Source: Pantera Capital December Blockchain Letter ; Translated by: Jinse Finance
A year of structural progress
Author: Erik Lowe, Head of Content, Pantera Capital
Considering the expectations for 2025—a government that finally supports cryptocurrency, Gary Gensler's resignation, and potential interest rate cuts—Bitcoin's 25% rise since the presidential election might seem somewhat disappointing. Meanwhile, in mid-July, Kalshi predicted a 53% probability that Bitcoin would reach $150,000 by 2025.
This is somewhat similar to Peter Thiel's famous quote: "They promised us flying cars, and we got 140 characters."
While BTC prices may not meet expectations, cryptocurrencies have made more structural progress in 2025 than in any previous year.
Putting the price aside for now, here's what we actually received:
Governments that support cryptocurrencies
White House Director of Artificial Intelligence and Cryptocurrency Affairs and a Working Group Focused on Digital Asset Markets
Gary Gensler resigns
Paul Atkins, the U.S. SEC chairman who supports cryptocurrencies
SAB 121 was repealed—removing a barrier for financial institutions to provide cryptocurrency custody services.
Establishing a US strategic Bitcoin reserve and digital asset reserve
The U.S. Securities and Exchange Commission (SEC) has dropped several major cryptocurrency lawsuits.
Coinbase has been included in the S&P 500 index—becoming the first cryptocurrency-native company to receive this honor.
Robinhood launches tokenized shares
Stablecoin legislation has been signed into law.
The Market Structure Act has been passed by the House of Representatives.
Solana and XRP ETF
Nine blockchain companies went public
Vanguard Group lifted its ban on cryptocurrency ETFs, opening up trading access for 50 million customers and $11 trillion in assets.
U.S. Securities and Exchange Commission Chairman Paul Atkins announced an "innovation exemption" program for crypto products.
The value of on-chain real-world assets (“RWA”) increased by 235%.
The stablecoin market size increased by $100 billion.
From this perspective, we believe 2025 will be the most important year for the entire industry. In this year, we will begin laying a deep foundation to support sustained long-term growth.
Below, Pantera's Chief Legal Officer, Katrina Paglia, will delve deeper into these structural developments, providing a comprehensive overview of the latest developments in cryptocurrency regulation and policy.
Cryptocurrency Regulation and Policy Updates
Authors: Katrina Paglia, Chief Legal Officer, and Andrew Harris, Platform Manager, Pantera
As in previous years, we aim to provide an updated report on key policy and regulatory developments in the crypto asset space as we approach 2025—a year of profound change for U.S. cryptocurrency regulation. The Trump administration's inauguration has brought about a near-complete transformation in U.S. cryptocurrency policy and regulation. Actions by regulators such as the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), as well as by the executive branch, indicate that a new, positive path for cryptocurrencies is emerging. Below, we explore the key administrative, regulatory, and legislative initiatives shaping the policy environment in 2025.
Presidential Digital Assets Working Group
Just days after taking office, President Trump signed an executive order aimed at “clarifying” the regulatory rules for crypto assets. The order established the “Presidential Task Force on Digital Asset Markets,” chaired by AI and cryptocurrency czar David Sacks, with members including the Treasury Secretary, the Chairman of the Securities and Exchange Commission, the Chairman of the Commodity Futures Trading Commission, and heads of other agencies and departments.
The working group's mission is to review existing regulations and propose reforms to promote the development of crypto assets. In July, the working group released a comprehensive report entitled "Strengthening U.S. Leadership in Digital Financial Technologies." This report made 100 policy and legislative recommendations on digital asset market structure, banking and digital assets, stablecoins and payments, combating illicit finance, and taxation. Notably, the report distinguishes between security-type digital assets (regulated by the U.S. Securities and Exchange Commission (SEC)) and non-security-type digital assets (regulated by the U.S. Commodity Futures Trading Commission (CFTC)). This marks a significant shift from the SEC's policy during the Biden era, when the SEC treated most crypto assets as securities.
As we will discuss below, the U.S. Securities and Exchange Commission and the U.S. Commodity Futures Trading Commission have begun taking action to advance the recommendations of the report.
U.S. SEC, Cryptocurrency Working Group, and Cryptocurrency Projects
Shortly after President Trump took office, then-acting chairman of the U.S. Securities and Exchange Commission (SEC), Mark Uyeda, established a “Cryptocurrency Task Force” within the commission, aiming to “develop a comprehensive and clear regulatory framework” for crypto assets. Led by Commissioner Hester Peirce, the task force sought to create a “rational regulatory path,” a departure from the SEC’s previous approach, which was primarily driven by enforcement actions.
In August, U.S. SEC Chairman Paul Atkins delivered a landmark speech, announcing that most crypto assets are not securities and launching a project called "Project Crypto." Chairman Atkins outlined five key elements of Project Crypto:
Establishing a clear regulatory framework for the distribution of crypto assets in the United States
Ensure freedom of choice between cryptocurrency exchanges and cryptocurrency custodians.
Embrace market competition and promote the development of "super apps," through which platforms and intermediaries can offer a range of crypto services and assets (including securities and non-securities) under a single, efficient licensing structure.
Supports on-chain innovation and decentralized finance (DeFi).
Innovation exemption and commercial viability.
ICOs, Securities and Crypto Asset Distribution: Have We Reached the End of the Tunnel?
The biggest regulatory risk facing participants in the US cryptocurrency market often lies in whether crypto assets are securities or offered to US investors through securities transactions. The previous administration and the Securities and Exchange Commission (SEC) under former Chairman Gensler treated most crypto assets as securities and adopted a strategy widely seen as "enforcement regulation" towards cryptocurrency issuers and other market participants. This approach led many cryptocurrency issuers to move their operations overseas, issuing assets through foundations established in the Cayman Islands, Panama, or other jurisdictions. Many cryptocurrency exchanges screened US users, and many cryptocurrency companies restricted or completely ceased interaction with US users.
Under Chairman Atkins, the U.S. SEC has taken a radically different approach. The current SEC has dropped numerous cases against cryptocurrency platforms and issuers and developed a new, less restrictive classification standard, dividing crypto assets into four categories:
Digital goods are valued based on fully functional decentralized protocols, rather than on management promises or the issuer’s ongoing efforts.
Digital collectibles or tokens, such as NFTs, are designed for people to collect.
Digital tools with practical applications, such as access permissions, credentials, or identity features.
Tokenized securities represent traditional securities or financial instruments (such as equity or debt) that are still subject to securities laws.
Even before the SEC chairman announced this four-tier classification, SEC staff had already begun hinting at this position through no-action letters and statements. In 2025, SEC staff issued guidance stating that U.S. fiat stablecoins and memes are not securities, nor are protocol staking and liquidity staking.
There is good reason to believe that the U.S. SEC will continue to adopt a relatively lenient approach to cryptocurrency regulation in 2026 and establish regulatory framework elements for the issuance of online tokens and other crypto assets within the country.
The Rise of Prediction Markets
In 2025, prediction markets emerged and gradually gained regulatory approval. Prediction market platforms allow users to express their views on real-world outcomes through event-based contracts. These contracts pay out the full value to the winners, while the losers receive nothing. A key turning point came when Kalshi, one of the earliest operating prediction markets in the United States, won its regulatory battle with the Commodity Futures Trading Commission (CFTC) and was granted permission to operate as a designated contract market regulated by the CFTC, offering contracts related to elections and other events.
Since Kalshi's victory, interest in prediction markets has grown rapidly, with more platforms receiving federal approval and traditional financial and consumer platforms (such as Robinhood) entering the field. Despite uneven regulatory treatment—particularly under gambling laws in some states—prediction markets are increasingly being seen as a legitimate financial foundation. Of particular note are the exploration by some platforms of tokenization or cryptocurrency implementations, further driving the integration of prediction markets with digital asset infrastructure. Coinbase's announcement of a partnership with Kalshi underscores this trend, which is likely to continue until 2026.
Latest developments in noteworthy litigation
Lawsuits against Coinbase and other cryptocurrency-related entities dropped—In 2023, the U.S. Securities and Exchange Commission (SEC) filed major lawsuits against Coinbase in the Southern District of New York and against Binance in the District of Columbia, alleging multiple violations, including operating as an unregistered broker-dealer, exchange, and clearinghouse, and conducting unregistered securities offerings through their respective staking services. In the first quarter of 2025, the SEC reached separate joint agreements with Coinbase and Binance, dropping all charges against them.
The U.S. Securities and Exchange Commission (SEC) also rejected ongoing enforcement actions against other cryptocurrency market participants, including Kraken, Consensys, Ripple, and DRW Cumberland. The SEC noted that rejecting these pending enforcement actions was part of the Commission's ongoing efforts to reform its approach to regulating the cryptocurrency industry and was not based on any assessment of the substance of the allegations.
The U.S. Securities and Exchange Commission (SEC) has established a new Cyber and Emerging Technologies Division—a reform of the SEC's approach to cryptocurrency enforcement. This division replaces the previous Crypto Assets and Cyber Division, which was responsible for enforcement actions against several prominent cryptocurrency market participants. The new Cyber and Emerging Technologies Division is expected to focus on fraud and other misconduct, including blockchain-related fraud and fraud perpetrated using emerging technologies such as artificial intelligence and machine learning.
Outlook: New Developments in Cryptocurrency Regulation under the Trump Administration
While the shift in the cryptocurrency policy landscape is real and clear, there are still some regulatory and legislative developments worth watching closely as we head into 2026. Below, we highlight some key areas:
The GENIUS Act —the Directing and Establishing National Innovation for Stablecoins in the United States Act (GENIUS Act)—cannot be ignored in any discussion about 2025, and it is the first major federal legislation on cryptocurrency. Passed with bipartisan support, the bill establishes a regulatory framework for “paying with stablecoins.”
Under this bill, issuers of payment stablecoins are generally limited to: (1) certain U.S. qualified persons subject to federal regulation or (for some issuers) state regulation; or (2) certain non-U.S. qualified persons registered with the Office of the Comptroller of the Currency (OCC) and subject to a similar regulatory regime (as determined by the Secretary of the Treasury). The bill imposes licensing requirements on issuers and complies them with prudential supervision and consumer protection standards similar to those for banks, aiming to increase transparency of reserve assets and reduce potential risks. Payment stablecoins do not include “algorithmic” stablecoins, and issuers of payment stablecoins will be prohibited from paying interest to stablecoin holders. Public comment on the bill has been initiated, and provisions such as the prohibition on issuers paying interest are likely to be highly controversial.
Comprehensive Cryptocurrency Legislation— Unlike the GENIUS Act, comprehensive cryptocurrency market structure legislation continues to progress intermittently in Congress. The Digital Asset Market Transparency Act of 2025 (CLARITY Act) passed the House of Representatives in July 2025 with strong bipartisan support, but has yet to make progress in the Senate. Among other things, the CLARITY Act assigns jurisdiction over the regulation of “digital goods” to the Commodity Futures Trading Commission (CFTC), while jurisdiction over the regulation of “restricted digital assets” is assigned to the Securities and Exchange Commission (SEC). The bill also establishes a temporary registration pathway until the SEC and CFTC finalize their rules and stipulates that assets can be converted from securities to digital goods once the network achieves decentralization. Although the government shutdown has slowed the bill's progress, there are still high expectations for comprehensive cryptocurrency legislation to be enacted in 2026.
Real-World Assets, Tokenization, and New Frontiers – In 2025, the tokenization of "real-world assets" continues. Unlike "native crypto" assets, the tokenization of real-world assets involves placing existing traditional assets on the blockchain, sometimes in a fractional form. Tokenization involves a wide variety of assets, including precious metals or other commodities, government bonds, and private equity fund interests. However, a recent proposal submitted by Nasdaq to the U.S. SEC marks a new frontier for tokenization. This proposal requests that investors be allowed to trade existing stock securities in tokenized form. This proposal has attracted widespread attention, and the SEC has indicated its willingness to consider the request to trade existing traditional listed securities in tokenized form.
We will strive to keep our LPs and the wider community informed about these structural changes and emerging initiatives. We look forward to developments in digital asset policy and regulation in 2026.
