Key Takeaways
- • Asia is moving fastest on digital assets through sandboxes, pilots and licensing regimes, with Hong Kong's tokenisation of a China asset management fund described by Standard Chartered as "a reality, not just a pilot project."
- • Europe has built the most comprehensive passportable framework, with MiCA covering 27 markets, the DLT Pilot Regime, and national laws in Germany and Switzerland, but experts say this clarity comes at the cost of slower execution.
- • The US remains the world's deepest capital market but faces regulatory friction from overlapping SEC, CFTC and state rules, though recent moves such as the repeal of SAB 121 and the GENIUS Act are seen as shifting perceptions.
- • Industry participants including State Street, Standard Chartered, DTCC and Deutsche Bank are building multi-jurisdiction custody, collateral and tokenisation capabilities, and experts agree interoperability and shared standards will determine who scales.
Summary
Digital assets, once framed as a single borderless global market, are splintering into regional ecosystems, a divergence the article describes as a "digital assets Cold War" among Asia, Europe and the United States. Asia is prioritising speed and population-scale demand. Boon Hiong Chan, Deutsche Bank's head of Securities Market and Technology Advocacy for APAC, points to mobile-first populations and large under-banked segments as drivers of "fertile demand for alternative financial infrastructure." Singapore, Hong Kong and Japan are advancing sandboxes and licensing regimes, and Chan argues Asian markets should pursue region-specific use cases such as tokenised SME funding rather than copying Western deep-capital-market models.
Europe is prioritising safety, structure and legal certainty. Markus Hammer, chief product officer at BrickMark X, cites MiCA, the DLT Pilot Regime, Germany's eWpG and Switzerland's DLT Act as frameworks that let institutions operate with confidence. He says MiCA provides passportability across 27 markets but suggests a "MiCA II" may be needed to address slower innovation, since tokenised securities remain under full MiFID supervision. BNP Paribas' Verena Hess describes the EU as the first major jurisdiction with a comprehensive, passportable framework for digital assets, and an ESMA spokesperson called MiCA "a revolutionary regulation, unique at the global level." Hammer also points to the UAE, through Dubai's VARA regime and Abu Dhabi's ADGM framework, as an emerging third regulatory centre.
The US is described as retaining deep capital markets while facing regulatory cohesion challenges. Hammer says conflicting interpretations from the SEC, CFTC and state regulators create friction that global institutions prefer to avoid, and German Soto Sanchez of Broadridge describes "stop/start cycles" driven by unclear jurisdictional lines and enforcement-first patterns. A State Street spokesperson says recent developments, including the repeal of Staff Accounting Bulletin No. 121, the GENIUS Act and progress on stablecoin regulation, have changed perceptions toward a "comprehensive, and in some cases more permissive, regulatory stance." Standard Chartered counters that the US is "not losing ground at all" to Asia or Europe and innovates through market behaviour rather than regulatory design.
Industry responses are converging across regimes. State Street plans digital asset custody, tokenised transfer agency and digital collateral management. Standard Chartered is building digital custody capabilities in Luxembourg, Dubai, Hong Kong and Singapore. DTCC is running experiments with Euroclear and Clearstream and moving tokenised Treasuries across ecosystems, and its Nadine Chakar says any token it creates should be interoperable across traditional and blockchain systems. Richard Baker, CEO of Tokenovate, argues that without shared frameworks "digital asset markets cannot scale with confidence or interoperability," and cites the UK's Common Domain Model as a cross-border blueprint. The article's experts broadly agree the outcome will not be winner-takes-all, with BNP Paribas comparing blockchain to the early internet and DTCC expecting scale to come from standards and cross-industry collaboration.
Europe is prioritising safety, structure and legal certainty. Markus Hammer, chief product officer at BrickMark X, cites MiCA, the DLT Pilot Regime, Germany's eWpG and Switzerland's DLT Act as frameworks that let institutions operate with confidence. He says MiCA provides passportability across 27 markets but suggests a "MiCA II" may be needed to address slower innovation, since tokenised securities remain under full MiFID supervision. BNP Paribas' Verena Hess describes the EU as the first major jurisdiction with a comprehensive, passportable framework for digital assets, and an ESMA spokesperson called MiCA "a revolutionary regulation, unique at the global level." Hammer also points to the UAE, through Dubai's VARA regime and Abu Dhabi's ADGM framework, as an emerging third regulatory centre.
The US is described as retaining deep capital markets while facing regulatory cohesion challenges. Hammer says conflicting interpretations from the SEC, CFTC and state regulators create friction that global institutions prefer to avoid, and German Soto Sanchez of Broadridge describes "stop/start cycles" driven by unclear jurisdictional lines and enforcement-first patterns. A State Street spokesperson says recent developments, including the repeal of Staff Accounting Bulletin No. 121, the GENIUS Act and progress on stablecoin regulation, have changed perceptions toward a "comprehensive, and in some cases more permissive, regulatory stance." Standard Chartered counters that the US is "not losing ground at all" to Asia or Europe and innovates through market behaviour rather than regulatory design.
Industry responses are converging across regimes. State Street plans digital asset custody, tokenised transfer agency and digital collateral management. Standard Chartered is building digital custody capabilities in Luxembourg, Dubai, Hong Kong and Singapore. DTCC is running experiments with Euroclear and Clearstream and moving tokenised Treasuries across ecosystems, and its Nadine Chakar says any token it creates should be interoperable across traditional and blockchain systems. Richard Baker, CEO of Tokenovate, argues that without shared frameworks "digital asset markets cannot scale with confidence or interoperability," and cites the UK's Common Domain Model as a cross-border blueprint. The article's experts broadly agree the outcome will not be winner-takes-all, with BNP Paribas comparing blockchain to the early internet and DTCC expecting scale to come from standards and cross-industry collaboration.
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