RESEARCH MEMO · Digital Finance × Regulated On-chain Finance
Tokenized Finance Is Entering Regulated Market Infrastructure
SEC × ECB: From On-chain Markets to Multi-Money Settlement | Research Memo | 22 September 2026
Listed companies discussed: Circle Internet Group (NYSE: CRCL) | Coinbase Global (NASDAQ: COIN)
The SEC has opened a controlled secondary-trading path for eligible tokenized NMS stock, while Eurosystem Pontes connects wholesale tokenized assets to central-bank-money settlement. ACIS view: tokenization is moving from experimentation into financial infrastructure, but value will be shared across assets, money, settlement, compliance and distribution—not automatically captured by one stablecoin or RWA token.
Term of the SEC's temporary conditional relief
Eurosystem launch of the initial Pontes service
Expected full implementation of Pontes
01 · RESEARCH BRIEF
The one-minute brief
Two developments moved in the same direction while addressing different layers of finance. The SEC issued five-year temporary conditional relief for limited secondary trading in eligible tokenized NMS stock. The Eurosystem launched the initial version of Pontes, enabling wholesale tokenized assets to settle in central-bank money. Together, they show traditional finance redesigning both how assets trade and how trades settle. This is not broad market opening and does not prove scaled commercial adoption. It raises the probability of institutional implementation; actual volume, repeat usage, fees and revenue conversion remain the next tests.
Audio transcript
On-chain finance received two different entry points this week. First, the SEC issued five-year temporary conditional relief allowing limited secondary trading in eligible tokenized NMS stock. Participants must be permissioned, while smart contracts must be public, auditable and deployed on a public permissionless distributed ledger. Second, the Eurosystem launched the initial version of Pontes, connecting wholesale tokenized assets with central-bank-money settlement. Together, the developments show traditional finance redesigning both asset trading and cash settlement. But this is not blanket approval and it does not prove commercialization is complete. ACIS believes the probability of tokenization entering regulated financial infrastructure is rising. Future value will not belong to one stablecoin alone; it will be shared across assets, money, settlement, compliance and distribution. The next evidence is concrete: the first operating venues, actual Pontes settlement volume, repeat usage, durable fees and eventual conversion into public-company revenue and free cash flow.
Known facts and open questions
- Confirmed
- The SEC relief covers limited secondary trading in eligible tokenized NMS stock.
- Confirmed
- The Eurosystem launched Pontes and an initial group completed onboarding.
- Still open
- First venues, settlement volume, repeat usage, sustainable fees and public-company revenue contribution.
Assets
Eligible tokenized stocks, funds, Treasuries and deposits enter programmable markets.
Money
Private stablecoins, tokenized bank deposits and central-bank money coexist by use case.
Connectivity
Trading, settlement, custody, identity, compliance and distribution connect assets to money.
| Form of money | Best-fit use | Core advantage | Still unproven |
|---|---|---|---|
| Private stablecoins | Cross-border payments, public-chain liquidity and always-on internet commerce | Open distribution, programmability and existing liquidity | Regulatory scope, reserve quality and durable economics |
| Tokenized bank deposits | Bank customers, corporate treasury and regulated deposit systems | Client relationships, identity controls and balance-sheet integration | Interbank interoperability and real adoption |
| Central-bank-money settlement | Regulated wholesale securities and institutional final settlement | Low credit risk and settlement finality | Asset coverage, operating hours, cost and actual volume |
02 · FACTS → IMPACT → VIEW
Why does this change matter?
Tokenized finance now has institutional entry points at both trading and settlement
- What is confirmed
- The SEC has created a limited secondary-trading route for eligible tokenized NMS stock, while the Eurosystem has put the initial Pontes service into operation.
- Why it matters
- The former addresses how regulated assets can trade; the latter addresses how wholesale tokenized assets can settle in central-bank money. Together, they reduce institutional market-structure and settlement friction.
- ACIS view
- On-chain finance is moving from blockchain experiments toward regulated market infrastructure, but the process remains constrained, layered and gradual. Value is more likely to spread across assets, money, settlement, compliance and distribution.
03 · EVIDENCE & ANALYSIS
Evidence and analysis
01｜What did the SEC do?
On 17 September, the SEC issued five-year temporary conditional relief allowing eligible Tokenized Securities Venues to use permissioned automated-market-maker liquidity pools for limited secondary trading in tokenized NMS stock. Participants must be permissioned, while smart contracts must be public, auditable and deployed on a public, permissionless distributed ledger.
02｜This is not blanket approval of tokenized equities
The relief excludes primary issuance and synthetic stocks and imposes limits on the number of securities and trading volume. A venue must also notify the issuer before listing stock tokenized by an unaffiliated third party, and the issuer may object. This is a controlled route, not an immediate migration of all securities on-chain.
03｜What does Eurosystem Pontes change?
On 21 September, the Eurosystem launched the initial Pontes service, linking market DLT platforms with TARGET Services so wholesale tokenized-asset transactions can settle in central-bank money. Initial banks, public institutions and market infrastructures have completed onboarding. Features and operating hours will expand gradually, with full implementation expected by 2028.
04｜Why do the two developments matter together?
Institutional tokenized markets need both a lawful, controlled trading entry point and a final settlement asset acceptable to large financial institutions. The United States is addressing market structure; Europe is addressing central-bank-money settlement. They are separate systems, but jointly raise the probability that tokenized finance becomes mainstream infrastructure.
05｜Competition is broader than USDT versus USDC
Private stablecoins, bank-issued stablecoins, tokenized deposits and central-bank-money settlement may all coexist. The research question therefore shifts from which coin wins to who controls assets, money, settlement, compliance and distribution. Interoperability, identity and compliance become more valuable as the system fragments.
06｜Commercialization is still incomplete
New rules and settlement rails improve feasibility; they do not create revenue automatically. The first venue operating notices remain to be seen, recurring Pontes volume and fee economics are undisclosed, and growth in stablecoins or RWA has not proved that any one protocol or token can capture durable value.
04 · INVESTMENT IMPLICATIONS
Industry and asset implications
Circle / USDC
The structural direction is validated, but wholesale settlement will not necessarily use private stablecoins. Payment volume, distribution revenue, the proposed Tazapay closing and unit economics remain the tests.
Coinbase
Trading, custody, wallets and infrastructure may benefit, but neither the SEC nor ECB materials identify the company as a participant. Real volume and fee revenue are the relevant evidence.
Commercial banks
Tokenized deposits and bank stablecoins bring client relationships, identity controls, balance sheets and traditional distribution. Cross-institution adoption and sustained settlement volume remain unproven.
RWA platforms
The asset-tokenization thesis strengthens, but assets under management do not automatically become protocol revenue, free cash flow or token-holder value.
Connectivity and compliance
More forms of digital money and tokenized assets raise the importance of oracles, identity, compliance, custody and cross-system settlement. The ability to charge remains the key test.
This memo discusses industry structure and listed-company research implications. It is not a recommendation to trade securities, stablecoins or other digital assets.
05 · VALIDATION & RISKS
What to watch next
Next 7–30 days
Watch for the first Tokenized Securities Venue operating notice, eligible securities and issuer responses.
What would weaken the view: No qualified venue enters operation, or issuers broadly object to third-party tokenization.
Next 30–90 days
Track the first Pontes transactions, asset classes, settlement volume, new participants and operating hours.
What would weaken the view: Participant lists expand without verifiable repeat transactions.
Commercial proof
Look for repeat usage, repeat volume, durable fees and identifiable revenue contribution.
What would weaken the view: Activity remains confined to pilots and one-off projects.
Stablecoin distribution
Monitor regulatory approval and closing of Circle's proposed Tazapay acquisition, USDC mix and incremental network revenue.
What would weaken the view: The deal is delayed, customers leave or payment scale fails to convert into USDC usage and revenue.
What would change our view?
The regulated on-chain-finance thesis would progress more slowly if venues fail to launch, Pontes volume remains low, institutions favor closed tokenized-deposit systems, or compliance and interoperability costs offset efficiency gains. Even if the industry grows, value capture can diverge sharply across Circle, Coinbase, RWA platforms and individual tokens.
06 · FAQ
Key questions
Has the SEC broadly approved tokenized stock trading?
No. It issued five-year temporary conditional relief for limited secondary trading in eligible tokenized NMS stock, with security, volume, participant and disclosure conditions.
How can permissioned participants use a public permissionless ledger?
Permissioning governs who may enter the trading pool. The underlying ledger can still be public and permissionless. The order requires smart contracts to be public, auditable and deployed on such a ledger.
Is Pontes a new stablecoin or the retail digital euro?
Neither. It is a wholesale settlement solution linking tokenized-asset transactions to central-bank money and TARGET Services, not a consumer wallet.
Does this guarantee a benefit for USDC?
No. Open internet payments and cross-border distribution may suit USDC, while regulated wholesale securities may use central-bank money or tokenized bank deposits.
Where could Coinbase benefit?
Potential areas include trading, custody, wallets and institutional infrastructure. That is an investment inference, not a role confirmed in the official documents, and requires volume and fee proof.
Does RWA growth imply RWA tokens will rise?
No. Asset scale, protocol revenue, cash flow and token-holder rights must be analyzed separately. Industry adoption is not evidence of value capture.
What would constitute real commercialization?
Sustained clients, repeat volume, durable fees, visible cost economics and a contribution that reaches public-company revenue or free cash flow.
07 · TERMS & SOURCES
Terms, sources and related research
Key terms
- NMS stock
- A U.S.-listed equity traded in the National Market System; the relief applies only to eligible tokenized NMS stock.
- Tokenized Securities Venue
- A venue operating under the relief that brings together trading in tokenized NMS stock through permissioned AMM liquidity pools.
- Permissioned AMM
- An automated market maker in which access is restricted to approved participants while smart contracts execute pricing and liquidity rules.
- Pontes
- The Eurosystem solution linking market DLT platforms with TARGET Services for wholesale settlement in central-bank money.
- Central-bank money
- Money issued or recorded by a central bank and used for final settlement with minimal credit risk.
- Tokenized deposits
- A distributed-ledger representation of commercial-bank deposits that remains a bank liability.
- Interoperability
- The ability of different ledgers, assets, forms of money and institutional systems to exchange information and complete transactions safely.
- Token value capture
- Whether industry growth translates into economic rights, revenue or cash flow for token holders rather than usage alone.
[1] U.S. SEC | Temporary conditional exemptive order | 17 September 2026 ↗
[2] U.S. SEC | Innovation Exemption press release | 17 September 2026 ↗
[3] ECB | Eurosystem launches Pontes | 21 September 2026 ↗
[4] ECB | Pontes project overview ↗
[5] Circle | Definitive agreement to acquire Tazapay | 8 September 2026 ↗
[6] Coinbase | Stablecoin capabilities for community banks with Moov | 10 September 2026 ↗
Evidence boundary: regulatory and settlement facts come from official SEC and ECB materials. The implications for Circle and Coinbase are ACIS research inferences; neither company is designated by the SEC or ECB documents as a participant or beneficiary. A regulatory path, a live system and commercial adoption are three distinct stages.