WuBlockchain

Standard Chartered has become the first bank to distribute one of Hong Kong’s two regulated stablecoins, offering HKDAP, issued by Anchorpoint Financial, to eligible institutional clients and partners. The bank plans to launch tokenized money market fund subscription and settlement services with asset managers in Q4, while also testing HKDAP for intragroup settlement and exploring cross-border payment and treasury-management use cases.

According to Binance market data, BTC has broken above the $80,000 level, reaching a nearly three-month high, and is currently trading at around $79,174. BTC last broke above $80,000 on May 4, 2026, marking a return to the level after 113 days. According to CoinGlass data, total crypto liquidations over the past four hours reached approximately $179.19 million, including $78.99 million in long positions and $100.20 million in short positions.

According to CryptoSlate, citing SEC filings, CleanCore sold substantially all of its 463 million DOGE holdings on July 20 for about $33.4 million and redirected the proceeds toward its AI infrastructure business. The company also completed a $100 million stock offering, increasing shares outstanding by about 122% to 502.1 million, while additional warrants could create further dilution.

DWF Labs said Bitcoin posted its strongest weekly gain since March 2023, rising 23.6% to $77.7K, while ETH gained 31.3% to $2.46K. The firm pointed to several catalysts, including the U.S. Treasury’s decision to double long-end bond buybacks to at least $4 billion per operation, the SEC’s Regulation Crypto proposal, and $2.6 billion in combined BTC and ETH ETF inflows. Crypto volatility also rebounded sharply, with August 19 seeing about $2.99 billion in liquidations, mostly shorts, while aggregate futures open interest rose 16.5% to $137.5 billion. DWF Labs argued that the move was driven more by short covering and spot demand than by a buildup in leveraged longs.

BitMine said it acquired 32,447 ETH over the past week, bringing total holdings to 5,847,611 ETH, or about 4.8% of Ethereum’s supply. The company has staked 5,067,309 ETH, roughly 87% of its holdings, with projected annualized staking revenue of about $330 million. BitMine also reported $308 million in cash and marketable securities, while total crypto, cash, securities and other investments reached $14.9 billion as of August 23.

Strategy said it sold 18.26 million MSTR shares for $2.01 billion in net proceeds between August 17 and 23. Of the proceeds, $136.4 million was used to repurchase STRC preferred shares, $300 million was added to its existing USD Reserve, and the remainder was allocated to a newly established “USD Cash” pool for flexible Bitcoin treasury purposes, including potential BTC purchases, debt service and share repurchases. As of August 23, Strategy held $5.10 billion in USD Reserve and $1.59 billion in USD Cash. The company made no Bitcoin purchases or sales during the week, leaving holdings unchanged at 840,447 BTC.

According to CNBC, citing two senior Treasury officials, the U.S. Treasury is considering using funds from its roughly $950 billion Treasury General Account to help finance larger buybacks of long-dated government debt. Treasury recently doubled the size of individual buybacks of off-the-run 10- to 30-year securities from $2 billion to at least $4 billion, while Treasury Secretary Scott Bessent said the operations could be even larger. Officials did not disclose how much of the TGA might be used or when, but said the funds are considered available for the buyback program.

Author | @agintender
Complied by | WuBlockchain
Original Link：
https://x.com/agintender/status/2071837382828249527
If the crypto world from 2016 to the present were compressed into a single sentence, it would read something like this: over the course of a decade, the industry went from “I do not need anyone’s permission” to “I must obtain a license” — and it traveled that road through a succession of settlements, criminal charges, court rulings, and several major collapses.
Prologue: Compliance Was Not Imposed on the Industry; It Became the Price of Admission
Every time the industry thought it had won, another wave of regulation followed. Every time regulators thought they had brought the industry under control, it moved into the next uncharted territory. This is a classic system of cat-and-mouse evolution, but a more precise description would be a compliance flywheel: crises, enforcement, and legislation take turns driving the cycle forward. With each rotation, regulation becomes more granular and another part of the industry’s “gray area” disappears.
I divide this decade into five stages. Each stage has a defining compliance paradigm, a set of landmark cases, and a previous generation of “gray areas” that was forced out of existence.
Stage One (2016–2018): The Era of Industry Self-Regulation. Amid the ICO frenzy, the industry created its own compliance tools — SAFTs, foundation structures, and allowlist-based KYC. The Howey test returned to prominence, while the SEC used the DAO Report to declare that tokens could also constitute securities.
Stage Two (2019–2021): The Era of Licensing. The FATF Travel Rule was introduced, countries began rolling out licensing regimes, and regulators started pulling crypto into the traditional banking framework. BitMEX became the first major “offshore” exchange to face criminal prosecution. (This article covers only the first two stages.)
Stage Three (2022): The Year of Collapse. Terra, Tornado Cash, and FTX delivered three successive shocks. OFAC sanctioned a piece of code for the first time, and the regulatory debate shifted decisively from “whether to regulate” to “how to regulate comprehensively.”
Stage Four (2023–2024): The Era of Enforcement Reckoning. Binance and CZ paid $4.3 billion, offshore exchanges collectively entered an “era of settlements,” and the SEC pursued cases against Coinbase, Kraken, and Binance on three parallel fronts. Proof of Reserves was rolled out with great fanfare during this period, yet regulators remained largely unmoved — a phenomenon that itself merits closer examination.
Stage Five (2024–2026): The Era of Legislative Codification. The GENIUS Act, the CLARITY Act, the repeal of SAB 121, the wave of SEC case dismissals, and the approval of crypto ETFs marked a shift from “hostile enforcement” to rules set out in black and white. The industry moved from “winning in court” to “finally getting the rules it had been waiting for.”
Four underlying threads run through all five stages:
The scope of regulation kept expanding — from project teams to exchanges, protocol code, and eventually the entire ecosystem.
Compliance tools continued to evolve — from registration and disclosure to licensing, cross-border standards, sanctions, and legislation.
The driving force kept changing — from industry self-regulation to regulatory agencies, crisis-driven intervention, and ultimately lawmakers.
The offshore–onshore dynamic repeatedly reversed itself — from moving offshore to escape regulation, to regulators penetrating offshore structures, and finally to a selective return onshore.
We now turn to the main discussion.
Stage One (2016–2018): The Era of Industry Self-Regulation
1.1 The ICO Frenzy and the Birth of “Pseudo-Compliance” Tools
The year 2017 marked crypto’s first real collision with U.S. securities law. Global ICO fundraising surged from less than $100 million in 2016 to approximately $6.5 billion in 2017, then doubled again in the first half of 2018. Filecoin raised $257 million in a single offering, while EOS raised $4.1 billion through a year-long ICO — the latter remains the fundraising record for a single project.
But how was all this money raised? The answer is that the vast majority of projects had never seriously considered that they might be selling securities. The compliance narrative surrounding early ICOs could be reduced to a single sentence: “We are selling a utility token, not a security.” The legal basis for that narrative was extremely weak. The four-prong investment contract test established by the U.S. Supreme Court in SEC v. W.J. Howey Co., 328 U.S. 293 (1946) — an investment of money, in a common enterprise, with an expectation of profits, derived from the efforts of others — was already broad enough to bring most ICOs within the reach of securities law. Yet few market participants cared about that in 2017.
Lawyers were among the first within the industry to recognize the risk. In the second half of 2017, Marco Santori of Cooley LLP proposed the SAFT, or Simple Agreement for Future Tokens, framework. The idea was to treat the presale to accredited investors as a securities offering conducted under the Rule 506(c) exemption of Regulation D, then allow the tokens to circulate publicly once they had acquired genuine utility. The framework attempted to create a transitional path to compliance for ICOs.
From the outset, however, the SAFT was a legally contentious design. Legal scholars argued that its attempt to divide the Howey analysis into two stages was untenable. An issuer could not sell a promise of “future tokens” during the fundraising stage — which was plainly a security — and then declare that the tokens were “no longer securities” once they launched. An asset’s legal character should be determined by its economic substance, not by an issuer’s decision to divide the transaction into two time periods. In retrospect, this was precisely the reasoning the SEC later used in the Telegram case to defeat Telegram’s SAFT structure.
Developing alongside the SAFT was the offshore foundation structure. Beginning in the second half of 2017, new projects increasingly stopped incorporating in Delaware and instead turned to three jurisdictions:
Zug, Switzerland, or “Crypto Valley”: The Ethereum Foundation and the Tezos Foundation established themselves there. In February 2018, the Swiss Financial Market Supervisory Authority, or FINMA, issued its ICO guidelines, classifying tokens into utility, payment, and asset tokens and providing comparatively favorable room for interpretation.
Singapore: The Monetary Authority of Singapore, or MAS, issued its guide to digital token offerings in November 2017. Its pragmatic approach made Singapore foundations a preferred option for Asian projects.
The Cayman Islands: Tether, BitMEX, FTX, and numerous other “operating entities” were incorporated there, attracted by the absence of income tax and relatively permissive entity-formation requirements.
Together, these three jurisdictions formed the “standard compliance template” for ICO projects in 2017 and 2018: a Singaporean or Swiss foundation would issue the tokens, a Cayman Islands company would hold the operating assets, and a U.S. entity would handle marketing or development. The central idea was to separate legal liability from economic benefits geographically. This structure later became a recurring target for the SEC and the DOJ. One of the key arguments used by the DOJ in the FTX, Binance, and Tether cases was that where an entity was incorporated mattered less than whether it was providing services to U.S. users.
1.2 The DAO Report: The First Major Regulatory Blow
On July 25, 2017, the SEC released a historic document: Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934: The DAO (Release №81207). The report examined The DAO, a decentralized venture capital fund built on Ethereum that raised approximately $150 million in 2016 before losing around $60 million in a hack. The incident indirectly led to the Ethereum hard fork and the creation of Ethereum Classic.
The report did not initiate an enforcement action. Instead, the SEC issued it as a Section 21(a) “report of investigation,” effectively making it a public warning. Its conclusions were nevertheless groundbreaking: the SEC expressly stated that DAO Tokens constituted securities and that both issuers and trading platforms could violate federal securities laws. It was the first time a U.S. regulator had applied the Howey test comprehensively to a crypto token.
Following the DAO Report, the SEC accelerated its enforcement activity. On December 11, 2017, In the Matter of Munchee Inc. (Securities Act Release №10445) became the first ICO to face direct SEC enforcement. Munchee, a restaurant-review app, launched its ICO in October 2017. The SEC intervened the following month, prompting the company to halt the offering and return all funds raised.
The SEC’s order made the principle clear: even if an issuer claimed that its token had utility, it could still constitute a security if purchasers had an “expectation of profits” based on the “efforts of others.” The speed of the Munchee action — from the launch of the ICO to its termination in just one month — sent the industry an unambiguous message: regulators had awakened.
1.3 Landmark Cases: SEC v. Telegram and SEC v. Kik
If Munchee was the SEC’s warning shot against smaller ICOs, SEC v. Telegram and SEC v. Kik between 2018 and 2020 represented its reckoning with the SAFT framework itself.
In SEC v. Telegram Group Inc., 448 F. Supp. 3d 352 (S.D.N.Y. 2020), Telegram sold approximately $1.7 billion worth of Gram Token Purchase Agreements to accredited investors in 2018 through a private placement under Regulation D, Rule 506(c), promising to deliver Gram tokens after the TON mainnet launched. It was a textbook SAFT structure. The SEC filed suit in October 2019, arguing that the purportedly “two-stage” transaction constituted a single securities offering when viewed as a whole.
On March 24, 2020, presiding Judge P. Kevin Castel issued a preliminary injunction preventing Telegram from distributing Gram tokens to both U.S. and non-U.S. investors. The ruling contained a crucial conclusion: the SAFT agreements and the tokens formed an economically integrated arrangement, and SAFT purchasers had expected from the outset to resell the tokens on secondary markets for a profit. In other words, these were not two independent transactions but a single, integrated securities offering.
Telegram formally abandoned the TON project in May 2020, returned approximately $1.2 billion to investors, and paid an $18.5 million civil penalty to the SEC.
The same reasoning appeared in SEC v. Kik Interactive Inc., 492 F. Supp. 3d 169 (S.D.N.Y. 2020). In September 2017, Kik raised $50 million through a private SAFT sale, followed by approximately another $50 million through the public sale of Kin tokens. In a summary judgment issued on September 30, 2020, Judge Alvin K. Hellerstein accepted the SEC’s argument in full: the private SAFT sale and the public offering constituted a “single integrated offering,” which, taken as a whole, was an offering of securities. Kik ultimately paid $5 million to settle the case.
Together, the two rulings effectively brought the SAFT framework to an end. From the second half of 2020 onward, almost no project was willing to rely solely on a SAFT structure to raise funds in the U.S. market.
1.4 USDT’s “Unregulated Era”: The First Chapter of Stablecoins
Another thread was quietly emerging during the first turn of the compliance flywheel: stablecoins.
USDT was launched in 2014 by Tether Limited, formerly known as Realcoin, and was effectively controlled by the team behind Bitfinex through iFinex Inc. Its original promise was exceptionally simple: “Every USDT is backed by one real U.S. dollar held in reserve.” Between 2014 and 2018, however, this claim was never verified through an independent audit.
In 2017, Tether engaged Friedman LLP to conduct a “comfort letter”-style review of its reserves. The resulting document did not constitute an audit opinion, and Friedman and Tether ended their relationship soon afterward.
During the second half of 2018, the circulating supply of USDT grew from less than $1.5 billion at the beginning of the year to nearly $2.8 billion. Rumors that USDT was not fully backed repeatedly circulated through the market. In October 2018, USDT briefly fell to around $0.85 on secondary markets — the first large-scale depegging event in stablecoin history.
At this stage, the stablecoin market was essentially a private monetary experiment conducted without any regulatory involvement. Tether injected liquidity through Bitfinex and distributed it across the broader ecosystem through centralized exchanges, particularly in Asian markets. No one could verify whether its reserves were genuine, and no legal framework required it to disclose them.
That regulatory vacuum would be filled during the second stage by the New York Attorney General, or NYAG, and the CFTC. The price, however, would be the largest compliance crisis in USDT’s history.
Stage Two (2019–2021): The Era of Licensing and Integration with Traditional Finance
2.1 The FATF Travel Rule: Bringing Crypto into the Banking Framework
On June 21, 2019, the Financial Action Task Force, or FATF, issued an updated interpretation of Recommendation 15, formally bringing “virtual asset service providers,” or VASPs, within the anti-money laundering and counter-terrorist financing framework. The provision with the greatest practical impact was the Travel Rule:
For any virtual asset transfer exceeding the equivalent of $1,000 or EUR 1,000, VASPs must collect and transmit identifying information about the originator and beneficiary at the time of the transfer. This includes the originator’s name, account number, and address, as well as the beneficiary’s name and account number. The information must “travel” with the transaction between VASPs.
The Travel Rule was not created by FATF from scratch. It was directly adapted from the rules governing bank wire transfers that took effect in 1996, including Title 31 CFR 1010.410(f) under the U.S. Bank Secrecy Act. In essence, FATF’s action in 2019 declared that the rules governing crypto asset transfers should be aligned with those governing traditional bank wires.
The rule had profound and painful consequences.
In the traditional banking system, the Travel Rule is implemented through closed, standardized, and permissioned infrastructure such as the SWIFT network. In crypto, however, transfers occur on public blockchains, and no standardized protocol exists for transmitting identity information between VASPs. The industry was therefore forced to build its own “Travel Rule solutions,” resulting in multiple incompatible protocols, including TRP, Sygna, Notabene, and TRUST, an alliance led by Coinbase.
Self-hosted wallets became a gray area. Subsequent FATF guidance allowed VASPs to transact with “unhosted wallets,” but required them to conduct due diligence using a “risk-based approach.” This effectively shifted responsibility onto exchanges, and national regulators diverged in how they implemented the rule. South Korea and Switzerland adopted some of the strictest approaches, requiring additional verification for self-hosted wallets. The U.S. Financial Crimes Enforcement Network, or FinCEN, attempted to introduce stricter rules in late 2020 but ultimately put them on hold, while the European Union adopted a comparatively intermediate approach under the MiCA framework.
The Travel Rule represented a paradigm shift in the compliance flywheel. It marked the point at which regulators stopped treating crypto as a “novel phenomenon” requiring special treatment and began applying established rules from traditional finance directly to the industry. The difficulties created by this process would repeatedly surface in the subsequent Binance, Bitzlato, and Tornado Cash cases.
2.2 The Global Expansion of Licensing Regimes
Between 2019 and 2021, major jurisdictions established or further developed licensing frameworks for crypto exchanges:
Japan’s FSA: Following the 2017 amendment to the Payment Services Act, Japan became one of the first countries to legally recognize “virtual currency exchanges.” After Coincheck lost $530 million worth of NEM in a hack in January 2018, the Financial Services Agency tightened its licensing reviews. By 2021, it had issued approximately 30 full licenses.
Singapore’s MAS: The Payment Services Act, or PSA, took effect in January 2020, requiring all digital payment token service providers to apply for licenses. Large numbers of crypto projects initially moved into Singapore, but MAS tightened its approach significantly beginning in the second half of 2021. Over a three-year period, it issued Major Payment Institution licenses to only a small number of firms, including DBS Vickers, Independent Reserve, and Crypto.com, while rejecting many other applications. Binance voluntarily withdrew its Singapore license application in December 2021, marking Singapore’s shift from relatively open entry to strict licensing approval.
The U.S. NYDFS BitLicense: The BitLicense regime had already taken effect in 2015, but implementation was slow. By the end of 2021, the New York State Department of Financial Services had issued approximately 30 BitLicenses and limited-purpose trust charters. Coinbase, Gemini, Paxos, and Circle all obtained important New York licenses during this period.
The EU’s 5AMLD: The Fifth Anti-Money Laundering Directive, which took effect in January 2020, brought crypto service providers within the EU’s AML framework for the first time. It laid the groundwork for MiCA’s full implementation in 2024.
Hong Kong’s SFC: In December 2020, the Securities and Futures Commission introduced a voluntary licensing framework for virtual asset trading platforms, or VATPs. Only OSL and HashKey obtained licenses during the second stage. The landscape changed again after Hong Kong moved to a mandatory licensing regime in 2023.
The essence of a licensing regime is that market access is determined by regulators rather than the market. Before 2018, launching an exchange required little more than a domain name, a matching engine, and a hot wallet. From 2020 onward, legally operating without a license became nearly impossible in major markets.
This pushed the industry toward two extremes: either fully embrace licensing, as Coinbase, Gemini, and Kraken did, or move entirely offshore, as Binance, FTX, BitMEX, and OKX did. The latter group soon encountered its first direct regulatory blow.
2.3 A License Is Not a Passport; It Reflects Local Priorities
The greatest danger in applying for licenses is path dependence.
Many crypto companies made the same mistake in their early years: they assumed that obtaining one license meant they had mastered a compliance template that could be replicated globally. They would begin in Singapore, then move to Dubai, Abu Dhabi, and Europe, before eventually attempting to find a route back into the United States. On the surface, this appeared to be a “global compliance strategy.” In practice, it often involved presenting the same documents, the same governance narrative, and the same legal language repeatedly to different regulators.
Yet licensing is one of the clearest expressions of local priorities.
The logic of Singapore’s MAS places the reputation of the financial center first. Singapore does not reject crypto outright, but it does not want crypto to turn the country into a casino for Asian retail investors. After the Payment Services Act took effect in 2020, Singapore received approximately 170 applications from digital payment token service providers. By mid-2021, 30 applications had been withdrawn, two had been rejected, and approximately 90 firms were still operating under temporary exemptions while awaiting review. MAS stated at the time that its assessments focused on AML and counter-terrorist financing risks, as well as controls for technological risks.
By 2022, MAS had gone further, instructing DPT service providers not to promote crypto services extensively to the general public. The restrictions extended to advertisements in subway stations and other public spaces, as well as promotional campaigns involving social media influencers. (MAS PS-G02)
MAS therefore cannot be described simply as “friendly” or “unfriendly.” It welcomes custody, payments, institutional services, and stablecoin infrastructure, while remaining wary of exchange businesses built around retail customers, high leverage, and aggressive marketing. Obtaining a Singapore license is not about proving that “we can grow.” It is about proving that “we will not damage Singapore’s reputation as a financial center.”
Dubai’s Virtual Assets Regulatory Authority, or VARA, has a very different character. VARA is a regulator established specifically for virtual assets, and its approach resembles a combination of industrial development and conduct regulation: companies are welcome to enter, but they must maintain a local legal entity, responsible personnel, an office, and an operational presence that regulators can oversee.
VARA’s public register specifies each VASP’s authorized activities, permitted customer types, and licensing status. Recent public records show approximately 49 entries. An in-principle approval, or IPA, does not authorize a company to begin operating. Only a firm holding a full VASP license may provide services to customers. (VARA Public Register)
VARA’s fee structure is equally revealing. The application fee for advisory services is approximately AED 40,000, while applications covering core activities such as exchange services, custody, broker-dealer services, and lending and borrowing generally cost AED 100,000. The corresponding annual supervision fee can reach AED 200,000. Applying for additional activities also incurs an extension fee. (VARA Fee Schedule)
These high thresholds send a clear message: a license is not a logo but a set of continuing costs. The more complex the business, the more expensive its supervision becomes. The more activities a company wants to cover, the greater the compliance budget, staffing, and local commitment it must provide.
The Abu Dhabi Global Market, or ADGM, represents another model. Its Financial Services Regulatory Authority, or FSRA, resembles a Middle Eastern version of an Anglo-American financial regulator. Rather than merely asking whether a company is a “crypto company,” it breaks the business down into conventional financial activities. Is the company operating a multilateral trading facility, providing custody, dealing in assets, or managing funds? Virtual assets are treated as the underlying assets, while the regulator focuses on the financial functions being performed.
ADGM’s virtual asset guidance brings trading venues, custodians, intermediaries, and the use of stablecoins within its framework. Capital requirements are adjusted according to risk and business complexity. A virtual asset MTF is generally required to maintain regulatory capital equivalent to 12 months of operating expenses, while other virtual asset businesses are typically required to maintain capital equivalent to six months of operating expenses. Higher-risk institutions may also be required to hold additional capital buffers. (ADGM FSRA Guidance)
This illustrates ADGM’s regulatory preferences. It favors institutional businesses with clear governance, well-defined director responsibilities, and transparent capital and custody arrangements. It is less receptive to growth narratives based on “acquiring users first and adding compliance later.”
MiCA reflects European priorities: rather than relying on isolated licensing decisions, it turns crypto into a regulated product within a single market. MiCA’s rules for stablecoins, including asset-referenced tokens, or ARTs, and electronic money tokens, or EMTs, began applying on June 30, 2024. The full MiCA framework became applicable on December 30, 2024. Existing crypto asset service providers, or CASPs, may remain subject to transitional arrangements until July 1, 2026, or until their authorization is granted or refused.
Europe’s objective is not to give a particular exchange a “green light,” but to codify issuance, reserves, white papers, market abuse, consumer protection, and cross-border passporting within a unified framework. Stablecoins that reach a certain scale may also be classified as “significant,” triggering direct or joint supervision by the European Banking Authority, or EBA. The associated supervisory fees may be calculated according to the size of reserve assets or the scale of issuance. (EBA MiCA Role)
The U.S. SEC has an entirely different disposition. The central question in the United States is not simply whether a “crypto license” exists, but whether a company has spent the past decade unlawfully offering securities, operating an unregistered exchange, or providing brokerage or clearing services without registration. U.S. regulators are often less focused on approving future activity than on judging past conduct.
In fiscal year 2024, the SEC brought 583 enforcement actions and obtained $8.2 billion in monetary remedies, the highest amount in its history. Binance’s $4.3 billion settlement was an especially prominent example. The DOJ stated that Binance had deliberately profited from the U.S. market in pursuit of growth, market share, and profits without implementing the controls required under U.S. law. (DOJ Binance Case)
Regulators therefore tailor their treatment to the company before them. The larger the company, the more stringent the requirements. The more it earns, the larger the potential penalties. The closer its activities are to retail customers, leverage, stablecoins, fiat on- and off-ramps, and cross-border users, the less likely regulators are to treat it as an ordinary technology company.
This is the most frequently misunderstood feature of the licensing era. The industry believed it was searching for the “friendliest regulator,” while regulators were screening for the companies best suited to their local policy narratives. Singapore prioritizes reputation, Dubai seeks industrial development, Abu Dhabi favors institutional finance, Europe wants uniform rules, and the United States focuses on retrospective accountability.
A license is not the end point but a form of mutual adaptation: companies are reshaped by local rules, while those rules are, in turn, shaped by the companies’ scale, employment, tax contributions, risks, and effects on international reputation.
2.4 Landmark Case: BitMEX — The First Signal That “Offshore” Was No Longer Safe
On October 1, 2020, the CFTC and the U.S. Attorney’s Office for the Southern District of New York, or SDNY, took simultaneous action against BitMEX and its three founders, Arthur Hayes, Benjamin Delo, and Samuel Reed, filing both civil and criminal cases.
Civil case: CFTC v. HDR Global Trading Limited et al., №1:20-cv-08132 (S.D.N.Y. 2020). The CFTC alleged that BitMEX had operated an unregistered futures exchange, failed to implement effective AML and KYC programs, and offered margined derivatives to U.S. users. In August 2021, BitMEX reached a $100 million settlement with the CFTC and FinCEN.
Criminal case: United States v. Arthur Hayes, Benjamin Delo, and Samuel Reed, №1:20-cr-00500 (S.D.N.Y.). The three founders were charged with violating the Bank Secrecy Act by willfully failing to establish an anti-money laundering program at the exchange. Hayes pleaded guilty on February 24, 2022, and was sentenced in May 2022 to six months of home detention and two years of probation. Delo and Reed also pleaded guilty separately.
The significance of the BitMEX case lay not in the size of the penalties, which were relatively modest by later standards, but in the three enforcement principles it established:
An “offshore” structure does not provide an exemption from the BSA. BitMEX was incorporated in the Seychelles and operated from Hong Kong, but the DOJ used the presence of “U.S. users” as the jurisdictional connection that brought it within the reach of U.S. law.
Liability extended to individuals, not only the company. All three founders faced criminal prosecution in their personal capacities. This laid the groundwork for the later cases against SBF and CZ.
The absence of an AML program could itself constitute a crime. Before BitMEX, AML failures were often treated as procedural violations resolved through civil penalties. The BitMEX case established that such failures could constitute criminal violations of the Bank Secrecy Act.
These three conclusions would later be applied to Binance on a scale roughly ten times greater.
2.5 China’s September 24 Crackdown: The Great Retreat and the Reset of Global Crypto Geography
If the logic of Western regulation during the second stage was to “bring crypto into the traditional financial framework,” China took the opposite approach during the same period: complete separation.
The final expression of this separation, the “September 24 Notice” issued on September 24, 2021, was a geographic paradigm shift within the compliance flywheel. Rather than attempting to reshape the industry, it moved the industry elsewhere on the map.
The Timeline of the Two-Stage Separation
China’s removal of crypto activity was completed in two decisive stages.
The first separation, September 4, 2017: The People’s Bank of China, the Cyberspace Administration of China, the Ministry of Industry and Information Technology, the State Administration for Industry and Commerce, the China Banking Regulatory Commission, the China Securities Regulatory Commission, and the China Insurance Regulatory Commission jointly issued the Announcement on Preventing Risks from Token Offering and Financing. It became known within the industry as the “September 4 Announcement.”
It contained two central provisions: no organization or individual could engage in token offering and financing activities, meaning ICOs, and virtual currency trading platforms could not provide exchange services between fiat currencies and tokens within China.
The immediate result was the collective migration of China-based exchanges overseas. OKCoin became OKEx, registered in Malta, and later moved to the Seychelles. Huobi incorporated in the Seychelles. Binance was already operating through a multi-entity structure spanning the Cayman Islands, Hong Kong, and Japan, and subsequently excluded mainland China entirely from its business scope, at least in formal compliance terms.
Chinese-speaking users nevertheless remained a core customer base for these exchanges. They had simply moved from “opening accounts domestically” to “using VPNs to open accounts with offshore platforms.”
The second separation, September 24, 2021: The People’s Bank of China, the Cyberspace Administration of China, the Supreme People’s Court, the Supreme People’s Procuratorate, and six other authorities jointly issued the Notice on Further Preventing and Addressing the Risks of Speculation in Virtual Currency Trading.
On the same day, the National Development and Reform Commission and ten other authorities issued the Notice on Regulating Virtual Currency “Mining” Activities. Together, the two documents became known as the “September 24 Notices.”
The September 24 measures went significantly further than the September 4 Announcement in three respects:
A stronger legal characterization: The authorities expressly stated that “virtual currency-related business activities constitute illegal financial activities.” This was no longer merely a “risk warning”; it classified the entire industry as unlawful.
Cross-border coverage: The measures expressly provided that overseas virtual currency exchanges offering services online to residents in China were also engaging in illegal financial activities. This closed the largest gap left by the September 4 Announcement. Offshore exchanges had previously operated in a gray area by serving mainland users through Chinese-language interfaces. After September 24, that route was formally closed at the legal level.
A comprehensive mining ban: The NDRC document released on the same day classified virtual currency mining as an “eliminated industry” and required its removal nationwide.
The Chain Reaction That Reset Global Crypto Geography
The September 24 measures triggered the largest geographic redistribution in the history of the crypto industry.
The migration of mining: Before May 2021, mainland China accounted for approximately 65–75% of global Bitcoin hash rate. By the end of 2021, the officially recorded figure had fallen to nearly zero.
Hash rate migrated primarily to the United States, particularly Texas, Wyoming, and Georgia, where miners were attracted by inexpensive electricity and favorable policies, as well as to Kazakhstan and Russia. The United States subsequently became the world’s largest Bitcoin mining jurisdiction and continued to account for approximately 35–40% of global hash rate through 2025.
The compliance implications of this migration became visible during the fourth stage. The regulatory obligations of publicly listed U.S. mining companies, including Marathon, Riot, and CleanSpark, brought the mining industry within the SEC’s regulatory perimeter.
The offshore migration of exchanges’ Chinese-language operations: Binance, Huobi, OKX, and Gate.io had already incorporated in offshore jurisdictions beginning in 2017. After September 24, however, their Chinese-language operating teams also began moving overseas on a large scale. Key employees relocated from Beijing, Shanghai, and Shenzhen to Singapore, Dubai, Seoul, and Tokyo.
This produced an unusual industry structure: incorporation in the Seychelles, operations in Dubai, users across the Chinese-speaking world, and compliance in Malta. These overlapping mismatches became a central target of U.S. enforcement during the fourth stage. In the plea documents involving Binance and OKX, regulators focused specifically on the conflict between “substantive ties to China” and “nominal offshore structures.”
Hong Kong as a “safety valve”: While the September 24 measures closed the mainland route, Hong Kong began moving in the opposite direction. In late 2022, the Hong Kong Special Administrative Region government issued its Policy Statement on Development of Virtual Assets in Hong Kong. It introduced a mandatory VATP licensing regime in June 2023 and approved Asia’s first spot BTC and ETH ETFs in April 2024.
Together, these measures made Hong Kong a major regulated channel through which mainland capital could access crypto between 2023 and 2025. In a sense, this was a concrete expression of “one country, two systems” within the crypto sector.
The Compliance Implications of the September 24 Measures
Placed within the broader narrative of the compliance flywheel, the September 24 measures carried at least three implications.
They helped create the “offshore exchange problem.” A significant part of the reason BitMEX, Binance, OKX, Huobi, KuCoin, and HTX adopted offshore structures can be traced to Chinese regulation. Had China not severed ties with the industry, these exchanges might have continued operating primarily from China and remained subject to Chinese supervision.
When the U.S. later used the Bank Secrecy Act and the International Emergency Economic Powers Act, or IEEPA, to pursue these offshore entities, it was, in one sense, dealing with the global aftermath of China’s removal of the industry.
They demonstrated a compliance path fundamentally different from the Western model. Western regulators pursued a path of incorporation: using enforcement, settlements, and legislation to bring crypto within the traditional financial framework. China pursued a path of separation: declaring crypto activity broadly unlawful while developing a central bank digital currency, the digital yuan or e-CNY, as an alternative.
These two paths became opposing dimensions of the deeper competition over stablecoins in 2024 and 2025. The underlying purpose of the GENIUS Act was to bring dollar-denominated stablecoins within a U.S. regulatory framework and reinforce the dollar’s position. China, meanwhile, sought to use the e-CNY and mBridge, the multi-CBDC platform, to reduce reliance on the dollar-based system.
Hong Kong’s stablecoin legislation and its pilot programs for Hong Kong dollar stablecoins, including HKDR and HKDG, represented a concrete expression of this deeper competition within the crypto market.
They represented the only successful “expulsion-based” turn of the compliance flywheel. From a purely regulatory perspective, the September 24 measures were effective: financial risks within mainland China were largely removed. The cost, however, was that the opportunities associated with developing the industry shifted to other jurisdictions.
This trade-off began to reemerge in the policy rebalancing between Hong Kong and mainland China in 2025. The mainland began quietly exploring “allowlist” mechanisms and digital asset pilot programs, although it remained far from returning to the degree of openness that existed before 2021.
2.6 Blockchain Analytics Companies: The Invisible Infrastructure of Enforcement
The least discussed but most influential participants in the compliance evolution of the second stage were not regulators, but a group of private blockchain analytics companies: Chainalysis, Elliptic, TRM Labs, CipherTrace, which was acquired by Mastercard, and Crystal Blockchain.
They formed the “invisible infrastructure layer” of the compliance flywheel. Without them, the FATF Travel Rule could not be implemented, OFAC could not identify sanctions targets, the FBI could not trace Silk Road funds, and the DOJ could not build cases against BitMEX and Binance.
Satoshi’s Paradox
The Bitcoin white paper offered an original promise: pseudonymity. Addresses did not correspond directly to identities, and blockchain data alone could not identify the specific individuals behind transactions. Between 2008 and 2014, this promise broadly held because effective analytical tools did not yet exist.
The rise of blockchain analytics companies effectively reversed that promise of “pseudonymity.” All data on a public blockchain is visible, permanent, and linkable. With sufficient computing power and engineering capabilities, combined with a limited amount of off-chain identifying information, such as exchange KYC data, IP addresses, and social media activity, almost any apparently anonymous address can be deanonymized.
What Chainalysis, Elliptic, and their peers did was conceptually simple: they turned something theoretically possible into an industrial-scale product.
Chainalysis was founded in New York in 2014 by former Kraken COO Michael Gronager and Jan Møller, with Jonathan Levin later joining as a co-founder. Its core products, Reactor for investigations and KYT, or Know Your Transaction, for real-time monitoring, now serve most leading global exchanges and law enforcement agencies in dozens of countries. The company was valued at $8.6 billion in May 2022.
Elliptic was founded in London in 2013 by James Smith, Tom Robinson, and others. It became deeply embedded in the enforcement infrastructure surrounding the U.K. Financial Conduct Authority and European regulators.
TRM Labs was founded in San Francisco in 2018 by Esteban Castaño and Rahul Raina and experienced the fastest rise of the group. It served as a key technical partner to the DOJ in the landmark BitMEX, Binance, and Tornado Cash cases.
Blockchain Analytics Behind Landmark Cases
Nearly every major enforcement case from the second through the fourth stages involved these companies in some capacity:
The continued tracing of Silk Road funds: Blockchain tracing supplied by Chainalysis became a central tool in the FBI’s continuing efforts to identify Silk Road fund flows. It was one of the company’s earliest landmark demonstrations of its capabilities.
The 2016 Bitfinex theft of 120,000 BTC: Chainalysis continued tracing the stolen funds for six years. On February 8, 2022, the DOJ arrested Ilya Lichtenstein and Heather Morgan in New York and seized approximately $3.6 billion. At the time, it was the largest single crypto asset seizure in DOJ history. The Department of Justice specifically described the tracing process in its press release.
The Colonial Pipeline ransomware attack in May 2021: After the DarkSide hacking group extorted 75 BTC, worth approximately $4.4 million, from Colonial Pipeline, the FBI recovered 63.7 BTC within 27 days. The recovery was supported by a combination of blockchain analytics and cooperation from crypto exchanges that helped identify the flow of funds.
The Tornado Cash sanctions in August 2022: OFAC expressly cited blockchain analysis in its announcement, stating that Tornado Cash had been used to launder more than $7 billion, including at least $455 million linked to the Lazarus Group. In the criminal case against Roman Storm, TRM Labs served as a principal technical expert for the prosecution.
The four-agency Binance settlement in November 2023: FinCEN’s documents detailed suspicious transactions conducted through the Binance platform. Those transactions were identified using blockchain analytics tools. The references to “Iranian users” and “Hamas-linked users” in the CFTC’s complaint against Samuel Lim were also initially based on address clustering supplied by blockchain analytics companies.
The Structural Problem of Private Companies as “Quasi-Enforcement Tools”
The rise of blockchain analytics companies introduced a compliance question that remained unanswered during the second stage: when a group of private companies effectively controls the determination of what funds are “clean” and what funds are “tainted,” does that itself represent a new form of centralization?
The issue appears at three levels.
Analytics companies determine exchanges’ preemptive screening decisions. Coinbase, Kraken, Binance, and other exchanges use tools such as Chainalysis KYT to monitor customer deposits in real time. If Chainalysis labels certain Bitcoin as “high risk” because it previously passed through Tornado Cash, a darknet market, or a sanctioned address, an exchange may automatically freeze the associated account.
This effectively outsources a form of “jurisdictional authority” to a private company. The affected user has no opportunity for a hearing because the freeze occurs within a private-law relationship governed by a user agreement, rather than through an act of public law.
The costs of incorrect labeling flow in only one direction. If a blockchain analytics company incorrectly labels an address as high risk, causing multiple exchanges to deny service to its owner, the user’s avenues for redress are extremely limited.
The user generally cannot sue the analytics company because no contractual relationship exists between them. It is also difficult to sue the exchange because user agreements typically grant exchanges broad discretion to refuse service. Similar forms of “labeling without effective redress” exist in traditional finance, including credit ratings and KYC blacklists, but blockchain analytics operates at a greater scale and speed.
The invisible expansion of cross-border jurisdiction: Address labels produced by a U.S. company such as Chainalysis can influence the operational behavior of exchanges worldwide. Even when a transaction takes place entirely between two non-U.S. parties, U.S. compliance standards may be applied automatically if either party uses Chainalysis tools.
This represents the “Americanization” of the FATF Travel Rule at the implementation level: FATF supplies the rule, U.S. companies supply the tools, and the rest of the world operates according to U.S. standards.
The significance of blockchain analytics companies is not that they replaced regulators, but that they made regulation enforceable. Without them, the FATF Travel Rule would remain a rule on paper. Without them, OFAC sanctions would remain names on a list.
These companies are the transmission mechanism that allows the compliance flywheel to turn in practice. At the same time, they exercise a new form of “private quasi-enforcement authority” that has yet to be clearly governed by any regulatory framework. This is an issue that the sixth turn of the compliance flywheel will inevitably have to address.
2.7 USDT’s Moment of Reckoning: Enforcement by the NYAG and CFTC
The two USDT settlements were the most important stablecoin events of the second stage.
In NYAG v. iFinex Inc., №450545/2019 (N.Y. Sup. Ct.), New York Attorney General Letitia James filed a case against Tether’s parent company, iFinex, in April 2019. The NYAG alleged that Tether had used its reserves in 2018 to cover an approximately $850 million shortfall at Bitfinex after funds held by the payment processor Crypto Capital Corp. were frozen.
In other words, Tether had used money that was supposed to back USDT to fill a hole at an affiliated exchange.
The parties reached a settlement on February 23, 2021. Tether and Bitfinex agreed to pay an $18.5 million penalty, cease providing services to residents of New York, and submit quarterly reports on their reserves to the NYAG.
The NYAG used exceptionally severe language in its investigation report:
“Tether’s claims that its virtual currency was at all times fully backed by U.S. dollars was a lie.” — New York Office of the Attorney General Press Release, February 23, 2021
That statement remains a legal anchor for the continuing controversy over the transparency of USDT’s reserves.
In CFTC v. Tether Holdings Limited et al., CFTC Docket №22–04, dated October 15, 2021, the CFTC followed the NYAG action by alleging that Tether had made “materially false or misleading statements” about its reserves between June 2016 and February 2019. According to the CFTC, Tether did not hold sufficient fiat currency reserves for most of that period.
Tether paid a $41 million penalty, while Bitfinex separately paid $1.5 million over related issues.
The compliance implications of the two enforcement actions were clear: stablecoins did not exist outside the law, and issuers’ representations about their reserves could be examined under the traditional standards governing misrepresentations in securities and commodities markets.
More notably, however, neither action classified USDT itself as a security. The CFTC treated it as an underlying asset within its commodities and derivatives jurisdiction, while the NYAG proceeded under consumer protection law and the Martin Act. This unresolved question of legal classification would receive a formal answer during the fifth stage through the GENIUS Act.
2.8 USDC’s Alternative Path: Working with Regulators
USDC offered a sharp contrast to USDT. Circle and Coinbase jointly launched USDC through the Centre Consortium in 2018 and adopted a fundamentally different approach from the outset:
Reserve transparency: USDC reserves were held by Circle, with an independent accounting firm, initially Grant Thornton and later Deloitte, issuing monthly reserve attestations. Although these attestations did not constitute full audits, they were considerably more rigorous than Tether’s early comfort letters.
A conservative reserve structure: The reserves consisted primarily of short-term U.S. Treasury securities and cash deposits at banks, with no holdings of commercial paper. Tether did not fully eliminate commercial paper from its reserves until the middle of 2022, and those holdings had been one of the market’s principal concerns that year.
An embrace of licensing: Circle obtained a NYDFS BitLicense in 2018, registered with the U.K. Financial Conduct Authority in 2020, and obtained a digital payment token service provider license from Singapore’s MAS in 2022.
During the second stage, this path appeared “burdensome but stable.” It would soon be tested under extreme conditions by the collapse of Silicon Valley Bank — but that belongs to the third stage.
Bitfinex Securities: It launched tokenized stocks as early as 2024, but remained limited in scale.
Offshore exchanges such as Bybit and Gate.io: These platforms successively launched tokenized stock products, with clear signs of regulatory arbitrage.
The compliance issue surrounding this wave of tokenized stocks was straightforward: they were almost certainly securities. What was more interesting, however, was that the SEC under Atkins did not take immediate enforcement action. Instead, it stated that it was “considering the possibility of an innovation exemption framework.” This stood in sharp contrast to the enforcement approach of the Gensler era.
The OpenAI and SpaceX Controversy in Cannes
On June 30, 2025, Robinhood made an additional announcement at an event in Cannes: it would offer EU users “tokenized equity” in OpenAI and SpaceX, with each eligible user receiving the equivalent of EUR 5. The announcement triggered a cascading legal and public relations crisis.
On July 2, OpenAI issued an official statement on X, explicitly denying that the tokens had any connection to the company:
“These ‘OpenAI tokens’ are not OpenAI equity. We did not partner with Robinhood, were not involved in this, and do not endorse it. Any transfer of OpenAI equity requires our approval — we did not approve any transfer.”
SpaceX did not respond publicly, although Elon Musk reportedly expressed his dissatisfaction in private.
Robinhood CEO Vlad Tenev responded that the “tokens” were effectively interests in a special purpose vehicle, or SPV, holding private shares in OpenAI or SpaceX, rather than interests directly tied to actual OpenAI or SpaceX equity.
This explanation made the situation even more complicated. It meant that users were acquiring “some form of derivative representing an on-chain interest in an SPV,” with highly ambiguous rights and obligations.
The Bank of Lithuania, where Robinhood’s EU license is based, subsequently announced that it had opened a “fact-finding review” into the offering.
The compliance implications of the controversy were significant. Once tokenization crosses the boundary from “publicly listed stocks” into “private equity,” it begins to challenge all the traditional securities law rules governing private placement exemptions, accredited investor verification, and transfer restrictions.
Private companies such as OpenAI have historically controlled their valuations and shareholder composition through strict shareholder agreements and transfer approvals. Tokenization bypassed all of those controls — but the cost of doing so could be broad compliance exposure for every party involved in the issuance.
Three Structural Problems
The tokenized stock wave exposed three issues that neither the GENIUS Act nor the CLARITY Act had fully resolved.
Who is the issuer? The issuer of a tokenized stock is not the company being tokenized. NVIDIA did not “issue” NVDAx. Instead, the issuer is an intermediary, such as Backed or a Robinhood SPV.
This type of “secondary securitization” structure is not unfamiliar under traditional securities law. ADRs, SPVs, and derivatives all use comparable structures. Cross-border on-chain arrangements, however, make it more difficult for regulators to trace responsibility.
How should cross-border circulation be regulated? Consider a tokenized Apple stock issued in Switzerland, circulating on Solana, and purchased by users around the world. Does the U.S. SEC have jurisdiction?
The answer is very likely yes, provided that U.S. users have access to it, but the cost of enforcement would be extremely high. This returns directly to the “U.S. user nexus” principle established in the BitMEX case during the second stage. The difference is that the principle must now be applied to a distributed token circulation network rather than a centralized offshore exchange.
How should voting rights and dividends be handled? Under the structures currently used by Backed and Robinhood, tokenholders receive equivalent economic rights, including dividends and buybacks, but do not receive voting rights.
This means that tokenized stocks are fundamentally stripped-down versions of shares. Under traditional securities law, they would be treated as “restricted securities” requiring explicit disclosure. Yet the disclosure documents for most tokenized stock products remain extremely limited.
Completing the Arc: From “Replacement” to “Wrapping”
Placing the ICOs of the first stage alongside the tokenized stocks of the fifth reveals the deepest narrative arc in crypto’s decade-long development.
The promise in 2017: Use tokens to replace stocks, with utility tokens taking the place of corporate equity; use DAOs to replace corporate governance; and use smart contracts to replace legal contracts.
The reality in 2025: Wrap stocks as tokens, including NVDAx and AAPLx; wrap private equity as SPV tokens, such as the “OpenAI token”; wrap U.S. Treasuries as stablecoins and tokenized products, including BUIDL and USYC; and wrap money market funds as “on-chain dollars.”
Tokenization did not replace traditional finance — it learned how to build wrappers for it.
This was the final form produced by the compliance flywheel: crypto became the next generation of infrastructure for TradFi rather than its replacement. This transition also meant that the regulation of crypto increasingly came to resemble the regulation of traditional financial infrastructure.
That, in itself, was the most complete “end state” produced by a decade of compliance evolution.
Conclusion: The Unfinished Evolution of Compliance
Viewed together, the five stages of crypto’s compliance evolution form a recurring spiral.
Each cycle begins with the failure of industry self-regulation. SAFTs failed after the Telegram case. Proof of Reserves failed after FTX and Genesis. Algorithmic stablecoins failed after Terra. Compliance theater failed after Samuel Lim.
The middle of each cycle consists of crisis-driven enforcement and reckoning, including the coordinated actions taken by the SEC, DOJ, CFTC, FinCEN, and OFAC in 2023 and 2024.
The cycle ends with legislative codification through measures such as the GENIUS Act, the CLARITY Act, and MiCA.
Every time the industry believes it has won, the next wave of regulation begins. Every time regulators believe they have brought the industry under control, it moves into another uncharted territory.
But the spiral is far from complete. The compliance questions of the sixth cycle are already visible on the horizon.
The compliance of DeFi. The CLARITY Act provided exemptions for non-custodial protocols, but the Tornado Cash criminal case — the Roman Storm case, in which a jury in the Southern District of New York found him guilty on multiple charges in August 2024 — demonstrated that personal liability for developers remained a sword hanging overhead.
Uniswap received an SEC Wells Notice in February 2024, which was withdrawn in February 2025, but no comprehensive compliance framework for DeFi has yet been established.
The convergence of AI agents and crypto. Autonomous AI trading agents began to be deployed at scale in 2025. Regulators have yet to establish rules governing KYC for “AI as a customer,” the allocation of liability, or market manipulation involving autonomous agents.
The next stage of cross-border regulatory coordination. Differences between MiCA and the GENIUS Act in their definitions of stablecoins, particularly their treatment of foreign issuers, are likely to become a major source of compliance friction over the next three years.
The fundamental tension between privacy and compliance. The principle established in the Van Loon ruling in the Tornado Cash case — that “code is not property” — gave privacy technology a degree of breathing room. Roman Storm’s conviction, however, shifted the boundary back toward individual developer liability.
Emerging technical approaches, including zero-knowledge proofs, Privacy Pools, and compliant mixing protocols, still lack corresponding legal frameworks.
Exactly ten years passed between the first ICO fundraising campaign completed on Ethereum in 2016 and the signing of the GENIUS Act at the White House in 2025.
Over that decade, the crypto industry paid a price of at least hundreds of billions of dollars through market collapses, personal bankruptcies, criminal imprisonment, penalties, and settlements. In return, it obtained a compliance framework that remains imperfect but is becoming increasingly clear.
In one sense, the first act of the story between crypto and regulation only came to an end in 2026.
The protagonists of the next act will not be crypto-native companies, but the traditional financial institutions entering crypto in earnest for the first time: BlackRock, Fidelity, JPMorgan, Goldman Sachs, and State Street.
They will enter with a decade of compliance experience and begin rewriting the rules.
That will be the beginning of another story.
Major Cases and Legislation Referenced in This Article:
SEC Report of Investigation (DAO), Release №81207 (2017); In the Matter of Munchee Inc., Securities Act Release №10445 (2017); SEC v. Telegram Group Inc., 448 F. Supp. 3d 352 (S.D.N.Y. 2020); SEC v. Kik Interactive Inc., 492 F. Supp. 3d 169 (S.D.N.Y. 2020); CFTC v. HDR Global Trading Limited, №1:20-cv-08132 (S.D.N.Y. 2020); United States v. Arthur Hayes et al., №1:20-cr-00500 (S.D.N.Y.); In the Matter of iFinex Inc., NYAG Settlement (2021); In the Matter of Tether Holdings Limited, CFTC Docket №22–04 (2021); SEC v. Terraform Labs Pte Ltd., №1:23-cv-01346 (S.D.N.Y. 2023); In re Three Arrows Capital Ltd., BVI Commercial Court (2022); United States v. Mashinsky, №1:23-cr-00347 (S.D.N.Y.); SEC v. Genesis Global Capital LLC and Gemini Trust Co., №1:23-cv-00287 (S.D.N.Y. 2023); People v. Digital Currency Group et al., NY Sup. Ct. (2023); CFTC v. Changpeng Zhao, Binance Holdings Ltd., and Samuel Lim, №1:23-cv-01887 (N.D. Ill. 2023); United States v. Roman Storm and Roman Semenov, №1:23-cr-00430 (S.D.N.Y. 2023); Van Loon v. Department of the Treasury, 122 F.4th 549 (5th Cir. 2024); United States v. Samuel Bankman-Fried, №1:22-cr-00673 (S.D.N.Y.); United States v. Binance Holdings Limited, №2:23-cr-00178 (W.D. Wash. 2023); SEC v. Binance Holdings Ltd., №1:23-cv-01599 (D.D.C. 2023); SEC v. Coinbase, Inc., №1:23-cv-04738 (S.D.N.Y. 2023); SEC v. Ripple Labs Inc., 682 F. Supp. 3d 308 (S.D.N.Y. 2023); Grayscale Investments, LLC v. SEC, 82 F.4th 1239 (D.C. Cir. 2023); NYDFS Order to Paxos Trust Co. (Feb 13, 2023); GENIUS Act, Pub. L. №119-XX (2025); MiCA, Regulation (EU) 2023/1114; FATF Updated Recommendation 15 (June 2019).
Follow us
Twitter: https://twitter.com/WuBlockchain
Telegram: https://t.me/wublockchainenglish

According to Ransomnews, a dataset published on a data-trading forum contained API keys tied to 659 Stripe merchant accounts, along with roughly 35GB of customer and payment data covering 688,363 customer records. The leak included 650 live secret keys and nine restricted keys. Collector metadata indicated that 573 accounts could accept payments, 531 could make payouts, and 519 had both capabilities, though Ransomnews did not test the keys itself. The outlet said Stripe’s own systems were not compromised and that no full card numbers were present in the dataset.

According to Bloomberg, World Liberty Financial has received conditional approval from the U.S. OCC to establish a national trust bank that could hold assets backing its USD1 stablecoin. The approval comes amid a surge in new U.S. bank charters, with the OCC approving 22 applications in the first 19 months of Trump’s second term, more than in the previous five years combined. World Liberty must still meet capital, governance and audit requirements before receiving final authorization.

Editor：Wu Blockchain
Verified as of August 23, 2026 (ET)——Coverage period: August 24–30, 2026 (ET)
The key events to watch this week:
Tuesday, August 25, 10:00 AM ET | U.S. Consumer Confidence
The release will show whether high interest rates and persistent inflation are further weakening U.S. consumers—and whether household expectations still support the soft-landing narrative.
Wednesday, August 26, 8:30 AM ET | July PCE, Second-Quarter GDP Revision and Durable Goods Orders
This is the week’s most concentrated macro data window. PCE will shape expectations for the Fed’s rate path, while GDP and durable goods orders will test the strength of economic growth and business investment.
Wednesday, August 26, 4:20 PM ET | Nvidia Q2 FY2027 Earnings
Nvidia is expected to release results at approximately 4:20 PM ET, followed by its earnings call at 5:00 PM ET. The key variables are AI compute demand, hyperscaler CapEx, the Blackwell ramp and whether higher memory and supply-chain costs are beginning to pressure margins.
Thursday, August 27, 4:45 PM ET | Marvell Q2 FY2027 Earnings Call
Watch whether demand for custom AI silicon, data center networking and memory infrastructure is translating into stronger revenue growth—and whether the company raises its forward guidance.
August 27–29 | Jackson Hole Economic Policy Symposium
This year’s theme is “Financial Innovation: Implications for Payments and Policy.” Fed Chair Kevin Warsh will deliver the keynote address on Friday, August 28 at 10:00 AM ET, with markets focused on his assessment of inflation and the path of monetary policy.
Friday, August 28, 10:00 AM ET | Preliminary Annual Benchmark Revision to U.S. Payroll Employment
The Bureau of Labor Statistics will use broader administrative employment records to reassess payroll growth through March 2026. A substantial downward revision could change the market’s view of U.S. labor-market strength and shift expectations for the Fed’s next moves.
Bottom line:
This week comes down to two questions—will the Fed lean more hawkish, and how much runway is left for AI demand?

According to official announcements, South Korea’s largest crypto exchange Upbit and second-largest crypto exchange Bithumb designated The Sandbox (SAND) as an investment caution asset on Aug. 24, citing unexplained or unresolved security incidents, including potential hacks involving its wallets or distributed ledger.
Bithumb is expected to review between Sept. 28 and Oct. 2 whether to lift or extend the caution designation or terminate support for SAND trading. The Sandbox is a blockchain-based virtual world and gaming platform where users can create, own and trade digital assets and virtual land.

Stablecoin neobank Fasset has raised $68 million in a funding round led by Japan’s SBI Group at a $1 billion valuation, according to CoinDesk.
The company also raised $51 million in May, bringing Fasset’s total funding this year to $119 million. CEO Mohammad Raafi Hossain said the company processes more than $40 billion in annualized transaction volume across 125 countries, while revenue has grown sixfold year over year.

Tether CEO Paolo Ardoino said on Aug. 23 that USDT adoption is increasing in developing countries including Venezuela, Argentina, Bolivia and Turkey, according to CriptoNoticias.
He said the stablecoin is increasingly used for domestic and cross-border trade, as well as a digital dollar and store of value amid local currency devaluation, dollar shortages and financial restrictions. Cited use cases include import and export settlements in Venezuela, commercial transactions in Bolivia, P2P trading in Argentina and inflation hedging in Turkey.

Ledger CTO Charles Guillemet said a vulnerability in certain clear-signing flows in the Ledger Ethereum app was discovered by Ledger Donjon and fixed two weeks ago.
Users who keep their Ledger firmware and apps up to date are protected. Guillemet also said a self-described “smart contract security” firm disclosed the issue only after the fix was deployed and later implied that it remained unresolved.

Cathie Wood, founder, CEO and CIO of ARK Invest, said that Circle (CRCL) has risen 84% since its IPO, while short-term stock markets still exhibit insufficient pricing efficiency. Visa (V) and Mastercard (MA) have risen approximately 33x and 150x, respectively, since going public in 2006 and 2008, benefiting analysts who recommended “buying the dip.” Wood believes that technology is driving changes in the traditional financial system and that Circle could become a major beneficiary.

Solana validator voting is now live on three governance proposals:
• SGP-0001: The Solana Constitution
• SGP-0002: Increase the disinflation rate from 15% to 30%
• SGP-0003: Restructure transaction fees into a base inclusion fee and a 100% burned resource fee
Voting runs until the end of epoch 1023, approximately 15:30 UTC on Thursday.

Phantom will end support for the Sui network on Sept. 24, 2026. After the transition date, users will no longer be able to view, send, swap or interact with Sui assets in Phantom. The assets will remain onchain and can be accessed through a compatible wallet using the same credentials.

Trump Responds to U.S. Bitcoin Accumulation Plans
On August 19, U.S. President Donald Trump was asked at a White House event with technology industry leaders whether the administration had any plans to accumulate sizable amounts of Bitcoin or other cryptocurrencies.
Trump said the matter had been discussed and that he would likely rely on SEC Chair Paul Atkins and the broader team for their judgment and recommendations. He also said the assets had taken some pressure off the dollar and had been very good for it. However, Trump did not confirm that the U.S. government had decided to increase its holdings.