If you're reading this and still haven't signed up, click the subscribe button below!

Pssst. We also have a podcast… find that here on your favourite podcast player or here on YouTube 🙏

Welcome to the Tokenized newsletter, brought to you by the creators of the Tokenized Podcast. Written by Simon Taylor of Fintech Brainfood and Shwetabh Sameer of Molten Ventures.

We are the newsletter for institutions that need help preparing for a Tokenized future.

We run through the headlines every week, what it means for you and a market readout. Always with an institutional, business-focused perspective. 

Join us every week as we meet your Tokenization needs.

💬 Simon's Market Readout: Live from Point Zero Forum in Zurich: a year after the GENIUS Act, two "oh shit" moments have reshaped global regulation - and banks should be chasing stablecoin revenue, not building defensive consortia.

📰 Stories You Can't Miss: The Bank of England publishes its stablecoin rulebook for a market that doesn't exist yet; Baillie Gifford puts actively managed corporate credit on public chains - the first tokenized fund where the cargo carries real risk; and Allium raises $40 million to be the Bloomberg of onchain data while Dune cuts 25% of staff chasing the same lane.

This newsletter is sponsored by M0!

Most stablecoin platforms give you one stack, one issuer, no choices.

M0 is modular. Choose your regulated issuer. Design how your stablecoin behaves. Change anything as your business evolves.

Your stablecoin, your stack, built around your business

Learn more at m0.org.

This week I've been at the Point Zero Forum in Zurich - the global regulators' gathering for all things tokenized money and tokenized finance, attended by the great and good, often under Chatham House rule. That was my argument in Zurich. Being on the ground, it's been phenomenal to see how fast both the industry and the regulators have had to move.

It's almost a year since the GENIUS Act passed on July 18th, and Dante from Circle put it bluntly - there have been two "oh shit" moments for regulators. The first was the Libra white paper, which he may have had something to do with. The second was the GENIUS Act itself. And that second one landed rather more poorly on European shores than it did at home in the US.

But it also forced a reaction. MiCA exists, it's a clear framework, and it's well understood. It's one European banks can adopt and work within in a way US banks can't move on as quickly, because MiCA is clear about what banks are and are not responsible for when it comes to anti-money laundering.

That lack of clarity is one of the things holding US banks back. Federal Reserve Governor Christopher Waller is quite concerned about what he calls the gap in how AML works in the unregulated DeFi and unhosted wallet space. As GENIUS is written, any issuer is responsible for freezing wallets in the event of sanctions. But once funds move outside any regulated market actor into an unhosted wallet, nobody is effectively on the hook for the AML - just like cash, which can move hand to hand between people.

The crypto industry pushes back on this. Its argument isn't that funds can't move; it's that it can't be held responsible for what happens beyond its own boundary, well outside its network. Can it really police that and raise SARs against it? Where does one party's responsibility stop and another's begin? Those are real implementation challenges. The counterargument is just as real: there is a lot of money laundering happening today, and somebody has to solve for it. So the US sits in a genuinely different position to Europe.

Meanwhile, tokenized money is here, and it's real - whether it's JP Morgan's Kinexys, which has settled three trillion dollars to date, or stablecoins doing about 400 billion dollars annually. From my seat in the market, I can see far more stablecoin adoption coming than meets the eye. We're only now seeing the first things that kicked off after GENIUS reach the market, and there's far more to come - along with far more interconnectivity between them.

So one thing I'm keen to see is more banks coming into the market to profit from stablecoins, rather than defending against them with tokenized deposits. Banks should do tokenized deposits, but tokenized deposits are money at rest. Stablecoins are money that moves. Banks are already monetizing stablecoin off-ramps. They're monetizing stablecoin-backed cards through sponsorship. They're doing real-time merchant payouts and cross-border payments for fintech partners. These are revenue-generating opportunities, not defensive consortia. That was my argument in Zurich: we don't have to act because we feel we need to defend. We can act because there's a revenue opportunity in stablecoins. That's what excites me.

On policy, I was particularly taken with the nuances in the Bank of England's recent statement. On one level it looks quite like MiCA. On another, there are a couple of nuances worth pulling apart, and I'll leave that to Shwetabh in the next story.

The Bank of England published its policy statement and draft Code of Practice for systemic stablecoins on 22 June. This is the clearest version yet of the framework we've tracked since the November 2025 consultation and Sarah Breeden's May speech calling the original proposals "overly conservative." Two changes from last year's draft, and the framework that results is workable. Whether workable is the same as competitive is the question the rules don't answer.

Key Points:

The Tokenized Take:

The yield headline is simple. A UK issuer earns on ~70% of its float. Under MiCA, euro stablecoin issuers earn ~40-70%, depending on the mix of bank deposits and sovereigns. A US issuer under the GENIUS Act earns on up to 100% (T-bills, cash, repo, no dead weight).

Which number matters depends on the business model. A yield-maximizing issuer makes money on the reserves, so 100% on a dollar book beats 70% on a sterling one - and the gap is wider than the percentages suggest, because ~99% of stablecoin supply is dollar-denominated. Holders are buying Treasury-backed dollar exposure, not reserve mechanics, so a sterling issuer earning on 70% of its float is competing for demand that mostly doesn't ask for pounds. On the yield-and-exposure axis, sterling barely registers.

Which is why the payments lane is the one that matters for the UK. A payments issuer's margin is on the movement, and there the cost that bites is settlement, not forgone yield. Without central-bank access, moving pounds runs through commercial banks: prefunded balances parked across institutions, intermediary fees on every hop, no 24/7 finality. The BoE deal swaps that for direct settlement, with the 30% at the Bank as the prefunding that moves money natively. Wise already works this way. It isn't a bank, but direct access to UK payment infrastructure lets it strip out sponsoring-bank dependency and move GBP cheaper. The BoE is offering systemic stablecoin issuers a version of the same trade - park liquidity at the central bank, settle natively in return.

Turnover is the decider. The yield forgone on ~30% of reserves is a fixed cost on a static pile, while the settlement saving comes off every pound that moves. Past a certain ratio of volume to float, native settlement wins outright, and the central bank liquidity backstop, now confirmed, removes a risk a US issuer still carries.

The £40 billion cap operates on the same logic. The BoE set a ceiling more than 120x the largest euro stablecoin (EURC) - a number designed to observe whether stablecoins drain bank deposits and reduce credit creation, not to limit issuance. If lending holds up, the cap lifts. The structure selects for payments issuers and watches what they do to deposits. UK bank executives we've spoken with question what problem tokenised deposits solve domestically, which leaves a gap stablecoins could fill - if anyone builds a compelling sterling coin.

On reserve economics, the UK looks better than MiCA - more of the float earns, and the path from FCA-supervised startup to BoE-supervised systemic issuer is designed as a managed ramp.

The catch is that the EU's rules are live and have been since MiCA took effect. The UK's won't produce a regulated stablecoin until 2027. Britain wrote the better rulebook for a market that doesn't exist yet.

London is the home of global FX. Whether it becomes the home of onchain FX turns on something these rules don't provide - a reason for an issuer to build here first, while the market is still forming.

The most institutionally visible tokenized funds have clustered around cash-equivalent collateral - Treasury funds, money-market funds, overnight cash-management products. Baillie Gifford has put something riskier on the same rails. The Baillie Gifford Enhanced Yield Fund (BAGEY), launched 22 June with BNY, is an actively managed short-duration corporate bond portfolio (BBB average credit, two-year duration, ~7% target yield) issued natively on Ethereum and Solana inside a UK-regulated OEIC. The architecture isn't new for Baillie Gifford. What's new is what it now carries, and who can buy it.

Key Points:

The Tokenized Take:

Tokenized funds built for collateral mobility have held cash for a reason. In the stress that makes mobility valuable, you want collateral that holds its value. The institutional cohort proves it - BUIDL, BENJI, Spiko's funds, the records on BNY and Goldman's LiquidityDirect all sit in the Treasury and money-market universe. BAGEY puts a BBB credit book on the same rails. Native issuance, public availability, a UK register held onchain - none of it is unprecedented in isolation. Apollo and Hamilton Lane reached tokenized credit through Securitize before this, and Baillie Gifford itself ran a tokenized UK credit fund in a feeder version last year. What BAGEY combines is a publicly available UK fund whose register lives natively onchain, holding a risk asset rather than a cash sleeve - and that combination is what makes the next question the interesting one

The register claim is worth getting right. Under PS26/7, an onchain record can be the fund's primary books and records, and BAGEY uses that - a departure from BUIDL, where the token mirrors a register a US transfer agent keeps off-chain. But the FCA still requires Baillie Gifford, as fund manager, to be able to amend the register without third-party consent. A holder's recourse runs through UK fund law like any OEIC shareholder's. The gain is operational - fewer intermediaries, a unit that can move on-chain - not a stronger legal claim than a wrapped fund already offers.

That mobility is where the real question sits. The case for tokenised funds as collateral leans on the 2022 gilt crisis, when pension funds dumped government bonds into a falling market to meet margin calls because their high-quality holdings were too slow to pledge - and the asset that argument reaches for is a stable-NAV money-market fund. BAGEY tests it with a harder one. A BBB, two-year-duration credit portfolio isn't bad collateral, but it carries haircuts, price volatility and eligibility questions a money-market fund doesn't.

Baillie Gifford's own rule is that tokenisation should be "same but better" - the same investor protections, better outcomes. The protections hold and the rails are better. The open question is the cargo. If a credit fund is pledged into the next rate shock, its holders will learn whether a BBB book can be mobilised at a price worth posting - the test a cash fund wouldn't face, and the one this product introduces.

The US Federal Reserve cites data from a 50-person startup founded in 2021. Visa built its Onchain Analytics Dashboard using the same company's infrastructure. DefiLlama, an open-source analytics platform, sources data from it. Allium has raised $40 million in a Series B led by Amplify Partners to scale what it calls the institutional data layer for onchain activity.

Key Points:

The Tokenized Take:

Allium raised $40 million to own the institutional data layer around the same time Dune cut a quarter of its staff and reappeared pitching the same end-to-end stack, ingestion through querying, to the same banks. An incumbent climbing into your lane while you raise is either validation that the lane is real or a warning that margins are about to compress. Which one depends on whether Allium's pricing holds as Dune moves upmarket, or whether institutional buyers treat enriched onchain data can be substituted.

Allium holds the strongest customer proof points and the cleanest delivery model for the institutional buyer. Warehouse-native drops into Snowflake, BigQuery, and Databricks let a bank join onchain data with its CRM, treasury ledger, and KYC records inside its own environment. Dune’s heritage is giving you a hosted SQL editor; its enterprise push is newer. For an institution with a mature data stack and a security team that won't approve another third-party dashboard, that distinction decides the vendor selection.

But pressure is converging from three directions: Dune climbing up with the same pitch; agent-native upstarts like Surf, which raised $15 million in December from Pantera, Coinbase Ventures, and DCG, attacking from below; and L1/L2 chains plus open-source tooling pushing the raw-data floor down.

Raw data is commoditizing. The value is in telling institutions what's real. Allium's estimate that of $62 trillion in annual stablecoin transfers, only roughly $4.2 trillion (~ 7%) represents real economic activity once bots and routing noise are stripped out. That filtered layer is what powers Visa's Onchain Analytics Dashboard. When DefiLlama, an open-source analytics platform, sources data from Allium, it tells you where the trust layer sits. 

Allium is building switching costs around labelled entities, bot filtering, audit trails, warehouse-native delivery, and workflow integration, before Dune, Surf, open-source tooling, and chain-native indexing compress the raw-data layer beneath it.

In our May 14 edition, we noted that the compliance vendor market (Elliptic, Chainalysis, TRM Labs) is recapitalizing because the buyer base shifted from crypto exchanges to Deutsche Bank and Nasdaq. The same TAM expansion applies to data infrastructure, with one distinction worth pricing in. Compliance tools are mandatory; regulators require them. Data infrastructure is a prerequisite to building anything institutional onchain, but it's a choice. And choices face more price pressure than mandates.

Whether Allium's enrichment layer commands Bloomberg-like pricing or gets compressed toward commodity margins as competition converges from all three directions is what the next eighteen months settle on.

Thanks so much for reading the Tokenized Newsletter!

Please share this edition or share it with your colleagues if you enjoyed it!

Disclaimers