CTF Written Submission

RE: Comprehensive Technical Framework for Blockchain and Tokenization Infrastructure in International Financial Integration

Sept. 15, 2025
  • Tokenized securities are treated as securities under U.S. law, and the framework ensures compliance with the Securities Act of 1933 and the Securities Exchange Act of 1934, including support for Regulation D, Regulation A, and Regulation S offerings, with programmable enforcement of transfer restrictions and disclosure obligations.
  • The framework enables registered transfer agents to maintain blockchain-based master securityholder files, in compliance with SEC Rules 17Ad-1 through 17Ad-23, allowing for tamper-resistant records, automated corporate actions, and privacy-preserving off-chain personal data storage.
  • The proposal includes a comprehensive AML/KYC compliance system using verifiable digital identities and smart contracts to enforce transaction-level compliance, integrated with OFAC screening and automated Suspicious Activity Report (SAR) generation, aligning with Bank Secrecy Act and FinCEN requirements.
     

Last Reviewed or Updated: Sept. 15, 2025