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Source:Pantera Capital December Blockchain Letter;Compiled by: Bitchain Vision
A year of structural progress
By Erik Lowe, Head of Content at Pantera Capital
Given the expectations for 2025 — finally a pro-crypto government, Gary Gensler’s resignation, potential interest rate cuts — Bitcoin’s 25% rise since the presidential election may feel like a bit of a letdown.In mid-July, Kalshi predicted that the probability of Bitcoin reaching $150,000 in 2025 was 53%
It’s a bit like Peter Thiel’s quote: “They promised us flying cars and we only got 140 characters.”
While BTC prices may not live up to expectations, the cryptocurrency will make more structural progress in 2025 than in any previous year.
Price aside, here’s what we actually got:
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Governments that support cryptocurrencies
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White House chief of staff on artificial intelligence and cryptocurrencies and a working group focused on digital asset markets
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Gary Gensler resigns
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US SEC Chairman Paul Atkins Supports Cryptocurrency
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SAB 121 withdrawn – removing barriers for financial institutions to offer cryptocurrency custody services
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Establishing a U.S. Strategic Bitcoin Reserve and Digital Asset Reserve
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The U.S. SEC has dropped several major cryptocurrency lawsuits.
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Coinbase has been added to the S&P 500 Index – becoming the first cryptocurrency-native company to receive this honor.
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Robinhood launches tokenized stocks
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Stablecoin legislation signed into law
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The Market Structure Bill has passed the House of Representatives
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Solana and XRP ETF
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Nine blockchain companies go public
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Vanguard Group lifts ban on cryptocurrency ETFs, opening trading channels to 50 million customers and $11 trillion in assets.
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US SEC Chairman Paul Atkins announces “innovation exemption” plan for crypto products
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On-chain real world assets (“RWA”) value increased by 235%
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Stablecoin market size increases by $100 billion
From this perspective, we believe that 2025 will be the most important year for the entire industry.This year, we began laying deep foundations to support sustained long-term growth.
Below, Pantera Chief Legal Officer Katrina Paglia dives deeper into these structural developments, providing a comprehensive update on cryptocurrency regulation and policy.
Cryptocurrency Regulation and Policy Updates
By Pantera Chief Legal Officer Katrina Paglia and Platform Manager Andrew Harris
As in previous years, we hope to provide an updated report on key policy and regulatory developments in the crypto-asset space in anticipation of 2025, a year of profound change in U.S. cryptocurrency regulation.The Trump administration has seen an almost complete shift in U.S. cryptocurrency policy and regulation.Actions by regulators such as the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), as well as by the executive branch, suggest that a new, positive path towards cryptocurrencies is taking shape.Below we explore the key administrative, regulatory and legislative initiatives shaping the policy environment in 2025.
President’s Working Group on Digital Assets
Just days after taking office, President Trump signed an executive order aimed at “clarifying” the regulatory rules for crypto assets.The order establishes the “Presidential Task Force on Digital Asset Markets,” chaired by AI and cryptocurrency czar David Sacks and including the Treasury Secretary, the Chairman of the Securities and Exchange Commission, the Chairman of the U.S. Commodity Futures Trading Commission, and the heads of other agencies and departments.
The task force is tasked with reviewing existing regulations and recommending reforms to promote the development of crypto-assets.In July, the task force released a comprehensive report titled “Strengthening U.S. Leadership in Digital Financial Technology.”The report puts forward 100 policy and legislative recommendations on digital asset market structure, banking and digital assets, stablecoins and payments, combating illegal finance, and taxation.Among them, the report distinguishes between security digital assets (regulated by the U.S. Securities and Exchange Commission (SEC)) and non-security 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 discuss below, the SEC and CFTC have already begun taking action to advance the report’s recommendations.
US SEC, Cryptocurrency Working Group and Cryptocurrency Project
Shortly after President Trump took office, then-acting Chairman of the U.S. Securities and Exchange Commission (SEC) Mark Uyeda established a “Cryptocurrency Working Group” within the Commission to “develop a comprehensive and clear regulatory framework” for crypto-assets.The working group, led by Commissioner Hester Peirce, seeks to create a “reasonable regulatory path” that is completely different from the SEC’s previous approach that was mainly led by enforcement actions.
In August, U.S. SEC Chairman Paul Atkins delivered a landmark speech declaring that most crypto-assets were not securities and launched an initiative called Project Crypto.Chairman Atkins outlined five elements of a crypto project:
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Establishing a clear regulatory framework for crypto asset distribution in the United States
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Ensure freedom of choice between cryptocurrency trading venues and cryptocurrency custodians.
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Embrace market competition and promote the development of “super applications” 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.
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Support on-chain innovation and decentralized finance (DeFi).
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Innovation exemption and commercial viability.
ICOs, securities and crypto asset distribution: Is the end of the tunnel here?
The biggest regulatory risk faced by participants in the U.S. cryptoasset market is often whether cryptoassets are securities or whether they are offered to U.S. investors through securities transactions.The U.S. Securities and Exchange Commission (SEC) under previous administrations, as well as under former Chairman Gensler, treated most crypto-assets as securities and pursued a strategy that many viewed as “enforcement regulation” against crypto-asset issuers and other market participants.This regulatory approach has led many crypto asset issuers to move operations overseas, issuing assets through foundations established in the Cayman Islands, Panama or other jurisdictions.Many cryptocurrency exchanges screen U.S. users, and many cryptocurrency companies have limited or completely stopped interactions with U.S. users.
Under the leadership of Chairman Atkins, the US SEC has adopted a completely different approach.The current U.S. SEC has dismissed multiple cases against cryptocurrency platforms and issuers and developed a new, less restrictive set of classification standards that divide crypto assets into four categories:
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Digital commodities whose value is tied to a fully functional decentralized protocol rather than to the commitment of management or the continued efforts of the issuer.
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Digital collectibles or tokens, such as NFTs, are designed to be collected.
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Digital tools that have a practical purpose, such as access rights, credentials or identities.
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Tokenized securities represent traditional securities or financial instruments (e.g., equity or debt) that are still subject to securities laws.
Even before the SEC Chairman announced this quadruple classification, SEC staff had begun to hint at this position through no-action letters and statements.In 2025, SEC staff issued guidance stating that U.S. legal tender stablecoins and memecoins are not securities, and neither are protocol pledges and liquidity pledges.
There is good reason to believe that in 2026, the U.S. SEC will continue to adopt a relatively relaxed attitude towards cryptocurrency regulation and establish regulatory framework elements for the domestic issuance of network tokens and other crypto assets.
The rise of prediction markets
In 2025, prediction markets will emerge and gradually gain recognition from regulatory agencies.Prediction market platforms allow users to express their opinions on real-world outcomes through event-based contracts.These contracts pay the winner the full value, while the loser takes nothing.In a key turning point, Kalshi, one of the earliest operating prediction markets in the United States, won its regulatory battle with the U.S. Commodity Futures Trading Commission (CFTC) and was allowed 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 entering the space (such as Robinhood).While regulatory treatment remains uneven—particularly under certain states’ gambling laws—prediction markets are increasingly viewed as a legitimate financial foundation.In particular, some platforms are exploring tokenization or cryptocurrency implementations to further integrate prediction markets with digital asset infrastructure.Coinbase’s announcement of a partnership with Kalshi highlights a trend that is likely to continue into 2026.
Latest developments in litigation worthy of attention
Dropping of Coinbase and Other Crypto-Related Lawsuits – In 2023, the U.S. Securities and Exchange Commission (SEC) filed major lawsuits against Coinbase in the Southern District of New York and Binance in the District of Columbia, alleging multiple violations, including operating as an unregistered broker-dealer, exchange, and clearing agency, and conducting unregistered securities offerings through their respective staking services.In the first quarter of 2025, the SEC reached joint agreements with Coinbase and Binance to drop all charges against them.
The U.S. SEC also dismissed ongoing enforcement actions against other cryptocurrency market participants, including Kraken, Consensys, Ripple and DRW Cumberland.The SEC noted that the dismissal of these pending enforcement actions is part of the Commission’s ongoing efforts to reform its approach to regulating the cryptocurrency industry and is not based on any assessment of the substance of the allegations.
The U.S. SEC’s newly established Network and Emerging Technology Department – The SEC’s reform of cryptocurrency-related enforcement methods is also reflected in its newly established Network and Emerging Technology Department.The division replaces the Crypto-Assets and Cyber Division, which was previously responsible for taking enforcement actions against a number of high-profile cryptocurrency market participants.The new Cyber and Emerging Technologies unit is expected to focus on fraud and other misconduct, including blockchain-related fraud and fraud 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 environment is real and clear, there are still some regulatory and legislative developments worth keeping an eye on as we head into 2026.Below we highlight some key areas:
“GENIUS Act”– Any discussion of 2025 cannot ignore the Guiding and Establishing National Innovation Act for Stablecoins in the United States (GENIUS Act) – the first major federal cryptocurrency legislation.The bill, passed with bipartisan support, establishes a regulatory framework for “payment stablecoins.”
Under the Act, payment stablecoin issuers are generally limited to: (1) certain U.S. qualified persons who are subject to federal regulation or (for certain issuers) state regulation; or (2) certain non-U.S. qualified persons who are 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 subjects them to bank-like prudential regulatory and consumer protection standards, with the aim of increasing transparency of reserve assets and reducing potential risks.Payment stablecoins do not include “algorithmic” stablecoins, and payment stablecoin issuers will be prohibited from paying interest to stablecoin holders.Consultation on the bill has already begun, and provisions such as a ban on issuers paying interest are likely to spark intense controversy.
Comprehensive Cryptocurrency Legislation——Unlike the GENIUS Act, comprehensive cryptocurrency market structure legislation is still progressing intermittently in Congress.The Digital Asset Market Transparency Act of 2025 (“CLARITY Act” for short) was passed by the House of Representatives with strong bipartisan support in July 2025, but has yet to make progress in the Senate.The CLARITY Act would, among other things, allocate jurisdiction over “digital commodities” to the U.S. Commodity Futures Trading Commission (CFTC) and jurisdiction over “restricted digital assets” to the U.S. SEC.The bill also establishes a temporary registration path until the SEC and CFTC finalize relevant rules, and stipulates that assets can be converted from securities to digital commodities once the network is decentralized.Although the government shutdown has caused the bill’s progress to weaken, expectations are still high for the introduction of comprehensive cryptocurrency legislation in 2026.
Real World Assets, Tokenization and New Frontiers——In 2025, the tokenization process of “real world assets” continues.Unlike “native crypto” assets, tokenization of real-world assets involves putting existing traditional assets on the blockchain and sometimes dividing them.Tokenization involves a wide range of assets, including precious metals or other commodities, government bonds, and private equity fund interests.But a recent proposal submitted by Nasdaq to the U.S. SEC marks tokenization entering a new realm.The request for proposals would allow investors to trade existing equity securities in a tokenized form.The proposal has attracted widespread attention, and the SEC has expressed a willingness to consider requests to trade existing traditionally listed securities in tokenized form.
We will work hard to keep our LPs and the wider community informed of these structural changes and new initiatives as they emerge.We look forward to developments in digital asset policy and regulation in 2026.
