CTF Written Submission

Global Blockchain Business Council USA (GBBC USA)

Oct. 15, 2025
  • The document recommends that custody of digital assets in decentralized markets should be regulated differently from traditional markets, emphasizing technology-neutral standards, robust cryptographic key management, and operational resilience, with tailored requirements for multi-signature, MPC custody, and self-custody arrangements.
  • The framework treats tokenization as an operational change, not a change in legal categorization, and urges regulators to adapt existing risk categories for tokenized securities, focusing on transparency, operational integrity, and dispute resolution regardless of ledger type.
  • Regulations should permit temporary commingling of customer assets for operational reasons (e.g., settlement, forks), but require prompt disaggregation, robust internal controls, audit trails, and prohibit rehypothecation except with explicit customer consent.

Last Reviewed or Updated: Nov. 13, 2025