackRock used its Tokenised Collateral Network to post tokenised fund shares to Barclays as collateral for a derivatives trade, a transfer that took approximately one second, compared with what could otherwise take a day or more.
The tokenised asset market nearly quadrupled in 2025 to close to $20 billion, according to data from RWA.xyz.
Analysts at BCG and Ripple project the broader market could reach $18.9 trillion by 2033.
Jürgen Blumberg, COO of tokenisation specialist Centrifuge, has predicted that the total value of real-world asset tokens will exceed $100 billion by the end of 2026, with more than half of the world’s 20 largest asset managers having launched tokenised products.
SEC Chairman Paul Atkins has publicly endorsed tokenisation as a significant innovation for capital markets, describing it in a recent television interview as having the potential to change the financial system over the next few years.
Challenges Remain Substantial
Despite the progress, the path toward full integration of digital assets into mainstream capital markets remains complicated.
Regulatory fragmentation is one of the most persistent obstacles.
The EU’s MiCA framework is itself inconsistent in practice: transitional deadlines have varied by country, with the Netherlands requiring compliance by mid-2025 and others extending to July 2026.
ESMA audits in the first half of 2025 found that supervisory approaches remained uneven across member states.
In the U.S., the CLARITY Act remains stalled in the Senate. The jurisdictional boundary between the SEC and CFTC is still unresolved for most digital assets beyond stablecoins.
And while enforcement has eased significantly, formal rules governing issuance, custody, and trading are still being written.
Legal questions around tokenised assets are also largely unanswered.
How existing commercial law applies to token-based property ownership, and how tokens should be treated as collateral, remain active debates without clear resolution.
There is also a structural bottleneck in scaling tokenised markets: interoperability. Most tokenised instruments currently operate on different blockchains with incompatible standards.
Without shared identity frameworks and interoperability between networks, tokenised markets risk fracturing into disconnected pools rather than deepening into a unified infrastructure.
The Direction of Travel
The World Economic Forum described 2026 as a defining moment for digital assets, pointing to the convergence of regulatory clarity, enterprise-grade deployment, and improving interoperability as factors pushing blockchain from experimental applications toward the foundations of a new digital financial market infrastructure.
The regulatory picture, while incomplete, is moving in a clear direction. Stablecoins now have a federal framework in the U.S. and are governed by MiCA in Europe.
Tokenised securities are being defined as securities by regulators. Custody is becoming a permissible activity for mainstream banks. And institutional capital is following.
For market participants, the risk in 2026 is less about regulatory overreach and more about regulatory misalignment building products that do not meet the capital markets expectations that investors, counterparties, and regulators are already applying.
The rules are taking shape. The question is how quickly the rest of the market catches up.
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