On December 12, 2025, winter in Washington, D.C., was colder than usual.
When Senators Gillibrand and Lummis smiled as they announced at the Blockchain Association Policy Summit that the CLARITY Act was nearing its finale, the applause was sparse. A strange anxiety hung in the air compared to the fervor with which the House passed the bill a few months earlier.
Because everyone understood that inconspicuous footnote in Section 302 of the draft bill—the definition of a “mature decentralized network”.
It is no longer the vague "decentralized enough", but a cold mathematical red line: the token supply or network validation rights controlled by a single entity or affiliate shall not exceed 20%.
This is the sword of Damocles hanging over the trillion-dollar crypto market. Below 20%, you are a "digital commodity," governed by the CFTC, and enjoy free market treatment similar to gold and crude oil; above 20%, you are a "digital security," governed by the SEC, and face stringent audits comparable to those of publicly traded companies, as well as liquidity depletion.
This is not a gift to the crypto industry, but a verdict. Especially for VC coins that are accustomed to the "low circulation, high control" model, the death knell has been tolled.
Today, let's take on the role of the ruthless auditor, wielding this 20% yardstick to examine each of the top 20 crypto assets by market capitalization. Let's see who survives and who is destined to perish on this red line in the 360 days following the bill's enactment.
Based on on-chain data and token distribution models up to December 2025, we divide the Top 20 into "safe zone" and "death zone".
1. The Safe Haven: The Real "Digital Goods"
- Bitcoin (BTC)
- Control percentage: 0% . With Satoshi Nakamoto gone, no entity can control the Bitcoin network. It is the only perfect score candidate on the Clarity Act.
- Ethereum (ETH)
- Control percentage: <1% . The Ethereum Foundation's holdings have long been reduced to negligible levels, and validator nodes are extremely dispersed. Vitalik's personal influence is limited to the spiritual realm and does not cross the legal line of "20% control."
- Dogecoin (DOGE) / Litecoin (LTC)
- Control ratio: close to 0% . As early PoW products, they had no pre-mining, no VC rounds, and no foundation treasury. This "primitive" issuance method, ironically, became the biggest compliance moat in 2025.
2. The Red Zone: Giants that cross the 20% red line.
- XRP (Ripple)
- Risk Level: Extremely High . Despite winning some legal battles, the amount of XRP locked in Ripple's escrow accounts remains substantial under the new standards of the Clarity Act. If the law determines that these tokens are under the "control of a single entity," XRP will not be able to be traded as a commodity and must be registered as a security.
- Binance Coin (BNB)
- Risk Level: Extremely High . While the number of validator nodes on BNB Chain is increasing, its strong connection to the Binance exchange is difficult to sever. Furthermore, the exchange-driven periodic burning mechanism makes it difficult to pass the "decentralization" test.
- TON (The Open Network)
- Risk Level: High . Due to its historical issuance mechanism (early miners concentrated mining), TON's token concentration has always been a regulatory pain point. If it cannot prove the lack of connection between early whale addresses and the foundation, TON will likely face significant regulatory scrutiny.
- Sui / Aptos (Move Gemini)
- Risk Level: Extremely High . This is a typical example of a "VC coin." Looking at Tokenomics, the combined share of the team, investors, and foundation typically exceeds 50%. Even in 2025, a large number of tokens remain locked or under foundation control. They are the most direct targets of the legislation.
- Layer 2 governance tokens (such as ARB, OP)
- Risk Level: Medium-High . Although it touts DAO governance, its "Treasury" typically holds 30%-40% of the tokens. If regulators determine that the core multi-signature manager of the DAO constitutes a "single entity," then these L2 tokens will face securitization risks.
3. The Grey Zone: A Line Between Life and Death
- Solana (SOL)
- The FTX bankruptcy has dumped a large amount of SOL into the market, objectively increasing token decentralization. However, whether the total holdings of the Solana Foundation and its affiliated VCs are below 20% will be the focus of the legal team's negotiation with regulatory agencies.
360 Days of Life and Death Speed
The most brutal design of the CLARITY Act is that it provides a 360-day "grace period".
This sounds like a benevolent buffer, but it's actually a "breeding ground" phase where the market undergoes self-cleansing. From the moment the bill took effect, a countdown clock ticked in the meeting rooms of all high FDV (fully diluted valuation) projects.
We can preview what kind of magical drama will unfold in the market during these 360 days as companies try to reduce their control to below 20%.
Scenario 1: A Massive Airdrop for Survival. For projects genuinely wanting to survive and transform into "digital commodities," the only way is to dilute their holdings. We will most likely witness the largest "reverse liquidity grab" in crypto history—foundations must dump their holdings. This isn't charity; it's survival. Projects will frantically search for reasons to airdrop, fund developers, or even destroy their existing holdings. For airdrop hunters and retail investors, this might be the last hurrah. But this artificially created selling pressure will also drastically reduce the price in the short term.
Scenario Two: "Securification" with a Give-Up Many project teams will find that reducing control to below 20% is tantamount to giving back all the profits they've painstakingly gained from investors. This goes against the nature of capital. Therefore, they will choose another path: acknowledging themselves as securities. But this is not an easy road. Once labeled "digital securities," large, compliant exchanges like Coinbase and Kraken will have to remove them from their main boards, move them to a dedicated "securities zone," or even delist them altogether. This means an instantaneous break in liquidity. Market makers will withdraw, lending protocols will remove collateral eligibility, and these tokens will become zombie assets that only a few qualified investors can trade.
Scenario Three: The "Great Purge" of Exchanges Won't even wait until the 360-day period ends; their legal departments will act ahead of time. To protect their expensive DCE (Digital Commodity Exchange) licenses, exchanges like Coinbase will be even more aggressive in scrutinizing their listing lists than regulators. "Better to kill a thousand innocent people than let one guilty person go free." Those tokens in the gray area, with opaque control, will face a massive delisting wave in the first three months after the law takes effect. Liquidity will irreversibly flow back from Altcoin to Bitcoin and Ethereum.
Outcome: The Gentlemanization of the Crypto Market
Ten years from now, when we look back at this winter of 2025, we will find that the CLARITY Act was a watershed moment for the crypto industry.
Before this, it was the Wild West. If you could write code and tell a story, you could issue a coin, manipulate its price through high-level control, and reap the rewards. The heroes of that era were SBF, Do Kwon, and those anonymous VCs who shill on Twitter.
After that, this became Wall Street's backyard. The 20% threshold completely killed the get-rich-quick myth of "makeshift" operations. The future crypto market will no longer experience wild fluctuations of hundreds or thousands of times; instead, it will be characterized by compliance, auditing, low volatility, and institutional dominance.
The market has been brutally split in two: one half is the "whitelist" (commodities): BTC, ETH, SOL (potentially), which flow in the veins of ETFs and become allocation targets for global pension funds. The other half is the "blacklist" (securities): thousands of Altcoin that fail the 20% test will be driven out of mainstream exchanges and wander in the dark forest of on-chain DEXs, becoming private games for geeks and gamblers.
For ordinary investors, now is not the time for FOMO (fear of missing out), but rather the time to scrutinize balance sheets with a microscope.
Please open your token's browser and check the "Holders" section. If the top 10 addresses collectively account for 50% of the total, and most of them are marked with "Foundation," "Team," or the unnamed "Vest Contract," please check the following:
So, please make your choice before the 360-day countdown reaches zero. Because after that, the door to liquidity will be permanently closed to them.
