On May 20, 2026, P2P.org hosted a live practitioner roundtable on institutional digital asset infrastructure. The panel brought together Alexander Loktev, CRO at P2P.org (Moderator), Pavel Jakovlev, Head of Product Growth and Innovation at AMINA Bank, John Hallahan, Director of Business Solutions and Advisory EMEA at Fireblocks, and Patrick Delaney, CEO at Ampli.
The conversation covered five topics:
The technology works. That is no longer the question. What is holding institutions back in 2026 is the layer underneath. Compliance teams interpreting the same regulation differently, internal stakeholders who can block a deal at the last stage, operational models that were not built for onchain at scale, and reporting infrastructure that most institutions are still building in arrears.
John Hallahan opened with a diagnosis that shaped the rest of the conversation.
“The key issue is never technical. Where it breaks down is across three different areas: policy - the operational burden of approval processes and whitelisting; the operating model - unstaking, monitoring slashing risk, reconciling rewards; and the regulatory piece - in some jurisdictions staking is interest, in others it is a service fee. Compliance teams want to see that mapped before anything is signed off.”
- John Hallahan, Fireblocks
Pavel confirmed it from the bank side. AMINA Bank has been operationalising staking across ten protocols for several years, using a delegation model with infrastructure partners including P2P.org. The work is unglamorous and ongoing.
“We want to make sure that our clients' funds are segregated, we know exactly who we are interacting with, we minimise smart contract risk as much as possible, and the funds are not commingled. Same rules apply. We just have to replicate them onchain.”
- Pavel Jakovlev, AMINA Bank
Patrick added a dimension specific to agentic capital management. The security architecture around agent permissions is where institutions consistently underestimate the complexity.
“Session keys that control the permissions of the agents are often stored on some centralised server. You have a huge risk silo where everything is in one place, and if that gets compromised, the attacker would have control over everything.”
- Patrick Delaney, Ampli
The through-line across all three answers is the same: the gap between an institution receiving internal approval to go onchain and actually going live is larger than most expect, and almost none of it is explained by the technology.
The compliance discussion produced the clearest illustration of where the industry actually is on regulation. MiCA is in place. It is working. And it has not resolved the questions that matter most to compliance teams inside regulated institutions.
“What MiCA provides is a very clear framework around authorisation. The licensing perimeter is very clear. But every tier one that we work with is interpreting MiCA's staking provisions in a slightly different way. Accounting treatment, capital treatment, how staking is characterised - those are still being worked out on an institution-by-institution basis.”
- John Hallahan, Fireblocks
AMINA Bank is a useful case study in what operating under MiCA actually requires. The bank serves European clients through its Austrian entity, which introduces hard product constraints. USDT and Ethena's USDe cannot be offered to European clients under the current framework. Every new product goes through a multi-stakeholder sign-off process spanning compliance, technology, and jurisdictional review across Europe, Hong Kong, and Abu Dhabi simultaneously.
Switzerland, where AMINA holds its primary banking licence, has a longer regulatory history with digital assets. The DLT Act predates MiCA by several years, and AMINA’s compliance team is in active dialogue with FINMA on innovations including zero-knowledge proof frameworks that could allow regulators to verify wallet history and source of funds without compromising client privacy. That is the direction the regulatory frontier is moving - not more restriction, but more sophisticated verification.
The practical implication for anyone selling into or operating within regulated institutions: MiCA compliance at the infrastructure layer does not close the compliance conversation internally. It opens it.
The go-to-market section was the most commercially direct part of the session. John's framing was unambiguous.
“No one person can make a single decision to buy, but any of them can literally block the deal.”
- John Hallahan, Fireblocks
Fireblocks works with over one hundred banks. The patterns are consistent. Two things kill late-stage deals. The first is internal alignment failure. The CISO and procurement are the most frequent blockers. Getting the CISO team comfortable with the risk basis of staking - a very different product from custody - is a step that cannot be skipped.
The second is scope creep. A bank aligns on custody and staking. Then at the eleventh hour, someone wants to add a stablecoin project, a tokenisation initiative, and a DeFi proof of concept.
“If you are renegotiating the scope of things late stage, that is where deals can fall apart.”
- John Hallahan, Fireblocks
Pavel added the internal knowledge dimension. Pockets of expertise do not always communicate across large organisations. The technology built in 2018 could be optimised, but doing so would require rebuilding everything from scratch - a decision most institutions are not positioned to make, and one most infrastructure providers are not helping them think through.
The network selection discussion moved quickly past which chains are technically capable and into how institutions actually make the call.
“To launch an offering and be competitive as an institution, you need to cover all the major staking protocols that you can get on a Revolut or a Robinhood or an eToro, or else you are not going to be competitive. Then the validator partner choice flows quickly to unit economics.”
- John Hallahan, Fireblocks
Pavel described AMINA’s internal process: customer requests trigger reviews, the top 100 to 200 networks are always tracked, and specific ecosystems get deeper reviews when client demand signals are strong enough. He highlighted Hyperliquid as the most interesting current case.
“I have never seen more fanatical - in a good way - alignment across token holders, users, and developers. Most of our customers do not sell Hype. They just acquire it and keep it.”
- Pavel Jakovlev, Amina Bank
The practical consequence is that clients are now requesting staking against Hype assets with the ability to borrow against them, which requires LST infrastructure and a rethink of how bonding and unbonding periods interact with lending products. The Hyperliquid example matters beyond the specific ecosystem: it illustrates what institutional protocol selection actually responds to - not network fundamentals in the abstract, but demonstrated user behaviour that creates specific product requirements on the institutional side.
Patrick raised the broader paradox this creates: DeFi was built to eliminate middlemen, and now banks are using it on behalf of clients. Alexander offered a reframe:
“Agents give a feeling that it is me. When I interact with DeFi through my agentic ecosystem, it feels like I am working directly with the end product, passing all the middlemen. In reality, we are just moving all the middle players into an infrastructural layer where they interact through APIs with the agentic world. But from the user perspective, that is how it feels - and that matters.”
- Alexander Loktev, P2P.org
Alexander opened the reporting section with a framing that applies across the full product stack. Staking is increasingly a commoditised product. Custody was commoditised before it. DeFi will be commoditised. The decisions clients make between infrastructure providers are increasingly driven by the operational services built around the core product - and reporting is at the top of that list.
“Two or three years ago, clients were fine getting just a list of logs and onchain records. With the scaling of their staking operations, that stopped working. What they strictly require today is explanation.”
- Alexander Loktev, P2P.org
John confirmed it from the infrastructure side. Fireblocks acquired TRES Finance specifically because regulated entities were pulling blockchain data but could not get it into standard accounting formats.
“If you are a regulated entity doing quarterly reporting, that accounting audit reconciliation offering is now a core part of the infrastructure stack. It is going to be pretty much non-negotiable.”
- John Hallahan, Fireblocks
Pavel was direct about what AMINA’s regulatory position requires. The bank goes through both internal and external audits regularly. On occasion, the regulator comments on punctuation. The scrutiny is not going to decrease as the product set expands into DeFi and more complex earn structures.
Patrick described an emerging reporting dimension specific to agentic systems. The requirement is not just a log of what happened onchain - it is a log of intent versus execution: what did the agent propose, did it comply with the client's policy engine, was it approved or rejected and why. As institutions begin to explore agentic capital management, the reporting layer will need to account for the decision chain, not just the transaction record.
Key Takeaways
The closing question - what do institutions consistently get wrong when going onchain for the first time - produced four answers worth remembering:
“Move slow on exposing yourself to risk, but move quickly in terms of familiarising yourself with the infrastructure. Eventually this is not going to be DeFi. It is going to be finance. You will be left behind if you brush it off as that crypto thing.”
- Patrick Delaney, Ampli
“Build your infrastructure and your operating model for where you think you are in five years, not your first use case. We have seen many early movers on the banking side who are now re-platforming. Build the stack for your strategy five years from now.”
- John Hallahan, Fireblocks
“I was speaking with a bank that banks other banks. They told me they know how to move billions onchain and the systems are good. They have not figured out how to move trillions yet. So once they do that, they will start moving. It is coming.”
- Pavel Jakovlev, Amina Bank
“Make your first step very small, but make it as soon as you can. At P2P.org, when we hire people, we give them a hardware wallet with a small amount and ask them to stake, unstake, and withdraw. It brings non-web3 people into the web3 world within a single day. They lose the stigma.”
- Alexander Loktev, P2P.org
The replay is available here. P2P.org is a non-custodial validator infrastructure provider trusted by 190+ institutional clients, operating across 40+ networks with $10B+ in assets under validation and seven years of zero slashing events.
Policy frameworks, internal approval processes, and regulatory interpretation - not technical complexity. The technology is largely solved. The operational layer underneath it is where institutions get stuck.
MiCA provides the licensing and authorisation framework, but accounting treatment, capital treatment, and product scope are still interpreted differently by each institution's compliance team. MiCA compliance at the infrastructure layer does not close the internal compliance conversation.
Internal alignment failures - typically the CISO or procurement team raising concerns - and scope creep, where an institution expands requirements significantly during the negotiation phase.
Client demand first, unit economics second. EVM-compatible chains, Solana, and Cosmos are the practical shortlist for most regulated institutions. New networks get added following formal reviews triggered by specific client requests.
Translating onchain activity into standard accounting formats, maintaining complete audit trails, and for agentic systems, logging agent intent versus execution so every capital movement can be traced back to the authorisation that triggered it.
This article is provided for informational purposes only and does not constitute legal, regulatory, compliance, or investment advice. Regulatory obligations may vary depending on jurisdiction and specific business activities. Readers should consult their own legal and compliance advisors regarding applicable requirements
<h2 id="series-defi-dispatch">Series: DeFi Dispatch</h2><p>DeFi Dispatch is <a href="http://p2p.org/?ref=p2p.org">P2P.org</a>'s twice-monthly roundup of DeFi developments for institutional participants. Each edition covers the signals that matter for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams operating at the intersection of traditional and on-chain finance.</p><p>👉 Subscribe to our newsletter at the bottom of this page to receive a monthly summary of the latest DeFi and staking developments, curated for institutional participants.</p><p>Missed the previous edition? Catch up here: <a href="https://p2p.org/economy/defi-dispatch-defi-news-may-2026-issue-1">DeFi Dispatch: DeFi News and Signals May 2026 (Issue 1)</a></p><hr><h2 id="quick-learnings-for-busy-readers">Quick Learnings for Busy Readers</h2><p>Short on time? Here are the key takeaways. For the full analysis, continue reading below.</p><p>The second half of May brought five developments that institutional participants in DeFi and staking infrastructure should track closely.</p><ul><li>The CLARITY Act cleared the Senate Banking Committee with a bipartisan 15-9 vote on May 14, advancing the most consequential piece of U.S. digital asset market structure legislation to the Senate floor and moving the legal classification of staking as a non-securities activity closer to statute.</li><li>BlackRock filed for two new tokenized Treasury products with the SEC on May 8, including an on-chain share class for a $7 billion money market fund, marking a formal shift from tokenization experimentation to structured, SEC-reviewed architecture.</li><li>JPMorgan filed for JLTXX, its second Ethereum-based tokenized money market fund, on May 12, specifically designed to serve as compliant reserve assets for stablecoin issuers under the GENIUS Act.</li><li>The tokenized RWA market crossed $34.5 billion in May 2026, up more than 100% year-on-year, with private credit overtaking Treasuries as the single largest non-stablecoin RWA segment for the first time.</li><li>Remaining Ethereum staking ETF amendments from Fidelity, Franklin Templeton, Invesco, 21Shares, and VanEck are expected to clear their final SEC review windows in Q2 2026, creating a market dynamic where non-staking Ethereum ETFs become structurally inferior products.</li></ul><h2 id="whats-driving-defi-markets-in-the-second-half-of-may">What's driving DeFi markets in the second half of May?</h2><p>The second half of May 2026 reflects a market where institutional capital is no longer waiting for regulatory clarity before committing to on-chain infrastructure. Within the span of a few days, the Senate advanced the most consequential digital asset legislation in U.S. history, the world's two largest asset managers filed competing tokenized Treasury products on Ethereum, and the tokenized RWA market crossed $34.5 billion with a structural shift in which asset class is leading growth. The signal is consistent across every story in this edition: the infrastructure layer is being built now, by the institutions that will depend on it.</p><p>Below, we break down five key developments and why they matter for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams.</p><h3 id="story-1-clarity-act-clears-senate-banking-committee-with-bipartisan-vote"><strong>Story 1: CLARITY Act Clears Senate Banking Committee With Bipartisan Vote</strong></h3><p>The Senate Banking Committee advanced the Digital Asset Market Clarity Act to the Senate floor with a bipartisan 15-9 vote on May 14, the most significant legislative milestone for U.S. crypto market structure in years. Two Democrats voted in support alongside all Republicans on the panel, with several more indicating they might support the bill on the floor with further amendments. The bill defines which digital assets fall under SEC jurisdiction as securities and which fall under CFTC jurisdiction as commodities, ending the enforcement-by-ambiguity framework that has kept institutional capital on the sidelines for a decade.</p><p>The remaining obstacle is the ethics provision, which would limit government officials from profiting from the crypto industry. Democrats have made clear they will not advance the bill without it, while White House advisers have rejected any language that singles out a specific officeholder. Cody Carbone, who leads the Digital Chamber, told reporters that resolving the ethics provision before the floor vote is the most likely path to clearing the 60-vote threshold required for Senate passage.</p><p><strong>Why is this important for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams?</strong></p><ul><li>Committee passage converts the March 17 SEC-CFTC joint interpretation classifying staking as a non-securities activity from persuasive guidance into a bill with a clear path to statute, providing durable legal certainty that cannot be reversed by a future administration</li><li>The decentralization threshold test in the bill, which determines whether a token shifts from SEC to CFTC jurisdiction, is the operative mechanism that institutional compliance departments will use to classify staking programs and DeFi vault deployments</li><li>For staking product managers building multi-chain programs, the bill's DeFi exclusion provisions directly protect non-custodial validator infrastructure and distributed validator technology operators from intermediary registration requirements</li></ul><p>Source: <a href="https://www.coindesk.com/policy/2026/05/14/clarity-act-clears-u-s-senate-committee-on-its-way-to-a-final-test-in-congress?ref=p2p.org" rel="noreferrer">CoinDesk</a>, ABA Banking Journal, May 2026.</p><h3 id="story-2-blackrock-files-for-two-new-tokenized-treasury-products-on-ethereum">Story 2: BlackRock Files for Two New Tokenized Treasury Products on Ethereum</h3><p>BlackRock filed for two new tokenized Treasury-linked products with the SEC on May 8, extending the institutional architecture it has been building since the BUIDL fund launch in March 2024. The first is the BlackRock Daily Reinvestment Stablecoin Reserve Vehicle, a tokenized fund designed to hold cash, short-term U.S. Treasuries, and overnight repo agreements backed by Treasuries. The second adds an on-chain share class for the BlackRock Select Treasury Based Liquidity Fund (BSTBL), a money market fund managing nearly $7 billion in assets, with BNY Mellon maintaining official ownership records on Ethereum using ERC-20 token standards.</p><p>The filings represent a structural shift. BlackRock is not testing tokenized assets — it is proposing a formal, SEC-reviewed architecture that turns short-term Treasuries and money market funds into on-chain cash equivalents. By mid-May 2026, BUIDL's assets under management had reached approximately $2.5 billion, and the broader tokenized U.S. Treasury sector stood at around $11 billion, with the overall RWA market surpassing total value locked on decentralized exchanges for the first time.</p><p><strong>Why is this important for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams?</strong></p><ul><li>BlackRock filing for on-chain share classes for a $7 billion money market fund signals that tokenized Treasury infrastructure is moving from pilot product to core cash management architecture for the world's largest asset manager</li><li>The BSTBL filing's use of BNY Mellon and Ethereum ERC-20 standards establishes a custody and settlement template that competing asset managers and custodians will reference when building their own on-chain product architectures</li><li>As tokenized money market funds become standard institutional cash management tools, the Ethereum validator infrastructure settling those transactions faces the same reliability expectations applied to traditional clearinghouses</li></ul><p>Source: <a href="https://www.coindesk.com/markets/2026/05/08/blackrock-files-for-tokenized-treasury-products-on-ethereum?ref=p2p.org" rel="noreferrer">CoinDesk</a>, CryptoTimes, <a href="https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=blackrock&type=N-1A&ref=p2p.org" rel="noreferrer">SEC filings</a>, May 2026.</p><h3 id="story-3-jpmorgan-files-for-jltxx-its-second-tokenized-money-market-fund-on-ethereum"><strong>Story 3: JPMorgan Files for JLTXX, Its Second Tokenized Money Market Fund on Ethereum</strong></h3><p>JPMorgan filed with the SEC on May 12 to launch the JPMorgan OnChain Liquidity-Token Money Market Fund, ticker JLTXX, its second tokenized fund on Ethereum following the December 2025 launch of MONY. The fund will invest exclusively in short-term U.S. Treasuries with maturities of 93 days or less and fully collateralized overnight repurchase agreements, maintaining a stable $1.00 net asset value and operating through JPMorgan's Kinexys Digital Assets platform. JLTXX issues Token Class Shares on Ethereum while maintaining traditional book-entry ownership records in parallel, structured to comply with SEC Rule 2a-7 and stablecoin reserve requirements under the GENIUS Act.</p><p>The positioning of JLTXX as reserve infrastructure for stablecoin issuers is the architectural detail that distinguishes it from MONY. Where MONY targeted institutional cash management for qualified investors, JLTXX is engineered to serve as the compliant reserve asset layer for the growing number of banks and technology firms seeking to issue stablecoins under the GENIUS Act framework. Tokens are transferable peer-to-peer with near-instant settlement, and investors can use them as collateral across markets.</p><p><strong>Why is this important for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams?</strong></p><ul><li>JPMorgan's second tokenized fund in five months signals that the largest U.S. bank has moved from evaluating on-chain infrastructure to actively building the product architecture that institutional stablecoin issuers will depend on</li><li>JLTXX's explicit design for GENIUS Act compliance means that Ethereum validator infrastructure settling these transactions is now embedded in the reserve management stack for regulated stablecoin issuance</li><li>The combination of BlackRock's BSTBL and JPMorgan's JLTXX filings in the same week establishes a competitive dynamic among the largest traditional finance institutions for on-chain cash management infrastructure, with Ethereum as the primary settlement layer</li></ul><p>Source: <a href="https://www.coindesk.com/markets/2026/05/12/jpmorgan-files-for-second-tokenized-money-market-fund-on-ethereum?ref=p2p.org" rel="noreferrer">CoinDesk</a>, CryptoTimes, <a href="https://www.banklesstimes.com/jpmorgan-jltxx-tokenized-money-market-fund-ethereum?ref=p2p.org" rel="noreferrer">BanklessTimes</a>, SEC filing, May 2026.</p><h3 id="story-4-tokenized-rwa-market-crosses-345-billion-as-private-credit-overtakes-treasuries">Story 4: Tokenized RWA Market Crosses $34.5 Billion as Private Credit Overtakes Treasuries</h3><p>The tokenized real-world asset market crossed $34.5 billion in May 2026, up more than 100% year-on-year, with private credit overtaking tokenized Treasuries to become the single largest non-stablecoin RWA segment for the first time. Tokenized U.S. Treasuries climbed to $15.2 billion, with BlackRock and Circle leading inflows, while the broader market growth reflects a structural shift from yield-seeking institutional capital moving beyond government securities into private market exposure that was previously inaccessible on-chain. Standard Chartered projects the tokenized asset market to reach $30 trillion by 2034.</p><p>The legal architecture underpinning current institutional RWA adoption marks a clear break from earlier attempts. RWA tokens now carry registered securities status, are subject to Investment Company Act oversight, and have defined custody arrangements with traditional custodians maintaining book-entry records in parallel with on-chain balances. Ethereum remains the dominant network, hosting over 56% of all tokenized asset value as of mid-May 2026, with its deep DeFi ecosystem allowing tokenized assets to be used as collateral in lending protocols and integrated into structured products.</p><p><strong>Why is this important for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams?</strong></p><ul><li>Private credit overtaking tokenized Treasuries signals that institutional capital is moving up the complexity curve on-chain, from simple yield instruments to structured credit products that require more sophisticated validator and settlement infrastructure</li><li>Ethereum hosting 56% of all tokenized asset value means that Ethereum validator performance, uptime, and slashing risk management are now directly relevant to the operational reliability of the fastest-growing segment in institutional finance</li><li>Standard Chartered's $30 trillion projection by 2034 provides the long-range demand context for why validator infrastructure investments made today carry multi-decade relevance for institutions building on-chain capital programs</li></ul><p>Source: <a href="https://news.bitcoin.com/tokenized-rwa-market-crosses-34-5-billion-private-credit-overtakes-treasuries?ref=p2p.org" rel="noreferrer">Bitcoin.com News</a>, <a href="https://yellow.com/news/tokenized-rwa-market-2026?ref=p2p.org" rel="noreferrer">Yellow.com</a>, <a href="https://www.coingecko.com/research/publications/tokenized-rwa-report-2026?ref=p2p.org" rel="noreferrer">CoinGecko RWA Report</a>, May 2026.</p><h3 id="story-5-remaining-ethereum-staking-etf-amendments-set-to-clear-sec-in-q2-2026">Story 5: Remaining Ethereum Staking ETF Amendments Set to Clear SEC in Q2 2026</h3><p>The remaining staking amendments from Fidelity, Franklin Templeton, Invesco, 21Shares, and VanEck are expected to clear their final SEC review windows in Q2 2026, following the approval of BlackRock's ETHB and Grayscale's Ethereum Staking ETF earlier in the year. Once all amendments are approved, every major spot Ethereum ETF will offer staking, creating a market dynamic where non-staking products become structurally inferior — same underlying exposure with no yield. Capital would logically migrate toward staked versions, accelerating the supply dynamics unique to proof-of-stake ETFs.</p><p>The mechanism is architecturally distinct from Bitcoin ETFs. Every ETH staked through an ETF is ETH that cannot be sold immediately. The exit queue for unstaking takes days to weeks, creating a structural supply reduction that has no equivalent in Bitcoin ETF structures. Total Ethereum ETF inflows reached an estimated $12.94 billion in 2025, and analysts at Bitwise maintain that structural demand from regulated financial products will likely absorb new issuance of approximately 960,000 ETH annually throughout the second half of 2026.</p><p><strong>Why is this important for asset managers, custodians, hedge funds, ETF issuers, exchanges, and staking teams?</strong></p><ul><li>Full approval of staking amendments across all major Ethereum ETFs would concentrate institutional ETH capital into staking-integrated products, creating a sustained demand driver for validator infrastructure that grows with ETF AUM rather than being tied to spot price performance</li><li>The structural supply reduction from ETF staking lockups creates a market dynamic with no Bitcoin precedent, making Ethereum validator capacity planning a more complex and strategically important exercise for infrastructure providers</li><li>For ETF issuers and custodians still operating non-staking Ethereum products, the Q2 approval window creates an urgent operational timeline for integrating validator relationships and redemption mechanics before the competitive disadvantage becomes visible to allocators</li></ul><p>Source: <a href="https://techi.com/2026/05/ethereum-staking-etf-amendments-sec-q2-2026?ref=p2p.org" rel="noreferrer">TECHi</a>, <a href="https://kappasignal.com/2026/05/bitwise-ethereum-staking-etf-inflows-analysis?ref=p2p.org" rel="noreferrer">Bitwise via Kappa Signal</a>, May 2026.</p><h2 id="key-takeaways-for-asset-managers-custodians-hedge-funds-etf-issuers-exchanges-and-staking-teams">Key Takeaways for Asset Managers, Custodians, Hedge Funds, ETF Issuers, Exchanges, and Staking Teams</h2><p>The second half of May 2026 surfaces five converging signals for institutional participants in on-chain infrastructure:</p><ul><li>The CLARITY Act clearing the Senate Banking Committee with bipartisan support moves the legal classification of staking as a non-securities activity closer to statute, reducing the risk of regulatory reversal for institutions building long-term staking programs</li><li>BlackRock and JPMorgan filing tokenized money market products in the same week establishes Ethereum as the primary settlement layer for institutional cash management infrastructure, with validator reliability becoming a direct component of reserve asset operational standards</li><li>JPMorgan's JLTXX fund, designed explicitly for GENIUS Act-compliant stablecoin reserve assets, embeds Ethereum validator infrastructure into the reserve management stack for regulated stablecoin issuance at institutional scale</li><li>The tokenized RWA market crossing $34.5 billion with private credit overtaking Treasuries signals that institutional capital is moving beyond simple yield instruments into structured on-chain credit products that require sophisticated validator and settlement infrastructure</li><li>Full Q2 approval of remaining Ethereum staking ETF amendments would concentrate institutional ETH capital into staking-integrated products, creating a sustained and growing demand driver for validator infrastructure tied to ETF AUM rather than spot price performance</li></ul><h2 id="frequently-asked-questions-faqs">Frequently Asked Questions (FAQs)<br></h2><h3 id="what-does-the-clarity-act-clearing-the-senate-banking-committee-mean-for-staking-programs-in-practice">What does the CLARITY Act clearing the Senate Banking Committee mean for staking programs in practice?</h3><p>Committee passage is a structural milestone, not a finish line. The bill still needs 60 votes on the Senate floor, conference reconciliation with the House version, and a presidential signature. However, bipartisan committee support signals that the legal classification of staking as a non-securities activity is moving toward permanent statutory status rather than remaining reversible administrative guidance. Institutions building staking programs now have a clearer legislative timeline to build compliance frameworks against.</p><h3 id="why-are-blackrock-and-jpmorgan-filing-tokenized-money-market-products-on-ethereum-in-the-same-week">Why are BlackRock and JPMorgan filing tokenized money market products on Ethereum in the same week?</h3><p>Both firms are positioning to serve the same institutional need: compliant, yield-bearing reserve assets for the growing number of stablecoin issuers operating under the GENIUS Act. The GENIUS Act prohibits payment stablecoins from paying yield on deposits, which redirects institutional demand toward tokenized money market funds as the yield-generating reserve layer. BlackRock and JPMorgan are building the infrastructure that will sit inside stablecoin reserve structures for the next generation of institutional digital dollar products.</p><h3 id="what-does-private-credit-overtaking-tokenized-treasuries-signal-about-institutional-defi-maturity">What does private credit overtaking tokenized Treasuries signal about institutional DeFi maturity?</h3><p>Tokenized Treasuries were the entry point for institutional on-chain capital because the regulatory path was clear and the underlying asset was familiar. Private credit overtaking Treasuries as the largest non-stablecoin RWA segment signals that institutions are now comfortable enough with on-chain infrastructure to deploy into more complex, less liquid instruments. It also reflects that the yield differential between on-chain private credit and tokenized government securities is large enough to justify the additional operational complexity for allocators operating structured programs.</p><hr><p>👉 <strong>Subscribe to our newsletter</strong> at the bottom of this page to receive a monthly summary of the latest DeFi and staking developments, curated for institutional participants. Or follow us on <a href="https://linkedin.com/company/p2p-org?ref=p2p.org">LinkedIn</a> and <a href="https://twitter.com/p2pvalidator?ref=p2p.org">X</a> to stay updated when new DeFi Dispatch editions are published.</p><hr><p><strong>Disclaimer</strong></p><p>This article is provided for informational purposes only and does not constitute legal, regulatory, compliance, or investment advice. Regulatory obligations may vary depending on jurisdiction and specific business activities. Readers should consult their own legal and compliance advisors regarding applicable requirements.</p>
from p2p validator
<hr><h2 id="series-defi-infrastructure-for-institutions">Series: DeFi Infrastructure for Institutions</h2><p>P2P.org's content series for regulated institutions evaluating on-chain capital allocation. Each article addresses a specific infrastructure, governance, or compliance dimension that determines whether a DeFi allocation can clear institutional approval and operate within mandate.</p><p>This article opens the third trilogy of the series, shifting from the structural and regulatory dimensions examined in the first two trilogies to the operational reality for specific institutional profiles. The first article in this trilogy addresses custodians. The second will address hedge funds. The third will address institutional treasury teams.</p><p>The previous trilogy examined how conflict-of-interest frameworks across MiFID II, AIFMD II, and IOSCO's DeFi recommendations are converging on the curator model. Read it here: <a href="https://p2p.org/economy/conflict-of-interest-defi-vault-regulation-institutional/">How Conflict-of-Interest Regulatory Frameworks Are Catching Up to the Curator Model</a></p><h2 id="learnings-for-busy-readers">Learnings for Busy Readers</h2><p>Short on time? Here are the key takeaways. For the full analysis and supporting data, continue reading below.</p><ul><li>Vault token custody is architecturally different from direct asset custody. When client assets enter a DeFi vault, the custodian holds vault tokens, not the underlying assets. Those tokens require dedicated valuation infrastructure, daily NAV reconciliation against the vault's on-chain portfolio, and client-level segregation built on top of the vault's pooled architecture.</li><li>Pre-execution mandate validation cannot be delegated to the vault. Curators have no visibility into individual client mandates. The custodian must maintain an independent validation layer that checks every vault interaction against each client's documented investment parameters before execution.</li><li>The Travel Rule obligation attaches at the custodian level. Smart contract-initiated vault rebalances do not generate originator or beneficiary data automatically. Custodians need vault-specific Travel Rule infrastructure that maps client identity to vault addresses and generates compliant data at the point of execution.</li><li>Client asset segregation requirements extend to vault token positions. MiCA and OCC qualified custodian standards require insolvency-remote, segregated structures. That requirement applies to vault token holdings, not just static asset custody.</li><li>Digital asset native custodians and traditional custodians face different gaps. Digital asset native custodians typically need to deepen governance and compliance infrastructure. Traditional custodians typically need to build technical access capability. Both need to close their respective gaps before offering institutional-grade DeFi vault access.</li></ul><h2 id="introduction">Introduction</h2><p>The digital asset custody market is projected to grow from approximately $1 trillion in assets under custody in 2026 to over $7 trillion by 2035, driven by institutional uptake and the expansion of tokenised real-world assets (Source: <a href="https://www.financemagnates.com/thought-leadership/how-digital-asset-platform-and-custody-technology-secure-institutional-funds/?ref=p2p.org">Finance Magnates, How Digital Asset Platform and Custody Technology Secure Institutional Funds</a>, February 2026). That growth is not coming from passive storage. It is coming from clients who want their custodians to do more: access DeFi protocols, generate yield on idle assets, and interact with on-chain capital markets on their behalf.</p><p>The regulatory environment has moved to support that expansion. The repeal of SAB 121 in January 2025 removed the accounting barriers that had prevented US banks from offering crypto custody at scale. The OCC's 2025 guidance reinforced that national banks can act as qualified custodians for digital assets. MiCA established comprehensive custody standards across all 27 EU member states from December 2024. The Responsible Financial Innovation Act, introduced in late 2025, is advancing a legislative framework for digital asset custody in the US.</p><p>But regulatory clarity on custody does not automatically produce operational clarity on DeFi vault access. The infrastructure requirements for holding digital assets and the infrastructure requirements for interacting with DeFi vaults on behalf of institutional clients are related but not equivalent. A custodian that has solved for asset segregation, key management, and regulatory reporting in the static custody context faces a different and more demanding set of requirements when those same assets are deployed into a DeFi vault, interacting with smart contracts, generating yield positions, and being managed by a curator whose incentive structure creates a conflict of interest that the custodian's governance framework must address.</p><p>This article examines what those requirements look like in practice, both for digital asset native custodians who are already building DeFi capabilities and for traditional custodians evaluating DeFi vault access for the first time.</p><figure class="kg-card kg-image-card kg-card-hascaption"><img src="https://p2p.org/economy/content/images/2026/05/custodian-defi-vault-infrastructure-stack.jpg" class="kg-image" alt="A vertical stack diagram showing the custodian infrastructure requirements for DeFi vault access. From top to bottom: client mandate layer with documented investment parameters, pre-execution validation layer checking every vault interaction before execution, a red gap marker labelled missing in standard custody architecture, vault token custody layer covering ERC-4626 token holding and client-level segregation, the DeFi protocol layer showing Aave, Morpho, and Euler, and a Travel Rule compliance layer for originator and beneficiary data at execution level." loading="lazy" width="1600" height="900" srcset="https://p2p.org/economy/content/images/size/w600/2026/05/custodian-defi-vault-infrastructure-stack.jpg 600w, https://p2p.org/economy/content/images/size/w1000/2026/05/custodian-defi-vault-infrastructure-stack.jpg 1000w, https://p2p.org/economy/content/images/2026/05/custodian-defi-vault-infrastructure-stack.jpg 1600w" sizes="(min-width: 720px) 720px"><figcaption><i><em class="italic" style="white-space: pre-wrap;">The four infrastructure layers a custodian must build to offer institutional-grade DeFi vault access.</em></i></figcaption></figure><h2 id="the-two-custodian-starting-points">The Two Custodian Starting Points</h2><p>The infrastructure gap between standard custody architecture and DeFi vault access looks different depending on where a custodian is starting from.</p><h3 id="digital-asset-native-custodians">Digital asset native custodians</h3><p>They have already solved for the core technical requirements of on-chain asset interaction: MPC key management, smart contract interaction, on-chain transaction signing, and basic DeFi protocol access. Their gap is typically at the governance and compliance layer. They can interact with DeFi protocols technically, but their frameworks for mandate validation, conflict of interest management, Travel Rule compliance for vault-specific transaction types, and audit trail production may not be built to the standard that their institutional clients' own compliance functions require. The infrastructure challenge for digital asset native custodians is governance depth rather than technical access.</p><h3 id="traditional-custodians">Traditional custodians</h3><p>These, when entering the DeFi space, are often starting from a stronger governance and compliance foundation, with established frameworks for mandate validation, client asset segregation, regulatory reporting, and audit trail production built over decades of traditional asset management. Their gap is typically at the technical access layer. They may not have the onchain infrastructure to interact with DeFi protocols directly, to custody vault tokens natively, or to generate compliant Travel Rule data for smart contract-initiated transactions. The infrastructure challenge for traditional custodians is technical access capability rather than governance depth.</p><p>Both profiles need to close their respective gaps before they can offer institutional-grade DeFi vault access to clients. The sequencing differs: digital asset native custodians build governance on top of existing technical access; traditional custodians build technical access within existing governance frameworks.</p><h2 id="infrastructure-requirements">Infrastructure Requirements<br></h2><h3 id="vault-token-custody-and-valuation">Vault Token Custody and Valuation</h3><p>When a custodian deposits client assets into a DeFi vault, the transaction produces vault tokens: ERC-4626 standardised tokens representing the client's proportional claim on the vault's portfolio. These vault tokens are the asset the custodian holds in custody. The underlying assets, the ETH, USDC, or other tokens that the vault has deployed into lending markets, are held in smart contracts. The custodian does not hold them directly.</p><p>This creates a custody architecture problem that does not exist in static asset holding. The custodian must maintain infrastructure that holds vault tokens securely using the same MPC and key management standards applied to direct asset custody, values vault tokens accurately against the underlying portfolio daily, generates client reporting in a format that maps vault token positions to the underlying asset exposures they represent, and maintains segregated vault token positions for each client to prevent commingling.</p><p>The valuation problem is particularly demanding. Vault tokens do not have a fixed price. Their value is a function of the vault's net asset value, which changes as the curator rebalances positions, as lending markets generate yield, and as market conditions shift collateral valuations. A custodian offering vault token custody to institutional clients must have infrastructure that can pull accurate vault NAV data from on-chain sources, reconcile that data against the client's reported position, and produce a daily valuation that an auditor can verify independently.</p><p>The ERC-4626 vault standard, which became the dominant architecture for institutional vault deployments through 2025, provides a universal interface for deposits, withdrawals, and share accounting. Total value in curated ERC-4626 vaults grew 28 times in twelve months, from under $150 million to over $4.4 billion by mid 2025, reflecting the speed at which institutional capital is moving into the standard (Source: <a href="https://www.zircuit.com/en/blog/vault-infrastructure-the-institutional-upgrade-traditional-asset-management-has-been-waiting-for?ref=p2p.org">Zircuit, Vault Infrastructure: The Institutional Upgrade Traditional Asset Management Has Been Waiting For</a>, 2025). Custodians building vault token custody infrastructure should build against the ERC-4626 standard as the baseline integration layer.</p><h3 id="pre-execution-mandate-validation">Pre-Execution Mandate Validation</h3><p>The curator managing a DeFi vault's allocation strategy operates at the portfolio level. They set strategy parameters for the vault as a whole: concentration limits across lending markets, collateral type allowlists, leverage bounds, oracle feed specifications. Those parameters apply to all depositors in the vault equally. The curator has no visibility into any individual client's mandate parameters, and no obligation to validate that their allocation decisions are within any specific client's mandate before executing them.</p><p>For a retail depositor, this is acceptable. The depositor chose the vault and accepted the curator's strategy.</p><p>For a custodian's institutional client, it is a governance problem. The client has a mandate with specific investment parameters: maximum concentration in any single protocol, allowlisted asset types, leverage restrictions, reporting requirements. Those parameters are the custodian's responsibility to enforce. The curator cannot enforce them because the curator does not know what they are.</p><p>The custodian must maintain a pre-execution validation layer that sits between the curator's strategy and the client's capital. Before any vault interaction is executed on the client's behalf, every transaction must be checked against the client's mandate parameters: does this vault interaction increase concentration in a restricted protocol? Does it expose the client to an asset type outside the mandate's allowlist? Does it create a leverage position that exceeds the client's risk parameters? Only if the transaction passes all checks does it proceed to execution.</p><p>This validation function is independent of the vault. It is a custodian infrastructure requirement, not a vault product feature. Building it requires a mandate parameter management system that holds each client's investment restrictions in a codified, queryable format, a transaction interception layer that captures every proposed vault interaction before it executes, a parameter checking engine that evaluates each proposed transaction against the relevant client's parameters, and a logging system that records every check, every block, and every approved transaction in a format that satisfies audit requirements.</p><blockquote><strong>The institutional digital asset space moves fast.</strong> Our subscribers get structured analysis across staking, DeFi vaults, and regulation through <em>DeFi Dispatch</em>, <em>Institutional Lens</em>, <em>DeFi Infrastructure for Institutions</em>, and <em>Legal Layer</em>. No noise. Just the signals that matter. <strong>Subscribe to the newsletter at the bottom of this page.</strong></blockquote><h3 id="travel-rule-compliance-for-vault-transactions">Travel Rule Compliance for Vault Transactions</h3><p>As examined in detail in the second regulatory trilogy article, the Travel Rule requires originator and beneficiary data to accompany every qualifying crypto-asset transfer involving a CASP. For custodians, this obligation attaches at the point of every vault interaction executed on a client's behalf.</p><p>The specific challenge for vault interactions is that most rebalances within a DeFi vault are executed by the vault's smart contract, not by a named human originator. When the curator initiates a rebalance and the smart contract executes transactions across lending markets, the transaction does not have a named originator in the format the Travel Rule requires. The custodian must generate that originator data from outside the protocol and attach it to the transaction chain.</p><p>Under the EU Transfer of Funds Regulation, which has applied to all CASP-to-CASP transfers with no minimum threshold since December 30, 2024, the required data includes the client's full name, account or wallet identifier, and either a physical address, official personal document number, customer identification number, or date of birth. For custodians managing DeFi vault positions for multiple institutional clients, generating this data at the transaction level requires a data architecture that maps each client's verified identity to the vault addresses associated with their position, intercepts vault transactions at the point of initiation, generates compliant Travel Rule data from the identity mapping, and transmits that data to counterparty VASPs before settlement.</p><p>Custodians whose Travel Rule infrastructure was built for direct asset transfers will find that it does not automatically extend to vault-specific transaction types. The smart contract initiation problem, the multi-hop transaction structure of vault rebalances, and the beneficiary identification challenge for protocol addresses all require vault-specific extensions to standard Travel Rule infrastructure.</p><h3 id="client-asset-segregation-at-the-vault-token-layer">Client Asset Segregation at the Vault Token Layer</h3><p>Institutional custody standards require client asset segregation: each client's assets must be held in segregated, insolvency-remote structures that are identifiable and accessible even if the custodian becomes insolvent. The repeal of SAB 121 and the OCC's 2025 guidance reinforced that these standards apply to digital assets held in custody by national banks, on the same basis as traditional asset custody. MiCA's client asset safeguarding requirements apply equivalent standards to CASPs across the EU.</p><p>For static asset custody, segregation is straightforward: each client's assets are held in dedicated wallets with documented ownership records. For vault token custody, the segregation requirement extends to the vault token layer. A custodian holding vault tokens on behalf of multiple clients must maintain a separate, documented vault token position for each client, ensuring that the client's proportional claim on the vault's portfolio is accurately recorded, insolvency-remote, and separable from other clients' positions and from the custodian's own assets.</p><p>The complication is that DeFi vaults are pooled products. Multiple depositors contribute to the same vault pool, and the vault's smart contract tracks each depositor's proportional share through vault tokens. The custodian must maintain its own client-level segregation on top of the vault's pooled architecture: tracking which vault tokens belong to which client, maintaining accurate client-level NAV calculations based on the vault's overall performance, and ensuring that client redemptions can be processed in a way that correctly reflects each client's proportional position.</p><p>Academic research covering six major lending systems found that a small set of curators intermediates a disproportionate share of system TVL and exhibits clustered tail co-movement (Source: <a href="https://arxiv.org/html/2512.11976v1?ref=p2p.org">Institutionalizing Risk Curation in Decentralized Credit, arXiv, December 2025</a>). For custodians, this systemic risk dimension means that client asset segregation at the vault token layer is not just a regulatory compliance requirement. It is the mechanism through which client exposure is identifiable and manageable if a curator-layer failure creates cascading effects across the protocols where the vault holds positions.</p><h2 id="risk-considerations-for-custodians">Risk Considerations for Custodians</h2><p>Beyond the infrastructure requirements, DeFi vault access introduces three categories of risk that custodians must model explicitly in their risk frameworks.</p><h3 id="smart-contract-risk">Smart contract risk</h3><p>DeFi vault interactions expose client assets to smart contract vulnerabilities in the vault itself, in the underlying lending protocols the vault interacts with, and in any bridge or oracle infrastructure the vault depends on. Unlike traditional asset custody where the primary risk is operational or custodian counterparty risk, smart contract risk is protocol-level and non-recoverable if exploited. Custodians must evaluate the audit history and security track record of every protocol layer in the vault's execution stack before offering vault access to clients.</p><h3 id="curator-concentration-risk">Curator concentration risk</h3><p>The research finding that a small number of curators intermediate a disproportionate share of total value locked and exhibit clustered tail co-movement means that custodian exposure to the curator layer is a systemic risk variable, not just a counterparty risk variable. A custodian offering multiple clients access to vaults managed by the same curator creates correlated exposure that needs to be modelled and disclosed. Custodians should track curator concentration across their client base and include curator-layer correlation in their stress testing frameworks.</p><h3 id="liquidity-and-redemption-risk">Liquidity and redemption risk</h3><p>DeFi vault positions may not be instantly redeemable. Vault liquidity depends on the available liquidity in the underlying lending markets, which can tighten during market stress events. Custodians whose client agreements specify withdrawal timelines must model vault liquidity conditions as a variable in their redemption planning. The assumption that vault positions can always be liquidated on demand at current NAV does not hold in all market conditions.</p><h2 id="what-this-means-for-custodians-evaluating-defi-vault-access">What This Means for Custodians Evaluating DeFi Vault Access</h2><p>The infrastructure requirements and risk considerations examined in this article are not arguments against custodians offering DeFi vault access. They are a map of what offering it properly requires.</p><p>Custodians that build vault token custody infrastructure, pre-execution mandate validation, vault-specific Travel Rule compliance, and client-level segregation at the vault token layer will be positioned to offer institutional-grade DeFi vault access as the market matures. Custodians that treat DeFi vault access as a straightforward extension of their existing product will encounter the infrastructure gap when institutional clients begin the due diligence process.</p><p>The market signal is clear. 83% of institutional investors plan to increase crypto allocations, with over two-thirds specifically targeting DeFi mechanisms, including lending and staking (Source: <a href="https://www.coinbase.com/institutional/research-insights/research/institutional-investor-digital-assets-study?ref=p2p.org">EY-Parthenon and Coinbase Institutional Investor Digital Assets Study</a>, January 2025). DeFi TVL across all chains sits at approximately $130 to $140 billion in early 2026, with on-chain DeFi lending capturing roughly two-thirds of the record $73.6 billion crypto-collateralised lending market by late 2025. The clients are coming. The custodians who have built the infrastructure will capture the allocation.</p><p><a href="https://p2p.org/?ref=p2p.org#form">Talk to our team</a> if you are evaluating how <a href="http://p2p.org/?ref=p2p.org">P2P.org</a>'s protection layer integrates with custodian infrastructure for institutional DeFi vault access.</p><h2 id="key-takeaway">Key Takeaway</h2><p>Custodians are the infrastructure layer through which most institutional capital will access DeFi vaults. The infrastructure requirements that access imposes, vault token custody and valuation, pre-execution mandate validation, vault-specific Travel Rule compliance, and client asset segregation at the vault token layer, are not extensions of existing custody capability. They are a new infrastructure layer that needs to be built explicitly.</p><p>The regulatory environment is supportive: the OCC's 2025 guidance, SAB 121 repeal, and MiCA's custody standards have all removed barriers to custodians offering digital asset services at an institutional scale. What the regulatory environment does not provide is the operational infrastructure to interact with DeFi vaults in a way that satisfies the governance requirements of institutional clients. That infrastructure is the variable, and it is being built now by the custodians who understand the distinction between holding digital assets and enabling institutional DeFi allocation.</p><p><em>Next in this series: How Hedge Funds Are Approaching Onchain Yield Strategies in 2026</em></p><h2 id="frequently-asked-questions-faqs">Frequently Asked Questions (FAQs)<br></h2><h3 id="what-is-vault-token-custody-and-why-is-it-different-from-direct-asset-custody">What is vault token custody, and why is it different from direct asset custody?</h3><p>When a custodian deposits client assets into a DeFi vault, the client receives vault tokens representing their proportional claim on the vault's portfolio. Those vault tokens are the custodial asset. The underlying assets are held in the vault's smart contracts, not in the custodian's wallets. Vault token custody requires infrastructure to hold vault tokens securely, value them against the underlying portfolio on a daily basis, report on them in a format that maps to underlying asset exposures, and maintain segregated positions for each client. This is architecturally different from direct asset custody, where the custodian holds the asset itself.</p><h3 id="how-does-pre-execution-mandate-validation-work-in-a-custodian-context">How does pre-execution mandate validation work in a custodian context?</h3><p>Pre-execution mandate validation in a custodian context is a layer that sits between the curator's allocation decisions and the custodian's execution of vault interactions on behalf of clients. Before any vault transaction is executed for a client, the validation layer checks whether the proposed interaction is within the client's documented mandate parameters: concentration limits, protocol allowlists, asset type restrictions, and leverage bounds. The curator cannot perform this validation because the curator has no visibility into individual client mandates. It is a custodian infrastructure requirement that must be built and operated independently of the vault.</p><h3 id="what-does-travel-rule-compliance-require-specifically-for-defi-vault-interactions">What does Travel Rule compliance require specifically for DeFi vault interactions?</h3><p>DeFi vault rebalances are typically initiated by smart contracts rather than named human originators. The Travel Rule requires custodians to generate originator and beneficiary data for these transactions from outside the protocol, using a data layer that maps each client's verified identity to their vault address and intercepts transactions at the point of initiation. Under the EU TFR, this data must be generated and transmitted before settlement, with no minimum threshold. Custodians whose Travel Rule infrastructure was built for direct asset transfers need vault-specific extensions to handle smart contract-initiated rebalances and multi-hop vault transaction structures.</p><h3 id="how-does-client-asset-segregation-apply-to-vault-token-positions">How does client asset segregation apply to vault token positions?</h3><p>Regulatory requirements for client asset segregation, including those under MiCA and the OCC's qualified custodian standards, require that each client's assets be held in segregated, insolvency-remote structures. For vault token custody, this means maintaining a separate, documented vault token position for each client, with accurate client-level NAV calculations and the ability to process client redemptions in a way that correctly reflects each client's proportional position. The DeFi vault's pooled architecture does not eliminate this requirement: the custodian must maintain client-level segregation on top of the vault's pooled token structure.</p><h3 id="what-is-curator-concentration-risk-and-why-does-it-matter-for-custodians">What is curator concentration risk, and why does it matter for custodians?</h3><p>Curator concentration risk arises when a custodian offers multiple clients access to vaults managed by the same curator, creating correlated exposure across the client base. Academic research covering six major lending systems found that a small number of curators intermediate a disproportionate share of total value locked and exhibit clustered tail co-movement, meaning that stress at the curator layer can propagate simultaneously across multiple protocols. For custodians, this means that curator-layer correlation across the client book needs to be modelled and included in stress testing frameworks, not treated as isolated counterparty risk.</p><hr><h2 id="about-p2porg">About P2P.org</h2><p>P2P.org builds the protection layer that sits between regulated institutions and DeFi execution environments, independently of the curators who manage allocation strategies. If you are evaluating the infrastructure requirements for a DeFi allocation program, <a href="https://p2p.org/?ref=p2p.org#form">reach out to our team of experts</a>.</p><hr><h2 id="disclaimer">Disclaimer</h2><p>This article is provided for informational purposes only and does not constitute legal, regulatory, compliance, or investment advice. Regulatory obligations may vary depending on jurisdiction and specific business activities. Readers should consult their own legal and compliance advisors regarding applicable requirements.</p>
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