On December 4, CertiK, the world's largest Web3 security company, released the "2025 Skynet U.S. Digital Asset Policy Report," systematically outlining the overall direction of digital asset regulation in the U.S. for 2025. The report indicates that the U.S. has established a relatively clear and systematic regulatory framework for digital assets for the first time, transitioning the U.S. digital asset market from an "exploration phase" to a "systematic stage." As regulatory norms for centralized functions become increasingly clear, code auditing will become a key measure for institutions to ensure security and compliance.
U.S. Federal Regulatory Framework Gradually Taking Shape, Global Landscape Diverging
The issuance of the "GENIUS Act," the passage of the "CLARITY Act" in the House of Representatives, and the SEC's repeal of "Employee Accounting Bulletin No. 121" constitute a new federal regulatory "three pillars." These three initiatives establish federal regulatory standards for stablecoins, principles for classifying digital asset functions, and compliance pathways for banks to conduct custody business. As a result, banks, stablecoin issuers, and interstate institutions now receive systematic guidance for their operational requirements.
As the first federal regulatory system in the U.S. targeting payment stablecoins, the "GENIUS Act" sets systematic requirements for issuance structure, prudential standards, and technical compliance, including 100% liquidity reserves, a prohibition on paying yields to holders, role-based access control (RBAC) for smart contracts, and governance mechanisms for freezing permissions.
At the same time, the report points out that the differences between the U.S. "GENIUS Act" and the EU "MiCA Act" in terms of reserve asset composition and judicial requirements will lead to a future scenario where the stablecoin market presents a "U.S. version" and a "EU version," resulting in a fragmentation of cross-regional liquidity.
Clear Asset Classification, Custody and Accounting Reforms Driving Market Structure Reshaping
The "CLARITY Act" delineates the regulatory boundaries between the SEC and the Commodity Futures Trading Commission (CFTC) based on function: Gas tokens, governance tokens, and other "digital commodities" will fall under CFTC jurisdiction, while tokens intended for financing will remain under SEC regulation. The act clarifies that trading in the secondary market by non-issuers does not constitute a securities offering, thereby reducing potential compliance risks for trading platforms.
Additionally, the Senate's "Responsible Financial Innovation Act" (RFIA) and the "Bipartisan Discussion Draft" provide supplementary pathways for future digital commodity market regulation; the repeal of SAB 121 eliminates a major accounting barrier for large financial institutions entering the digital asset custody business.
Infrastructure and Compliance Technology Upgrades, Code Auditing Becomes a Key Measure for Security and Compliance
The report also highlights the latest developments in clearing and settlement infrastructure, including the regulated liability network (RLN) being tested by the New York Federal Reserve Bank and several large banks, as well as the Monetary Authority of Singapore's "Project Guardian," which promotes global asset tokenization standards. These pilot programs validate the feasibility of tokenized deposits, wholesale central bank digital currencies, and cross-border financial activities, laying the groundwork for future compliant financial infrastructure.
In terms of compliance monitoring, the scope of regulatory technology adoption continues to expand: from using Benford's Law to identify anomalous transactions and employing clustering algorithms to monitor manipulative behavior, to adding freeze function verification in smart contract audits, reflecting an improvement in regulatory agencies' real-time monitoring capabilities of on-chain activities.
Notably, as regulatory norms for centralized functions become increasingly clear, financial institutions' strategic focus is gradually shifting towards permissioned digital assets, with code auditing becoming an important means to ensure institutional security and compliance. This trend is driving the continuous development of the industry.
Regulation Enters a Systematic Stage
Overall, U.S. digital asset regulation in 2025 is transitioning from an "exploration phase" to a "systematic stage," with digital assets steadily integrating into the U.S. financial system. As policy boundaries become clearer, the industry's development focus is shifting from evading regulation to seeking sustainable development solutions within the regulatory framework. Meanwhile, market fragmentation caused by regulatory differences will also become one of the key challenges that institutions need to address.
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