Digital Assets Infrastructure Update W51-2025

What Changed: On December 11-12, 2025, the Office of the Comptroller of the Currency conditionally approved five de novo and conversion applications for national trust bank charters. Circle's First National Digital Currency Bank and Ripple National Trust Bank received de novo approvals; BitGo, Fidelity Digital Assets, and Paxos received conditional conversions from state to federal charters. This follows OCC guidance in November 2025 (Interpretive Letter 1186) allowing banks to holdA misspelling of 'hold,' used to mean holding onto cryptocurrency for long-term gains blockchainA decentralized, digital ledger of transactions maintained across multiple computers tokens for operational fees and testing.

Why It Matters for Infrastructure: This removes institutional custody barriers at the federal level. Banks can now holdA misspelling of 'hold,' used to mean holding onto cryptocurrency for long-term gains ETHA decentralized blockchain platform that enables smart contracts and decentralized applications, SOLA high-performance blockchain known for fast transactions and low fees, and other network-native tokens for transactionA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger settlement without violating capital rules. It operationalizes Ripple and Circle as federally regulated digital asset custodians—shifting stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold infrastructure from fringe to core banking. Federal supervision creates audit trails, compliance frameworks, and risk stacks that institutions require. The charter pathway signals durable regulatory acceptance, not temporary tolerance. This is risk-stack evolution that enables bank balance sheets to directly support on-chainA decentralized, digital ledger of transactions maintained across multiple computers operations.

What Changed: On December 8, 2025, the CFTCU.S. federal agency regulating derivatives markets including crypto commodity futures announced a three-month pilot program allowing futures commission merchants (FCMs) to accept BitcoinThe first decentralized cryptocurrency, created in 2009 by Satoshi Nakamoto (BTC), Ether (ETHA decentralized blockchain platform that enables smart contracts and decentralized applications), and payment stablecoins (notably USDCA fully-reserved stablecoin pegged 1:1 to the US Dollar, issued by Circle and backed by regulated financial institutions) as margin collateral in US futures and swaps markets. Simultaneously, the CFTC issued technology-neutral guidance permitting tokenized representations of traditional assets (Treasuries, money market funds) to be used in derivatives markets under existing regulatory frameworks. The agency formally withdrew Staff Advisory No. 20-35, which had previously restricted digital asset collateral usage.

Why It Matters for Infrastructure: This action opens the institutional derivatives markets—the largest liquid markets globally—to digital asset-backed collateral, creating a direct on-rampA service that converts fiat money into cryptocurrency for blockchainA decentralized, digital ledger of transactions maintained across multiple computers-native settlement into regulated derivatives infrastructure. The technology-neutral guidance permits tokenized Treasuries and money market funds to be treated identically to their non-tokenized equivalents, materially reducing compliance complexity for issuers and eliminating a regulatory barrier to institutional tokenizationConverting real-world assets into digital tokens on a blockchain. The pilot program's requirement for weekly FCM reporting enables real-time market monitoring while establishing operational norms for digital asset margin.

What Changed: On December 15, 2025, J.P. Morgan Asset Management announced the launch of My OnChain Net Yield Fund (MONY), a tokenized money market fund operating on the public Ethereum blockchainA decentralized blockchain platform that enables smart contracts and decentralized applications. The fund invests exclusively in US Treasury securities and Treasury-backed repurchase agreements, offering qualified investors daily dividend reinvestment and the ability to subscribe and redeem using either cash or stablecoins through Morgan Money, the firm's institutional liquidityThe ease with which an asset can be bought or sold without affecting its price trading platform.

Why It Matters for Infrastructure: This is the first tokenized money market fund launched by a global systemically important bank on a public blockchainA decentralized, digital ledger of transactions maintained across multiple computers, establishing institutional cash settlement as a blockchain-native practice. The mechanism eliminates friction between stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold holding and yield generation, enabling peer-to-peer transferability and broader collateral usage within on-chain financial ecosystems. This signals to the market that public blockchains are now operationally viable for institutional fixed-income settlement, and executives at J.P. Morgan stated they expect other GSIBs to follow, creating a multiplier effect across institutional treasury operations.

What Changed: On December 11, 2025, State Street and Galaxy announced SWEEP (State Street Galaxy Onchain LiquidityThe ease with which an asset can be bought or sold without affecting its price Sweep Fund), a tokenized private liquidity fund using PayPal's PYUSDA stablecoin issued by PayPal and Paxos, pegged 1:1 to the US Dollar and designed for payments and transfers stablecoins for 24/7 on-chainA decentralized, digital ledger of transactions maintained across multiple computers cash management. Initial Ondo Finance investment of $200 million provides capitalisation. The fund launches on SolanaA high-performance blockchain known for fast transactions and low fees in early 2026, with planned Chainlink cross-chainThe ability of different blockchain networks to communicate and work together seamlessly integration to EthereumA decentralized blockchain platform that enables smart contracts and decentralized applications and Stellar.

Why It Matters for Infrastructure: This demonstrates institutional adoption of programmable liquidityThe ease with which an asset can be bought or sold without affecting its price on public blockchains. State Street is the world's largest custody provider by assets. Its deployment on SolanaA high-performance blockchain known for fast transactions and low fees (not a private chainA decentralized, digital ledger of transactions maintained across multiple computers) signals custodial comfort with public settlement rail speed and cost economics. Using PYUSDA stablecoin issued by PayPal and Paxos, pegged 1:1 to the US Dollar and designed for payments and transfers directly couples liquidity management to regulated stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold infrastructure. This unlocks capital markets on-chain for alternative assets (private equity, real estate, private credit) that traditionally demanded T+N settlement and high friction. Cross-chainThe ability of different blockchain networks to communicate and work together seamlessly interoperability via Chainlink extends institutional adoption across multiple L1s simultaneously.

What Changed: On December 16, 2025, Visa announced that US issuer and acquirer partners can now settle VisaNet obligations directly in Circle's USDCA fully-reserved stablecoin pegged 1:1 to the US Dollar, issued by Circle and backed by regulated financial institutions stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold over the SolanaA high-performance blockchain known for fast transactions and low fees blockchainA decentralized, digital ledger of transactions maintained across multiple computers. The program has achieved a $3.5 billion annualised run rate as of November 30, 2025. Initial participants include Cross River Bank and Lead Bank. Visa is additionally serving as a lead design partner for Circle's Arc blockchain and plans to operate a validatorA participant in a Proof of Stake network responsible for verifying new blocks nodeA computer that participates in a blockchain network by validating and relaying transactions once Arc launches.

Why It Matters for Infrastructure: This represents the integration of stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold settlement rails into the world's largest payment networkInfrastructure and networks that enable money transfer between parties's operational backbone. Banks and fintechs gain access to near-instant funds movement, seven-day-a-week settlement (versus traditional three-day T+3 or weekend delays), and improved liquidityThe ease with which an asset can be bought or sold without affecting its price predictability without any change to consumer-facing payment experiences. The deepening infrastructure integration—Visa operating as Arc validatorA participant in a Proof of Stake network responsible for verifying new blocks—materially shifts capital-efficiency incentives and custody flows for institutional payment operations.

What Changed: On December 12, 2025, ADI ChainA decentralized, digital ledger of transactions maintained across multiple computers (Abu Dhabi's sovereign digital infrastructure initiative) announced strategic partnerships with BlackRock, Mastercard, and Franklin Templeton. BlackRock will provide tokenized Treasury collateral and BUIDL fund integration; Mastercard will deliver stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold payment railsInfrastructure and networks that enable money transfer between parties and cross-border settlement infrastructure; Franklin Templeton will contribute tokenized money market fund technology. The partnerships position ADI Chain as a regulated bridgeA connection between two blockchains that allows the transfer of assets or data between Gulf liquidityThe ease with which an asset can be bought or sold without affecting its price and Western institutional blockchain infrastructure.

Why It Matters for Infrastructure: This signals sovereign-level adoption of Western institutional blockchainA decentralized, digital ledger of transactions maintained across multiple computers standards in the Gulf region. ADI Chain's regulatory framework—developed with UAE Central Bank oversight—creates a compliant pathway for cross-border stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold settlement and tokenized asset flows between MENA and G7 markets. The BlackRock/Mastercard/Franklin Templeton consortium provides institutional credibility and operational infrastructure that smaller Gulf blockchain initiatives have lacked. For global institutions, this creates a regulated on-rampA service that converts fiat money into cryptocurrency for Gulf capital into tokenized Treasury markets and vice versa.

What Changed: On December 14, 2025, Intuit announced a partnership with Circle to integrate USDCA fully-reserved stablecoin pegged 1:1 to the US Dollar, issued by Circle and backed by regulated financial institutions payment railsInfrastructure and networks that enable money transfer between parties into QuickBooks, Mailchimp, and Credit Karma. The integration enables 8 million+ small and medium businesses to send and receive stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold payments natively within existing accounting and invoicing workflows. QuickBooks users can generate USDC invoices, accept USDC payments, and automatically reconcile stablecoin transactionsA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger within their general ledgerA record of financial transactions.

Why It Matters for Infrastructure: This is the largest fintech stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold integration by user baseCoinbase's Ethereum Layer 2 network using Optimism's OP Stack, designed for low-cost, high-speed transactions with Coinbase ecosystem integration, embedding programmable money into the operational backbone of American small business. The accounting automation—automatic USDCA fully-reserved stablecoin pegged 1:1 to the US Dollar, issued by Circle and backed by regulated financial institutions-to-fiatTraditional government-issued currency, such as USD, EUR, or NIS conversion, real-time reconciliation, tax basis tracking—removes friction barriers that have limited stablecoin adoption outside crypto-native businesses. For the broader ecosystem, Intuit's integration validates stablecoin settlement as enterprise-grade infrastructure, not a crypto novelty. The Mailchimp integration additionally enables stablecoin payouts for creator economy and gig worker payments.

What Changed: On December 13, 2025, the Office of the Comptroller of the Currency issued Interpretive Letter #1188 clarifying that national banks may conduct "riskless principal" stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold transactionsA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger without additional capital charges. Under riskless principal treatment, banks acting as intermediaries in stablecoin buy/sell transactions—where positions are immediately offset—face zero market risk capital requirements. The letter builds on OCC guidance from November 2025 (ILA temporary loss experienced when providing liquidity in DeFi due to price changes in paired assets #1186) and aligns with Basel Committee standards for agency-style crypto intermediation.

Why It Matters for Infrastructure: This removes a key balance-sheet barrier to bank stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold intermediation. Previously, banks faced uncertainty about capital treatment for stablecoin market-making and brokerage activities, limiting participation to custody-only models. The riskless principal framework enables banks to offer stablecoin trading services with capital efficiency comparable to traditional FX intermediation. For institutional clients, this means access to bank-grade stablecoin liquidityThe ease with which an asset can be bought or sold without affecting its price with counterparty credit quality and regulatory oversight that non-bank market makers cannot provide.