Pantera: 2025 will be a year of structural progress for the crypto market.

Source: Pantera Capital December Blockchain Letter; Compiled by: Jinse Finance

A Year of Structural Progress

Author: Erik Lowe, Head of Content, Pantera Capital

Considering expectations for 2025—a government that finally supports cryptocurrencies, Gary Gensler's resignation, and potential interest rate cuts—Bitcoin's 25% rise since the presidential election might seem somewhat disappointing.

In mid-July, Kalshi predicted a 53% probability that Bitcoin would reach $150,000 by 2025. This is somewhat reminiscent of Peter Thiel's famous quote: "They promised us flying cars, and we got 140 characters." While the price of BTC may not meet expectations, 2025 will see more structural progress for cryptocurrencies than any previous year.

Leaving aside the price for now, here's what we actually got:

• Governments supporting cryptocurrencies

• White House Director of Artificial Intelligence and Cryptocurrency Affairs and a working group focused on the digital asset market

• Gary Gensler resigns

• SEC Chairman Paul Atkins supporting cryptocurrencies

• SAB 121 is repealed—removing barriers for financial institutions to provide cryptocurrency custody services

• Establishment of a US strategic Bitcoin reserve and digital asset reserve

• The US SEC has dropped multiple major cryptocurrency lawsuits.

• Coinbase is included in the S&P 500—becoming the first cryptocurrency-native company to receive this honor.

  Robinhood Launches Tokenized Stocks Stablecoin Legislation Signed into Law Market Structure Bill Passed by the House Solana and XRP ETFs Nine Blockchain Companies Go Public Vanguard Group Lifts Ban on Cryptocurrency ETFs, Opening Trading Access to $11 Trillion in Assets for 50 Million Customers SEC Chairman Paul Atkins Announces "Innovation Exemption" Program for Crypto Products Real-World On-Chain ("RWA") Value Grows 235% Stablecoin Market Size Increases by $100 Billion From this perspective, we believe 2025 will be the most important year for the entire industry. This is the year we begin laying a deep foundation to support sustained long-term growth. Below, Pantera's Chief Legal Officer, Katrina Paglia, will delve deeper into these structural developments, providing a comprehensive overview of the latest developments in cryptocurrency regulation and policy. Cryptocurrency Regulation and Policy Updates Authors: Katrina Paglia, Chief Legal Officer, and Andrew Harris, Platform Manager, Pantera As in previous years, we aim to provide an updated report on key policy and regulatory developments in the crypto asset space as we approach 2025—a year of profound change for U.S. cryptocurrency regulation. Since the Trump administration took office, U.S. cryptocurrency policy and regulation have undergone a near-complete transformation. Actions by regulatory bodies such as the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), as well as the executive branch, indicate that a new, positive path for cryptocurrencies is emerging. Below, we will explore the key administrative, regulatory, and legislative initiatives shaping the policy environment in 2025. Presidential Digital Assets Task Force Just days after taking office, President Trump signed an executive order aimed at “clarifying” the regulatory rules for crypto assets. The order established the "Presidential Task Force on Digital Asset Markets," chaired by David Sacks, the "Artificial Intelligence and Cryptocurrency Czar," with members including the Secretary of the Treasury, the Chairman of the Securities and Exchange Commission (SEC), the Chairman of the Commodity Futures Trading Commission (CFTC), and heads of other agencies and departments. The task force's mission is to review existing regulations and propose reforms to promote the development of crypto assets. In July, the task force released a comprehensive report entitled "Strengthening U.S. Leadership in Digital Financial Technologies." This report made 100 policy and legislative recommendations on digital asset market structure, banking and digital assets, stablecoins and payments, combating illicit finance, and taxation. Notably, the report distinguished between security-type digital assets (regulated by the SEC) and non-security-type digital assets (regulated by the CFTC). This marks a significant shift from the SEC's policy during the Biden era, when the SEC treated most crypto assets as securities. As we will discuss below, the SEC and CFTC have already begun taking action to advance the report's recommendations.

  US SEC, Crypto Working Group, and Crypto Project

  Shortly after President Trump took office, then Acting Chairman of the US Securities and Exchange Commission (SEC), Mark Uyeda, established the “Crypto Working Group” within the Commission, aiming to “develop a comprehensive and clear regulatory framework” for crypto assets. Led by Commissioner Hester Peirce, the working group sought to create a “rational regulatory path,” a departure from the SEC’s previous primarily enforcement-driven approach.

  In August, SEC Chairman Paul Atkins delivered a landmark speech announcing that most crypto assets are not securities and launching an initiative called “Project Crypto.” Chairman Atkins outlined five key elements of Project Crypto:

  • Establishing a clear regulatory framework for the distribution of crypto assets in the United States

  • Ensuring free choice between cryptocurrency exchanges and cryptocurrency custodians.

  • Ensuring free choice between cryptocurrency exchanges and cryptocurrency custodians.

  Embracing market competition and fostering the development of "super apps," through which platforms and intermediaries can offer a range of crypto services and assets (including securities and non-securities) under a single, efficient permissioned structure. Supporting on-chain innovation and decentralized finance (DeFi). Innovation exemptions and commercial viability. ICOs, Securities and Crypto Asset Distribution: Is the Tunnel Over? The biggest regulatory risk faced by participants in the US crypto asset market often lies in whether crypto assets are securities or whether they are offered to US investors through securities transactions. The previous administration and the Securities and Exchange Commission (SEC) under former Chairman Gensler treated most crypto assets as securities and adopted a strategy that many considered "enforcement regulation" towards crypto asset issuers and other market participants. This regulatory approach led many crypto asset issuers to move their operations overseas, issuing assets through foundations established in the Cayman Islands, Panama, or other jurisdictions. Many cryptocurrency exchanges screen U.S. users, and many cryptocurrency companies restrict or completely cease interaction with U.S. users. Under Chairman Atkins, the U.S. SEC has taken a drastically different approach. The current SEC has dismissed several cases against cryptocurrency platforms and issuers and developed a new, less restrictive classification standard that divides crypto assets into four categories: Digital goods, whose value is pegged to a fully functional decentralized protocol, rather than to management promises or the issuer's ongoing efforts. Digital collectibles or tokens, such as NFTs, designed for collection. Digital instruments with practical uses, such as access rights, credentials, or identity features. Tokenized securities represent traditional securities or financial instruments (such as equity or debt) that remain subject to securities laws. Even before the SEC Chairman announced this four-tier classification, SEC staff had already begun hinting at this position through no-action letters and statements. In 2025, SEC staff issued guidance stating that U.S. fiat stablecoins and memes are not securities, nor are protocol staking and liquidity staking. There is good reason to believe that in 2026, the U.S. SEC will continue to adopt a relatively lenient approach to cryptocurrency regulation and establish regulatory framework elements for the issuance of network tokens and other crypto assets within the country. The Rise of Prediction Markets In 2025, prediction markets emerged and gradually gained regulatory recognition. Prediction market platforms allow users to express their views on real-world outcomes through event-based contracts. These contracts pay out the full value to the winners, while the losers receive nothing. A key turning point came when Kalshi, one of the earliest operating prediction markets in the US, won its regulatory battle with the Commodity Futures Trading Commission (CFTC) and was granted permission to operate as a CFTC-regulated designated contract market, offering contracts related to elections and other events. Since Kalshi's victory, interest in prediction markets has grown rapidly, with more platforms receiving federal approval and traditional financial and consumer platforms (such as Robinhood) entering the field. While regulatory treatment remains uneven—particularly under gambling laws in some states—prediction markets are increasingly being seen as a legitimate financial foundation. Of particular note are the exploration by some platforms of tokenization or cryptocurrency implementations, further driving the integration of prediction markets with digital asset infrastructure. Coinbase's announcement of a partnership with Kalshi underscores this trend, which is likely to continue until 2026. **Key Litigation Developments** **Withdrawal of Lawsuits Against Coinbase and Other Cryptocurrency-Related Companies:** In 2023, the U.S. Securities and Exchange Commission (SEC) filed major lawsuits against Coinbase in the Southern District of New York and against Binance in the District of Columbia, alleging multiple violations, including operating as an unregistered broker-dealer, exchange, and clearinghouse, and issuing unregistered securities through their respective staking services. In the first quarter of 2025, the SEC reached joint agreements with Coinbase and Binance respectively, withdrawing all charges against them. **The SEC also rejected ongoing enforcement actions against other cryptocurrency market participants, including Kraken, Consensys, Ripple, and DRW Cumberland. The SEC stated that rejecting these pending enforcement actions was part of its ongoing reforms to its approach to regulating the cryptocurrency industry and was not based on any assessment of the substance of the allegations. **The SEC Establishes a New Internet and Emerging Technologies Division:** The SEC's reforms to its cryptocurrency enforcement approach are also reflected in its newly established Internet and Emerging Technologies Division. This department replaces the Crypto Assets and Networks Division, which previously handled enforcement actions against several prominent cryptocurrency market participants. The new Networks and Emerging Technologies Division is expected to focus on fraud and other misconduct, including blockchain-related fraud and fraud perpetrated using emerging technologies such as artificial intelligence and machine learning. Outlook: New Developments in Cryptocurrency Regulation under the Trump Administration While the shift in the cryptocurrency policy environment is real and clear, there are still some regulatory and legislative developments worth watching closely as we head into 2026. Below, we highlight some key areas: The GENIUS Act – No discussion of 2025 can ignore the Directing and Establishing the National Innovation for Stablecoins Act (GENIUS Act) – the first major federal cryptocurrency legislation. Passed bipartisanly, the act establishes a regulatory framework for “paying stablecoins.” Under this bill, payment stablecoin issuers are generally limited to: (1) certain U.S. qualified individuals subject to federal regulation or (for some issuers) state regulation; or (2) certain non-U.S. qualified individuals registered with the Office of the Comptroller of the Currency (OCC) and subject to a similar regulatory regime (as determined by the Secretary of the Treasury). The bill imposes licensing requirements on issuers and complies with prudential regulatory and consumer protection standards similar to those for banks, aiming to increase the transparency of reserve assets and reduce potential risks. Payment stablecoins do not include “algorithmic” stablecoins, and payment stablecoin issuers will be prohibited from paying interest to stablecoin holders. Public comment on the bill has been initiated, and provisions such as the prohibition on issuers paying interest are likely to be highly controversial. Comprehensive Cryptocurrency Legislation — Unlike the GENIUS Act, comprehensive cryptocurrency market structure legislation is still progressing intermittently in Congress. The Digital Asset Market Transparency Act of 2025 (CLARITY Act) passed the House of Representatives in July 2025 with strong bipartisan support, but has yet to make progress in the Senate. Among other things, the CLARITY Act assigns jurisdiction over the regulation of “digital goods” to the Commodity Futures Trading Commission (CFTC), while jurisdiction over the regulation of “restricted digital assets” is assigned to the Securities and Exchange Commission (SEC). The bill also establishes a temporary registration pathway until the SEC and CFTC finalize the relevant rules, and stipulates that once the network achieves decentralization, assets can be transformed from securities into digital goods. Although the government shutdown has slowed the bill's progress, there are still high expectations for comprehensive cryptocurrency legislation in 2026. Real-world assets, tokenization, and new frontiers—In 2025, the tokenization process of “real-world assets” continues. Unlike “native crypto” assets, the tokenization of real-world assets involves placing existing traditional assets on the blockchain, sometimes in a fragmented manner. Tokenization involves a wide range of assets, including precious metals or other commodities, government bonds, and private equity fund interests. However, a recent proposal submitted by Nasdaq to the U.S. SEC marks a new era for tokenization. This proposal requests that investors be allowed to trade existing equity securities in tokenized form. This proposal has attracted widespread attention, and the SEC has indicated its willingness to consider requests for tokenized trading of existing traditional listed securities. We will strive to keep our LPs and the wider community informed about these structural changes and emerging initiatives. We look forward to developments in digital asset policy and regulation in 2026.