The Briefing Memo

October 2025 - If you’re new here, welcome to The Briefing Memo, which features the latest insights and updates from The Venture Dept., the friendly former regulators on the cap table. If this newsletter has been forwarded to you, you can subscribe here.

Regulatory Cooperation is the New Vibe

The biggest development in the US may be the new spirit of cooperation between regulators, an even greater feat that the spirit of engagement and collaboration we’ve already seen between regulators and builders. The SEC and CFTC in particular seem to have turned a corner from being in competition to working together, which is huge for the industry.

• The Joint Harmonization Push: On September 5, the SEC and CFTC leadership issued a joint statement on regulatory harmonization opportunities and followed up with a joint roundtable on September 29. The goal is to stop the regulatory "no man's land" that has held the industry back. They are looking to align things like:

  • Innovation Exemptions/Safe Harbors: Creating clear pathways for new products, including peer-to-peer trading of spot crypto assets over decentralized finance (DeFi) protocols.

  • Market Alignment: Clarifying rules for 24/7 trading, perpetual contracts, and prediction markets, aiming to bring activity that moved offshore back to the US.

  • Streamlined Frameworks: Coordinating capital and margin requirements and harmonizing definitions for products and trading venues.

  • Spot Trading Clarity: Just before the harmonization announcement, the staff of both agencies issued a joint statement that essentially gave a green light. It clarified that, under existing law, registered exchanges aren't banned from listing and facilitating the trading of certain spot crypto asset products. This is a big step in removing long-standing regulatory ambiguity.

• DePIN No Action: The SEC issued a no-action letter for a DePIN token project, signaling that programmatic token rewards tied to real-world infrastructure contributions can fall outside securities-law enforcement when they don’t rely on a central promoter or speculative token sales. The agency emphasized that the token’s value proposition came from participants actually building and operating the network—not from passive investment or a team promising to drive token profits. There goes Howey, choking on an orange seed. Preach, Commissioner Peirce: “The economic reality of DePIN projects differs fundamentally from the capital-raising transactions Congress charged us with regulating.”

Institutional Crypto Adoption is Surging

As we’ve long hoped, TradFi is realizing the future is here.

• Banks Know FOMO. Post-GENIUS, we’re hearing from investors, founders, and advisers that the banks that haven’t put shovels in the ground on stablecoins are feeling late to the party. There are some building and some are buying, including Citi’s investment in BVNK. We’re hearing from multiple sources that from the biggest of the big to the most (literally, for lots of reasons) mid banks (and even the little guys) are trying to build out stablecoin infrastructure and are almost all fighting an uphill battle; engineers and legal staff, among others, are in short supply, because everyone and their mother is hiring them, too. (Our advice to bankers: talk to Omnia).

Global Stablecoin and Payments Progress

It's not just the US. International regulators and financial systems are also moving to integrate blockchain into banking and payments, particularly focusing on stablecoins.

• GENIUS Act Implementation: The Treasury issued an Advanced Notice of Public Rulemaking seeking public comment on how to implement the new U.S. stablecoin framework, including issuer requirements, limits on marketing, AML and sanctions obligations, coordination of state and federal oversight, treatment of foreign issuers, and related tax and insurance topics. Comments are due October 20, 2025. There’s a lot of alpha that can be gleaned from the questions they ask, and we highly recommend reviewing even if you don’t submit a formal comment letter.

• Tokenized Collateral Initiative: In the US, the CFTC officially launched its Tokenized Collateral and Stablecoins Initiative on September 23, seeking public input. This move is all about figuring out how to use tokenized assets, including stablecoins, as collateral in derivatives markets, which could significantly boost efficiency in the financial system.

• UK Regulatory Framework: In the UK, the FCA is moving ahead with its new crypto regulatory regime. On September 17, it published a consultation paper on how existing rules and guidance (like those on governance and senior management) will apply to crypto firms. The aim is to regulate crypto firms much like traditional investment services providers.

• Thailand's Government Stablecoin: Thailand's Finance Ministry is reportedly planning to launch a 10 billion baht stablecoin (~$275 million) backed by government bonds. This initiative is intended to use asset tokenization to make bond investments, which are usually only for institutions, more accessible to retail investors and to improve market liquidity. As we’ve been preaching, tokenizing bonds is step one for a stablecoin, so we’re looking forward to Thailand unlocking.

The Venture Dept. News and Events

The Venture Dept. has been around the world and back recently. In mid-September, Matt was in Rio for Stellar Meridian.

Matt came back to New York to be among the Crypto Cognoscenti for Crypto Prom at the Plaza.

The Venture Dept. was then off to Singapore for Token2049, which attracted some 25,000 conventiongoers (with, we heard, a 1:1 attendee:DJ ratio) and sprouted nearly 900 side events. (You should be tired on our behalf.)

We also co-hosted a series of stablecoin-focused panels at a half-day event, Stable Straits, with our friends at Liminal, Xweave, and Reciprocol. Here are some shots. 

One debate that came up repeatedly: the role of USD stablecoins versus local stablecoins. Our view is that USD stablecoins will account for most issuance for the foreseeable future. However, local stablecoins will represent a growing share of transaction volume. In other words, USD stablecoins will remain the dominant store of value, while local stablecoins will increasingly reflect the share of cross-border trade and payment flows between sending and receiving jurisdictions. Both trends matter. Local stablecoins are especially important for moving beyond the “stablecoin sandwich,” particularly in markets without real-time payment systems, and for realizing the full potential of cross-border stablecoin payments. USD is the reserve stablecoin of choice, with local stablecoins becoming the mechanism for transacting in non-USD economies.

The larger takeaway from our travels in Asia and Latin America is that the excitement over Internet Capital Markets is not just a post-GENIUS US phenomenon. These regions of the world have their own unique energy and flywheel of activity. The size of the pie is getting bigger.

After all that, the team was back in New York, this time at the annual Fordham Blockchain Association Symposium, where SEC Chair Paul Atkins stole the show.

The Latest From Our Founders and Projects

As we move to the end of 2025, a few of our portfolio companies have made progress worth spotlighting. From new launches to scaling milestones, it’s been a strong stretch across the board. We’re proud of the momentum across our portfolio. As always, we’re working alongside founders to provide capital, counsel, and connectivity to help them scale with purpose. In the past we’ve sometimes provided updates for nearly every portfolio company, but given the size of our portfolio is now 20, we think it’s time be a little more targeted and will focus just a few noteworthy developments per newsletter.

• Xweave enables real time & competitive cross-border payments with no locked-up capital. They were selected by the Monetary Authority of Singapore (MAS) as part of Project BLOOM — alongside global leaders including DBS, J.P. Morgan, StraitsX, Circle, Stripe, Temasek, and others.

• Multiliquid enables seamless, 24/7 exchanges of blue-chip real-world assets (RWAs) and stablecoins, across multiple blockchains, at scale. They recently released The Practitioner’s Guide to Real World Assets.

• Haraka provides credit access based on social trust. They recently announced their first product, Bondy, which brings real-world financial access onchain, helping micro-entrepreneurs, freelancers & gig workers build trusted digital reputations and unlock new possibilities.

• Rova is a growth platform where startups activate their users as contributors instead of paying for mercenary contractors. They recently launched Rova Tasks, a marketplace that lets startups turn their real users into paid contributors by completing structured growth tasks such as feedback, content creation, and product testing. It connects projects with engaged users who are rewarded in USDC or tokens for high-quality, authentic contributions that help products grow.

Reading & Listening List (Q3 2025)

This quarter brought a flood of critical reports and discussions that our team found essential for understanding the pivot to regulated digital finance. Here's what we were reading and listening to:

• Market Reads Episode 8 (“Regulated Digital Finance Deep-Dive”). Matt joined the Market Reads podcast for a discussion on recent industry developments. The discussion ranges from Nuvei’s move to power in-vehicle payments for Volkswagen Brazil and Coinbase’s and Mastercard’s race to acquire BVNK, to JPMorgan’s $2B AI investment and Revolut’s ambitions in India. The guests also unpack Aleo and Paxos’s privacy-embedded stablecoin launch, ICE’s $2B stake in Polymarket, and the AI breakthroughs shaping their current thinking.

• State Street Issues 2025 Digital Assets Outlook: Institutions Double Down on Tokenization. This comprehensive report underscored that tokenization is moving from pilot to policy, projecting that 10-24% of institutional investments will be tokenized by 2030. It clearly identifies private markets as the initial focus area, driven by demand for increased transparency and faster settlement speeds.

• SEC Staff Issues No-Action Relief Permitting Use of State-Chartered Trust Companies as Qualified Custodians of Digital Assets. RIAs and registered investment companies may now treat certain state-chartered trust companies as "banks" for the purpose of the SEC's Custody Rule. By qualifying these state entities as "banks," the staff is permitting them to act as "qualified custodians" for clients' crypto assets.

• The Unbundling of Banks: How Stablecoins Change Everything | Charles Calomiris | Bankless. Fascinating dive into the history of banks and how they came to control the current financial ecosystem, and how stablecoins could undo it.

• Stablecoins & the Future of the Financial System | a16z Podcast. How corporate treasuries are adopting stablecoins, why regulatory changes are bringing founders into the space, and the intersection of crypto and AI. This podcast offered a detailed legal perspective on how the newly enacted GENIUS Act will mandate clearer jurisdictional boundaries between the SEC and CFTC. The discussion highlighted the emerging need for harmonization between U.S. and E.U. frameworks to facilitate institutional cross-border trading.