Around the first quarter of 2026 and before May 17, the relationship between crypto assets and traditional finance is not progressing along a clear path, but diverging along two main lines of regulation and holdings. In Japan, a survey conducted by the "Economic News" on 18 major brokerages shows that 11 of them have indicated that they will consider launching crypto investment trusts as long as the Financial Services Agency provides a framework; more aggressive entities, such as SBI Securities and Rakuten Securities, plan to sell funds developed by SBI Global Asset Management that target high liquidity assets like Bitcoin and Ethereum without waiting for detailed rules to be established, effectively preemptively positioning themselves in a regulatory gray area. In Central Europe, the Polish House of Representatives has passed a revised cryptocurrency bill, actively integrating its domestic market into the EU MiCA framework, laying the groundwork for platforms and custodians to obtain licenses in the future. On the other side of the Atlantic, in the United States, debates are ongoing over whether the "Clarity Act" should label crypto assets, with Arthur Hayes openly hoping the bill is vetoed, while VanEck and Grayscale monitor regulatory winds while simultaneously submitting a revision application related to a BNB ETF on the same day, using product filings to test the boundaries of non-Bitcoin assets. As the regulatory paths in Japan, Poland, and the United States unfold different trajectories, institutional positions also start to show a hedging differentiation: Abu Dhabi's sovereign fund Mubadala disclosed in its first quarter 2026 13F filing that its holdings in IBIT increased to approximately 14,721,917 shares, valued at about $566 million, reflecting an increase of approximately 16% compared to the end of 2025; in the same batch of documents, the Harvard University endowment fund chose to liquidate its Ethereum ETF. The differences in risk appetite and regulatory tolerance between sovereign wealth funds and university endowment funds have been concretely reflected in their allocation decisions for Bitcoin and Ethereum, and when this divergence in holdings overlaps with the divergence of regulatory paths in various countries, the positioning of crypto assets in the traditional financial system is quietly being rewritten into a long-term game about "who will regulate, who dares to buy, and which type to buy."
Regulation Not Established, Japanese Brokerages Take the Lead
While the EU has written rules into law with MiCA, Japan remains in a gray area of "clear attitude, lack of details." The Financial Services Agency has yet to provide specific operational guidelines for crypto investment trust products, but roles in the market have already divided into fast and slow lanes. Around the first quarter of 2026, a survey by Japan's "Economic News" of 18 major brokerages found that 11 of them responded with "consider providing related products once the regulatory framework is established," with large institutions like Nomura Securities specifying "regulatory establishment" as a prerequisite. For them, this is not only a firewall against compliance risk but also an excuse to avoid standing on the wrong side at the wrong time.
In contrast, a few players have chosen to "drive first, read the sign later." SBI Securities announced that it would sell a crypto fund developed by its subsidiary SBI Global Asset Management, focusing on high liquidity assets like Bitcoin and Ethereum; Rakuten Securities quickly followed suit, openly stating plans to sell similar crypto investment trust products. Before the rules are fully written out, these two have effectively used product designs to reverse question regulators: to what extent is it permitted, how to disclose information, and how to define suitability obligations. Once such products gain scale in the market, they will naturally become the "compliance entry point" for retail and high-net-worth clients to access crypto assets, forcing the Financial Services Agency to choose between "allowing a few pilot programs" and "rewriting the industry boundaries," while the 11 brokerages that initially planned to wait for notification must reassess whether they are maintaining discipline or handing future clients over to competitors.
Poland Integrates into MiCA, Trading Platforms collectively Pass Security Checks
While Japan's Financial Services Agency is still avoiding clarifying details for new products, Poland has chosen another path: fully integrating its regulatory authority into the EU unified framework. After the House of Representatives passed a revised cryptocurrency bill, Poland's domestic crypto market was formally included under the MiCA framework, meaning that all institutions providing relevant services to Polish clients, from trading platforms to wallet custodians and issuers, are pushed onto a "unified security check" pathway. MiCA requires service providers within member states to obtain licenses and meet minimum capital and corporate governance requirements, and Poland's amendments effectively embedded these terms into its domestic laws, pulling all small platforms that previously survived on "registration" and "filing" into a more regulatory similar permitted system as financial institutions.
For the industry, this is not simply a registration of existing business but a systematic filtration. Polish platforms and custodians need to enhance their capital, risk control, and governance structures during the transition period to continue serving local users under MiCA licensing; crypto companies from other EU countries or third countries that establish a presence in Poland or target Polish customers must consider whether to comply with MiCA standards locally or simply exit the market. Since Poland is a relatively large economy in Eastern Europe, its choice to integrate into MiCA at this time sets a concrete reference for other member states in the region: to quickly convert the EU framework into executable local details or continue allowing the domestic market to operate in a gray area. The real variable lies in whether this round of "collective security checks," starting in Poland, will shrink the regional market down to a few licensed giants or reopen a cleaner licensing landscape for new players willing to bear compliance costs.
U.S. Regulation Pulls the Strings, BNB ETF Amendment Resubmitted
Shifting from the EU's unified framework to the United States, a distinctly different rhythm is evident. The "Clarity Act" has been packaged as a bill to "label" crypto assets, attempting to clearly define which are securities, which are commodities, and which fall into the gray area. But while legislation is still in discussion, Arthur Hayes has publicly opposed it, overtly stating hopes for the bill's veto, arguing that crypto assets can survive in an unregulated environment. Legislators are attempting to "write clear rules," while industry veterans advocate "maintaining wildness"; the debate in the U.S. is not about whether rules are needed but about how detailed and rigid they should be, and whether completing them locks innovation into a compliance cage.
Amidst this tug-of-war, VanEck and Grayscale have chosen to answer the question in another way: they submitted a revision application related to the BNB ETF product to regulators on the same day. What specifically was changed or which regulatory comments were addressed remains unknown to the external world, but the "same day resubmission" itself is a stance—issuers are no longer betting on a single pass, but adjusting structures and disclosures repeatedly according to narratives accepted under the existing framework, testing whether tokens issued by trading platforms can be packaged into ETF shells for the public market. The outcome is still pending, but the boundaries are beginning to emerge: on the legislative level, whether the "Clarity Act" should clearly categorize such assets; on the product level, whether the BNB-related ETF can be accepted will jointly determine whether exchange tokens and the U.S. public market are completely isolated or whether there is a high-cost but viable compliance channel.
Mubadala Increases Holdings in IBIT, Harvard Sells Out of Ethereum
While BNB-related ETFs are still being tugged within regulatory gaps, the holdings table on the other end of the 13F has already presented a more direct multiple-choice question. According to disclosures from the first quarter of 2026, Abu Dhabi's sovereign wealth fund Mubadala holds approximately 14,721,917 shares in IBIT, valued at about $566 million, reflecting an increase of about 16% compared to approximately 12.7 million shares at the end of 2025. For an institution backed by national capital, this is not about "sampling," but is using a Bitcoin ETF with transparent disclosures and mature trading rules to access a crypto exposure that has already been "tamed" under the U.S. regulatory framework. The 13F quarterly mandatory disclosure transforms this step from internal asset allocation decisions into a public statement to regulators and the market: sovereign capital is willing to continue to increase its bets on the clearest and most liquid crypto vehicle under regulation.
Turning the lens to Cambridge, Harvard University's endowment fund, in the same batch of 13F documents, shows that it has liquidated its positions in Ethereum ETFs. The brief does not disclose whether this was due to risk assessment, strategy adjustment, or liquidity demand. The contrasting documents—one increasing and one decreasing—reflect the differences in institution types: sovereign wealth funds carry long-term allocation tasks at the national level, placing greater importance on the alignment with the existing regulatory system; Bitcoin ETFs have already provided a compliance department-explainable template in terms of rules, custody, and auditing; while university endowment funds must justify to their boards, alumni, and the public. Regarding assets still under regulatory classification disputes, they are more inclined to view exposures as tactical positions that could be entered or exited. The result is that within the same domain of crypto assets, Mubadala opts to increase its weight along the regulatory comfort of Bitcoin ETFs, while Harvard preemptively withdraws from Ethereum ETFs, and this divergence in holdings is itself silently redrawing an invisible boundary: Bitcoin is being regarded as a "institutionalizable" crypto asset by some large institutions, while other assets remain in a gray area where regulatory and reputational risks cannot be hedged.
Various Regulatory Tracks, Institutions Choose Their Camps
While Japan is still waiting for the Financial Services Agency to draw that final line for crypto investment trusts, SBI Securities and Rakuten Securities have already chosen to step in first, while Nomura and others remain on the sidelines watching. This is a typical "actively exploring" path: details are lacking, but the market probes regulatory limits through products; Poland, on the other hand, moves towards another end, directly attaching its domestic market to the EU MiCA framework, with legislation proceeding first and a specific implementation timeline lagging, forming a model of "integration into a unified framework"; while across the Atlantic, the debate in the U.S. surrounding the "Clarity Act" continues to ignite, with Arthur Hayes openly opposing strengthened regulation, while VanEck and Grayscale keep revising the filing documents for BNB-related ETFs, responding to regulatory inquiries through product design. This route resembles a long slope of "continue debating": legal labels have not yet been firmly attached, and the market and regulation tug at each other’s boundaries on case by case basis. On these three tracks, sovereign funds and university endowment funds also make their choices: Mubadala leverages IBIT to further increase its Bitcoin ETF positions by about 16% in a quarter, willing to bet more capital on an asset narrative that is relatively clear in regulation; Harvard endowment fund chooses to liquidate its Ethereum ETF holdings, separating the larger uncertain exposure from its balance sheet. This divergence in holdings, rather than reflecting price judgments, can be seen as a vote on different regulatory pathways: some prefer to stand only on the asset side quickly accepted by regulations, while others would rather withdraw from varieties whose technological routes and regulatory prospects have not yet aligned. The true suspense lies in when the Financial Services Agency in Japan will drop the hammer on investment trust guidelines, when Poland will provide a timeline for implementing MiCA locally, the trajectory of the "Clarity Act" in Congress, and the final review outcomes for BNB-related ETFs, all of which could redefine global market compliance boundaries in the coming quarters. Before this round of games truly settles, regulators and institutions can only accelerate on their chosen tracks while being ready to pay the price for the next boundary redefinition.
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