The U.S. digital asset regulatory environment has transformed considerably in 2025 to provide a clearer statutory framework, according to an update from CertiK. New federal legislation and administrative reforms are now more aligned around how digital assets are being issued, traded, and custodied.
CertiK noted that the expected enactment of the GENIUS Act, which awaits final rulemaking and becomes effective in January 2027, and the House passage of the CLARITY Act (which remains subject to legislative evolution), coupled with the Securities and Exchange Commission’s (SEC) rescission of Staff Accounting Bulletin 121 (SAB 121) have “established a three-part framework.”
- A federal standard for payment stablecoins
- A functional classification system for digital assets (commodities vs. securities)
- A clearer operational pathway for bank and trust-company custody
This report from CertiK examines the overall legal mechanics, market-structure impacts, and operational requirements of this new framework and set of guidelines.
It also looks at the remaining fragmentation at the state level (the ‘Preemption Gap’) and shows how a de facto ‘Universal Baseline’ of cybersecurity and AML/CFT expectations now “governs multi-state operators.”
For market participants, this means:
- Banks and trust companies now have a clearer pathway to offer digital asset custody
- Stablecoin issuers face tighter, unified reserve and compliance expectations
- Multi-state operators must plan around a de facto universal baseline of cybersecurity and AML/CFT requirements
The CertiK report added:
“The regulatory developments of 2025 suggest a durable integration of digital assets into the U.S. financial architecture driven by both Federal and State-driven initiatives. For financial institutions, the strategic focus is shifting toward Permissioned Digital Assets: using blockchain-based settlement within clearly defined regulatory perimeters.”
The report concluded that as liquidity becomes segmented by jurisdiction (for instance, between U.S. and EU/MiCA-compliant pools), the “ability to map regulatory ‘gaps’ and build compliant, cross-jurisdictional infrastructure will be a key source of competitive advantage over the next few years.”
