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The Corporate Bitcoin Rush: How 228 Public Companies Built $148B in Digital Asset Treasuries

· 10 min read
Dora Noda
Software Engineer

In January 2025, roughly 70 public companies held Bitcoin on their balance sheets. By October, that number had surged past 228. Collectively, these "Digital Asset Treasury" (DAT) companies now hold approximately $148 billion in Bitcoin and other cryptocurrencies—a threefold increase in market capitalization from the $40 billion recorded just twelve months earlier.

This isn't speculation anymore. It's a structural shift in how corporations think about their balance sheets.

The numbers tell a story of accelerating institutional adoption: public companies now control 4.07% of all Bitcoin that will ever exist, up from 3.3% at the start of the year. Private businesses have pushed total corporate Bitcoin holdings to 6.2% of supply—a staggering 21x increase since January 2020. And $12.5 billion in new business Bitcoin inflows during just eight months of 2025 exceeded all of 2024's total.

But this gold rush has a darker side. Strategy's stock plummeted 52% from its peak. Semler Scientific dropped 74%. GameStop's Bitcoin pivot flopped. The "premium era is over," as one analyst put it. What's driving this corporate Bitcoin frenzy, who's winning, and who's getting crushed?

The New Rules of Corporate Finance

Two forces converged in 2025 to transform Bitcoin from a speculative curiosity into a legitimate corporate treasury asset: regulatory clarity and accounting reform.

FASB Changes Everything

For years, companies holding Bitcoin faced an accounting nightmare. Under the old rules, crypto assets were treated as indefinite-lived intangible assets—meaning companies could only record impairments (losses) but never recognize gains until they sold. A company that bought Bitcoin at $20,000 and watched it rise to $100,000 would still carry it at cost, but if the price dipped to $19,000 for even a moment, they'd have to write it down.

That changed on January 1, 2025, when FASB's ASU 2023-08 became mandatory for all calendar-year entities. The new standard requires companies to measure crypto assets at fair value each reporting period, reflecting both gains and losses in net income.

The impact was immediate. Tesla, which holds 11,509 BTC unchanged since early purchases, recorded a $600 million mark-to-market gain under the new rules. Companies that had been sitting on unrealized gains could finally report them. Bitcoin became a much cleaner asset for corporate balance sheets.

Regulatory Tailwinds

The GENIUS Act and CLARITY Act moving through Congress in 2025 provided something corporate treasurers had been waiting for: predictability. While neither bill has fully passed, the bipartisan momentum signaled that crypto wasn't going to be regulated out of existence.

For CFOs evaluating Bitcoin as a treasury asset, this regulatory trajectory matters more than any specific rule. The risk of holding an asset that might be banned or severely restricted dropped significantly. "Once Bitcoin rebounds," one analyst noted, "no CFO wants to be the one who ignored the cheapest balance-sheet trade of the cycle."

The Titans: Who Holds What

The corporate Bitcoin landscape is dominated by a handful of massive players, but the field is rapidly expanding.

Strategy: The $33 Billion Behemoth

Michael Saylor's company—now rebranded from MicroStrategy to simply "Strategy"—remains the undisputed king. As of January 2026, the firm holds 673,783 BTC acquired at an average price of $66,385, representing a total investment of $33.1 billion.

Strategy's "42/42 Plan" (originally the "21/21 Plan" before being doubled) targets $84 billion in capital raises through 2027—$42 billion in equity and $42 billion in fixed-income securities—to continue Bitcoin accumulation. In 2025 alone, they raised $6.8 billion through at-the-market programs and preferred stock offerings.

The scale is unprecedented. Strategy now controls approximately 3.2% of all Bitcoin that will ever exist. MSCI's decision to maintain the company's index status validated the "Digital Asset Treasury" model and made MSTR a primary vehicle for institutional Bitcoin exposure.

Marathon Digital: The Mining Powerhouse

MARA Holdings sits second with 46,376 BTC as of March 2025. Unlike Strategy, which simply buys Bitcoin, Marathon produces it through mining operations—giving the company a different cost basis and operational profile.

What sets MARA apart in 2025 is yield generation. The company began lending out portions of its holdings—7,377 BTC as of January 2025—to generate single-digit percentage returns. This addresses one of the key criticisms of corporate Bitcoin holdings: that they're dead assets producing no income.

Metaplanet: Asia's Biggest Bet

Tokyo-listed Metaplanet emerged as the breakout story of 2025. The company acquired 30,823 BTC valued at $2.7 billion by year-end, making it Asia's largest corporate Bitcoin holder and a global top-ten treasury.

Metaplanet's ambition extends further: 100,000 BTC by end of 2026 and 210,000 BTC by 2027—roughly 1% of total Bitcoin supply. The company represents the model going international, proving the Strategy playbook works beyond U.S. markets.

Twenty One Capital: The Tether-Backed Newcomer

Twenty One Capital launched as the "super newcomer" of 2025. This new entity went public through a SPAC merger with Cantor Equity Partners, backed by an unlikely coalition: Cantor Fitzgerald, Tether, SoftBank, and Bitfinex.

The initial raise brought $360 million and 42,000 BTC (valued at approximately $3.9 billion) onto the balance sheet. Tether contributed $160 million; SoftBank added $900 million; Bitfinex contributed $600 million. Twenty One represents the institutionalization of the DAT model—major financial players building purpose-built Bitcoin treasury vehicles.

The Newcomers: Mixed Results

Not every company riding the Bitcoin treasury wave found success.

GameStop: The Meme Stock Struggles Again

GameStop announced in March 2025 that it was issuing $1.3 billion in zero-coupon convertible bonds specifically for Bitcoin purchases. By May, the company had acquired 4,710 BTC.

The market reaction was brutal. Shares briefly jumped 7% on the announcement before crashing double digits. Three months later, the stock remained down over 13%. GameStop proved that a Bitcoin pivot couldn't cure fundamental business problems—and that investors could see through purely financial engineering.

Semler Scientific: From Hero to Acquisition

Semler Scientific, a healthcare technology company, saw its stock rise fivefold after announcing its Bitcoin treasury transformation in May 2024. By April 2025, the company planned to issue $500 million in securities explicitly for Bitcoin purchases.

But the 2025 downturn hit hard. Semler's stock dropped 74% from peak levels. In September 2025, Strive, Inc. announced an all-stock acquisition of Semler—a merger of two Bitcoin treasuries that looked less like expansion and more like consolidation of wounded players.

The Copycat Problem

"Not everyone can be Strategy," observed one analyst, "and there's no surefire formula that says a quick rebranding or merger plus adding bitcoin equals success."

Companies including Solarbank and ECD Automotive Design announced Bitcoin pivots hoping for stock pops. None materialized. The market began distinguishing between companies with genuine Bitcoin strategies and those using crypto as a PR tactic.

The Hidden Story: Small Business Adoption

While public company treasuries grab headlines, the real adoption story might be happening in private businesses.

According to the River Business Report 2025, small businesses are leading Bitcoin adoption: 75% of business Bitcoin users have fewer than 50 employees. These companies allocate a median 10% of net income to Bitcoin purchases.

The appeal for small businesses differs from public company motivations. Without access to sophisticated treasury management tools, Bitcoin offers a simple inflation hedge. Without public market scrutiny, they can hold through volatility without quarterly earnings pressure. Tax-loss harvesting strategies—selling at losses to offset gains, then immediately repurchasing (legal for Bitcoin but not stocks)—provide additional flexibility.

The Bear Case Emerges

The 2025 market correction exposed fundamental questions about the DAT model.

Leverage and Dilution

Strategy's model depends on continuously raising capital to buy more Bitcoin. When Bitcoin prices fall, the company's stock falls faster due to leverage effects. This creates pressure to issue more shares at lower prices—diluting existing shareholders to maintain the acquisition pace.

Since Bitcoin plummeted 30% from its October 2025 high, treasury companies entered what critics called a "death spiral." Strategy shares fell 52%. The premium investors paid for Bitcoin exposure through these stocks evaporated.

"The Premium Era Is Over"

"We're entering a phase where only disciplined structures and real business execution are going to survive," warned John Fakhoury of Stacking Sats. The structural weaknesses—leverage, dilution, and reliance on continuous capital raises—became impossible to ignore.

For companies with actual operating businesses, adding Bitcoin might enhance shareholder value. For companies whose entire thesis is Bitcoin accumulation, the model faces existential questions when Bitcoin prices decline.

What Comes Next

Despite the challenges, the trend isn't reversing. Bernstein analysts project public companies globally could allocate $330 billion to Bitcoin over the next five years. Standard Chartered expects this corporate treasury adoption to drive Bitcoin toward $200,000.

Several developments will shape 2026:

FASB Expansion

In August 2025, FASB added a research project on digital assets to "explore targeted improvements to the accounting for and disclosure of certain digital assets and related transactions." This signals potential further normalization of crypto assets in corporate accounting.

Global Tax Coordination

The OECD's Crypto-Asset Reporting Framework (CARF) now has 50 jurisdictions committed to implementation by 2027. This standardization of crypto tax reporting will make corporate Bitcoin holdings more administratively manageable across borders.

Yield Generation Models

MARA's lending program points toward the future. Companies are exploring ways to make Bitcoin holdings productive rather than simply sitting on cold storage. DeFi integration, institutional lending, and Bitcoin-backed financing will likely expand.

Strategic Reserve Implications

If governments begin holding Bitcoin as strategic reserves—a possibility that seemed absurd five years ago but is now actively discussed—corporate treasuries will face new competitive dynamics. Corporate and sovereign demand for a fixed-supply asset creates interesting game theory.

The Bottom Line

The corporate Bitcoin treasury movement of 2025 represents something genuinely new in financial history: hundreds of public companies betting their balance sheets on a 16-year-old digital asset with no cash flows, no earnings, and no yield.

Some will look brilliant—companies that accumulated at 2024-2025 prices and held through inevitable volatility. Others will look like cautionary tales—companies that used Bitcoin as a Hail Mary for failing businesses or leveraged themselves into insolvency.

The 228 public companies now holding $148 billion in crypto treasuries have made their bets. The regulatory framework is clarifying. The accounting rules finally work. The question isn't whether corporate Bitcoin adoption will continue—it's which companies will survive the volatility to benefit from it.

For builders and investors watching this space, the lesson is nuanced: Bitcoin as a treasury asset works for companies with genuine operational strengths and disciplined capital allocation. It's not a substitute for business fundamentals. The premium era may indeed be over, but the infrastructure era for corporate crypto has just begun.


This article is for educational purposes only and should not be considered financial advice. The author holds no positions in any companies mentioned.

The Yield Stablecoin Wars: How USDe and USDS Are Reshaping the $310B Market

· 11 min read
Dora Noda
Software Engineer

In early 2024, yield-bearing stablecoins held about $1.5 billion in total supply. By mid-2025, that figure had exploded past $11 billion—a 7x increase that represents the fastest-growing segment of the entire stablecoin market.

The appeal is obvious: why hold dollars that earn nothing when you could hold dollars that earn 7%, or 15%, or even 20%? But the mechanisms generating these yields are anything but simple. They involve derivatives strategies, perpetual futures funding rates, Treasury bills, and complex smart contract systems that even experienced DeFi users struggle to fully understand.

And just as this new category gained momentum, regulators stepped in. The GENIUS Act, signed into law in July 2025, explicitly prohibits stablecoin issuers from offering yield to retail customers. Yet instead of killing yield-bearing stablecoins, the regulation triggered a flood of capital into protocols that found ways to stay compliant—or operate outside U.S. jurisdiction entirely.

This is the story of how stablecoins evolved from simple dollar pegs into sophisticated yield-generating instruments, who's winning the battle for $310 billion in stablecoin capital, and what risks investors face in this new paradigm.

The Market Landscape: $33 Trillion in Motion

Before diving into yield mechanisms, the scale of the stablecoin market deserves attention.

Stablecoin transaction volumes soared 72% to hit $33 trillion in 2025, according to Artemis Analytics. Total supply reached nearly $310 billion by mid-December—up more than 50% from $205 billion at the start of the year. Bloomberg Intelligence projects stablecoin payment flows could reach $56.6 trillion by 2030.

The market remains dominated by two giants. Tether's USDT holds about 60% market share with $186.6 billion in circulation. Circle's USDC commands roughly 25% with $75.12 billion. Together they control 85% of the market.

But here's the interesting twist: USDC led transaction volume with $18.3 trillion, beating USDT's $13.3 trillion despite having a smaller market cap. This higher velocity reflects USDC's deeper DeFi integration and regulatory compliance positioning.

Neither USDT nor USDC offers yield. They're the stable, boring bedrock of the ecosystem. The action—and the risk—lives in the next generation of stablecoins.

How Ethena's USDe Actually Works

Ethena's USDe emerged as the dominant yield-bearing stablecoin, reaching over $9.5 billion in circulation by mid-2025. Understanding how it generates yield requires understanding a concept called delta-neutral hedging.

The Delta-Neutral Strategy

When you mint USDe, Ethena doesn't just hold your collateral. The protocol takes your ETH or BTC, holds it as the "long" position, and simultaneously opens a short perpetual futures position of the same size.

If ETH rises 10%, the spot holdings gain value, but the short futures position loses an equivalent amount. If ETH falls 10%, the spot holdings lose value, but the short futures position gains. The result is delta-neutral—price movements in either direction cancel out, maintaining the dollar peg.

This is clever, but it raises an obvious question: if price movements net to zero, where does the yield come from?

The Funding Rate Engine

Perpetual futures contracts use a mechanism called funding rates to keep their prices aligned with spot markets. When the market is bullish and more traders are long than short, longs pay shorts a funding fee. When the market is bearish, shorts pay longs.

Historically, crypto markets trend bullish, meaning funding rates are positive more often than negative. Ethena's strategy collects these funding payments continuously. In 2024, sUSDe—the staked version of USDe—delivered an average APY of 18%, with peaks touching 55.9% during the March 2024 rally.

The protocol adds additional yield from staking a portion of its ETH collateral (earning Ethereum's native staking yield) and from interest on liquid stablecoin reserves held in instruments like BlackRock's BUIDL tokenized Treasury fund.

The Risks Nobody Wants to Discuss

The delta-neutral strategy sounds elegant, but it carries specific risks.

Funding Rate Reversal: During sustained bear markets, funding rates can turn negative for extended periods. When this happens, Ethena's short positions pay longs instead of receiving payments. The protocol maintains a reserve fund to cover these periods, but a prolonged downturn could drain reserves and force yield rates to zero—or worse.

Exchange Risk: Ethena holds its futures positions on centralized exchanges like Binance, Bybit, and OKX. While collateral is held with off-exchange custodians, the counterparty risk of exchange insolvency remains. An exchange failure during volatile markets could leave the protocol unable to close positions or access funds.

Liquidity and Depeg Risk: If confidence in USDe falters, a wave of redemptions could force the protocol to unwind positions rapidly in illiquid markets, potentially breaking the peg.

During August 2024, when funding rates compressed, sUSDe yields dropped to about 4.3%—still positive, but far from the double-digit returns that attracted initial capital. Recent yields have ranged between 7% and 30% depending on market conditions.

Sky's USDS: The MakerDAO Evolution

While Ethena bet on derivatives, MakerDAO (now rebranded as Sky) took a different path for its yield-bearing stablecoin.

From DAI to USDS

In May 2025, MakerDAO completed its "Endgame" transformation, retiring the MKR governance token, launching SKY at a 24,000:1 conversion ratio, and introducing USDS as the successor to DAI.

USDS supply surged from 98.5 million to 2.32 billion in just five months—a 135% increase. The Sky Savings Rate platform reached $4 billion in TVL, growing 60% in 30 days.

Unlike Ethena's derivatives strategy, Sky generates yield through more traditional means: lending revenue from the protocol's credit facilities, fees from the stablecoin operations, and interest from real-world asset investments.

The Sky Savings Rate

When you hold sUSDS (the yield-bearing wrapped version), you automatically earn the Sky Savings Rate—currently around 4.5% APY. Your balance increases over time without needing to lock, stake, or take any action.

This is lower than Ethena's typical yields, but it's also more predictable. Sky's yield comes from lending activity and Treasury exposure rather than volatile funding rates.

Sky activated USDS rewards for SKY stakers in May 2025, distributing over $1.6 million in the first week. The protocol now allocates 50% of revenue to stakers, and spent $96 million in 2025 on buybacks that reduced SKY's circulating supply by 5.55%.

The $2.5 Billion Institutional Bet

In a significant move, Sky approved a $2.5 billion USDS allocation to Obex, an incubator led by Framework Ventures targeting institutional-grade DeFi yield projects. This signals Sky's ambition to compete for institutional capital—the largest untapped pool of potential stablecoin demand.

The Frax Alternative: Chasing the Fed

Frax Finance represents perhaps the most ambitious regulatory strategy in yield-bearing stablecoins.

Treasury-Backed Yield

Frax's sFRAX and sfrxUSD stablecoins are backed by short-term U.S. Treasuries, purchased through a lead bank brokerage relationship with a Kansas City bank. The yield tracks the Federal Reserve's rates, currently delivering around 4.8% APY.

Over 60 million sFRAX are currently staked. While yields are lower than Ethena's peaks, they're backed by the U.S. government's credit rather than crypto derivatives—a fundamentally different risk profile.

The Fed Master Account Gambit

Frax is actively pursuing a Federal Reserve master account—the same type of account that banks use for direct access to Fed payment systems. If successful, this would represent unprecedented integration between DeFi and traditional banking infrastructure.

The strategy positions Frax as the most regulation-compliant yield-bearing stablecoin, potentially appealing to institutional investors who can't touch Ethena's derivatives exposure.

The GENIUS Act: Regulation Arrives

The Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act), signed in July 2025, brought the first comprehensive federal framework for stablecoins—and immediate controversy.

The Yield Prohibition

The act explicitly prohibits stablecoin issuers from paying interest or yield to holders. The intent is clear: prevent stablecoins from competing with bank deposits and FDIC-insured accounts.

Banks lobbied hard for this provision, warning that yield-bearing stablecoins could drain $6.6 trillion from the traditional banking system. The concern isn't abstract: when you can earn 7% on a stablecoin versus 0.5% in a savings account, the incentive to move money is overwhelming.

The Loophole Problem

However, the act doesn't explicitly prohibit affiliated third parties or exchanges from offering yield-bearing products. This loophole allows protocols to restructure so that the stablecoin issuer doesn't directly pay yield, but an affiliated entity does.

Banking groups are now lobbying to close this loophole before implementation deadlines in January 2027. The Bank Policy Institute and 52 state banking associations sent a letter to Congress arguing that exchange-offered yield programs create "high-yield shadow banks" without consumer protections.

Ethena's Response: USDtb

Rather than fight regulators, Ethena launched USDtb—a U.S.-regulated variant backed by tokenized money-market funds rather than crypto derivatives. This makes USDtb compliant with GENIUS Act requirements while preserving Ethena's infrastructure for institutional customers.

The strategy reflects a broader pattern: yield-bearing protocols are forking into compliant (lower yield) and non-compliant (higher yield) versions, with the latter increasingly serving non-U.S. markets.

Comparing the Options

For investors navigating this landscape, here's how the major yield-bearing stablecoins stack up:

sUSDe (Ethena): Highest potential yields (7-30% depending on market conditions), but exposed to funding rate reversals and exchange counterparty risk. Largest market cap among yield-bearing options. Best for crypto-native users comfortable with derivatives exposure.

sUSDS (Sky): Lower but more stable yields (~4.5%), backed by lending revenue and RWAs. Strong institutional positioning with the $2.5B Obex allocation. Best for users seeking predictable returns with lower volatility.

sFRAX/sfrxUSD (Frax): Treasury-backed yields (~4.8%), most regulatory compliant approach. Pursuing Fed master account. Best for users prioritizing regulatory safety and traditional finance integration.

sDAI (Sky/Maker): The original yield-bearing stablecoin, still functional alongside USDS with 4-8% yields through the Dynamic Savings Rate. Best for users already in the Maker ecosystem.

The Risks That Keep Me Up at Night

Every yield-bearing stablecoin carries risks beyond what their marketing materials suggest.

Smart Contract Risk: Every yield mechanism involves complex smart contracts that could contain undiscovered vulnerabilities. The more sophisticated the strategy, the larger the attack surface.

Regulatory Risk: The GENIUS Act loophole may close. International regulators may follow the U.S. lead. Protocols may be forced to restructure or cease operations entirely.

Systemic Risk: If multiple yield-bearing stablecoins face redemption pressure simultaneously—during a market crash, regulatory crackdown, or confidence crisis—the resulting liquidations could cascade across DeFi.

Yield Sustainability: High yields attract capital until competition compresses returns. What happens to USDe's TVL when yields drop to 3% and stay there?

Where This Goes Next

The yield-bearing stablecoin category has grown from novelty to $11 billion in assets remarkably quickly. Several trends will shape its evolution.

Institutional Entry: As Sky's Obex allocation demonstrates, protocols are positioning for institutional capital. This will likely drive more conservative, Treasury-backed products rather than derivatives-based high yields.

Regulatory Arbitrage: Expect continued geographic fragmentation, with higher-yield products serving non-U.S. markets while compliant versions target regulated institutions.

Competition Compression: As more protocols enter the yield-bearing space, yields will compress toward traditional money market rates plus a DeFi risk premium. The 20%+ yields of early 2024 are unlikely to return sustainably.

Infrastructure Integration: Yield-bearing stablecoins will increasingly become the default settlement layer for DeFi, replacing traditional stablecoins in lending protocols, DEX pairs, and collateral systems.

The Bottom Line

Yield-bearing stablecoins represent a genuine innovation in how digital dollars work. Instead of idle capital, stablecoin holdings can now earn returns that range from Treasury-rate equivalents to double-digit yields.

But these yields come from somewhere. Ethena's returns come from derivatives funding rates that can reverse. Sky's yields come from lending activity that carries credit risk. Frax's yields come from Treasuries, but require trusting the protocol's banking relationships.

The GENIUS Act's yield prohibition reflects regulators' understanding that yield-bearing stablecoins compete directly with bank deposits. Whether current loopholes survive through 2027 implementation remains uncertain.

For users, the calculus is straightforward: higher yields mean higher risks. sUSDe's 15%+ returns during bull markets require accepting exchange counterparty risk and funding rate volatility. sUSDS's 4.5% offers more stability but less upside. Treasury-backed options like sFRAX provide government-backed yield but minimal premium over traditional finance.

The yield stablecoin wars have just begun. With $310 billion in stablecoin capital up for grabs, protocols that find the right balance of yield, risk, and regulatory compliance will capture enormous value. Those that miscalculate will join the crypto graveyard.

Choose your risks accordingly.


This article is for educational purposes only and should not be considered financial advice. Yield-bearing stablecoins carry risks including but not limited to smart contract vulnerabilities, regulatory changes, and collateral devaluation.

The Corporate Bitcoin Treasury Surge: 191 Public Companies Now Hold BTC on Their Balance Sheets

· 7 min read
Dora Noda
Software Engineer

In August 2020, a struggling business intelligence company made a $250 million bet that seemed reckless at the time. Today, that company—now rebranded simply as "Strategy"—holds 671,268 Bitcoin worth over $60 billion, and its playbook has spawned an entirely new corporate category: the Bitcoin Treasury Company.

The numbers tell a remarkable story: 191 public companies now hold Bitcoin in their treasury reserves. Businesses control 6.2% of total Bitcoin supply—1.3 million BTC—with $12.5 billion in new corporate inflows in 2025 alone, surpassing all of 2024. What started as Michael Saylor's contrarian thesis has become a global corporate strategy replicated from Tokyo to São Paulo.

Hyperliquid's $844M Revenue Machine: How a Single DEX Outearned Ethereum in 2025

· 9 min read
Dora Noda
Software Engineer

In 2025, something unprecedented happened in crypto: a single decentralized exchange generated more revenue than the entire Ethereum blockchain. Hyperliquid, a purpose-built Layer 1 for perpetual futures trading, closed the year with $844 million in revenue, $2.95 trillion in trading volume, and over 80% market share in decentralized derivatives.

The numbers force a question: How did a protocol that didn't exist three years ago surpass networks with $100 billion+ in total value locked?

The answer reveals a fundamental shift in how value accrues in crypto—from general-purpose chains to application-specific protocols optimized for a single use case. While Ethereum struggles with revenue concentration in lending and liquid staking, and Solana builds its brand on memecoins and retail speculation, Hyperliquid quietly became the most profitable trading venue in DeFi.

The Revenue Landscape: Where the Money Actually Goes

The 2025 blockchain revenue rankings shattered assumptions about which networks capture value.

According to CryptoRank data, Solana led all blockchains with $1.3-1.4 billion in revenue, driven by its spot DEX volume and memecoin trading. Hyperliquid ranked second with $814-844 million—despite being an L1 with a single primary application. Ethereum, the blockchain that supposedly anchors DeFi, came in fourth with roughly $524 million.

The implications are stark. Ethereum's share of app revenue has declined from 50% in early 2024 to just 25% by Q4 2025. Meanwhile, Hyperliquid controlled over 35% of all blockchain revenue at its peak.

What's remarkable is the concentration. Solana's revenue comes from hundreds of applications—Pump.fun, Jupiter, Raydium, and dozens of others. Ethereum's revenue distributes across thousands of protocols. Hyperliquid's revenue comes almost entirely from one thing: perpetual futures trading on its native DEX.

This is the new economics of crypto: specialized protocols that do one thing extremely well can outperform generalized chains that do everything adequately.

How Hyperliquid Built a Trading Machine

Hyperliquid's architecture represents a fundamental bet against the "general-purpose blockchain" thesis that dominated 2017-2022 thinking.

The Technical Foundation

The platform runs on HyperBFT, a custom consensus algorithm inspired by Hotstuff. Unlike chains that optimize for arbitrary smart contract execution, HyperBFT is purpose-built for high-frequency order matching. The result: theoretical throughput of 200,000 orders per second with sub-second finality.

The architecture splits into two components. HyperCore handles the core trading infrastructure—fully on-chain order books for perpetuals and spot markets, with every order, cancellation, trade, and liquidation happening transparently on-chain. HyperEVM adds Ethereum-compatible smart contracts, letting developers build on top of the trading primitive.

This dual approach means Hyperliquid isn't choosing between performance and composability—it's achieving both by separating concerns.

The Order Book Advantage

Most DEXs use Automated Market Makers (AMMs), where liquidity pools determine pricing. Hyperliquid implements a Central Limit Order Book (CLOB), the same architecture used by every major centralized exchange.

The difference matters enormously for professional traders. CLOBs deliver precise price discovery, minimal slippage on large orders, and familiar trading interfaces. For anyone accustomed to trading on Binance or CME, Hyperliquid feels native in a way that Uniswap or GMX never could.

By processing perpetual futures—the highest-volume derivative in crypto—through an on-chain order book, Hyperliquid captured professional trading flow that previously had no viable decentralized alternative.

Zero Gas Fees, Maximum Velocity

Perhaps most importantly, Hyperliquid eliminated gas fees for trading. When you place or cancel an order, you pay nothing. This removes the friction that prevents high-frequency strategies from working on Ethereum or even Solana.

The result is trading behavior that matches centralized exchanges. Traders can place and cancel thousands of orders without worrying about transaction costs eating into returns. Market makers can quote tight spreads knowing they won't be penalized for cancellations.

The Numbers That Matter

Hyperliquid's 2025 performance validates the application-specific thesis with brutal clarity.

Trading Volume: $2.95 trillion cumulative, with peak months exceeding $400 billion. For context, Robinhood's crypto trading volume in 2025 was roughly $380 billion—Hyperliquid briefly surpassed it.

Market Share: 70%+ of decentralized perpetual futures volume in Q3 2025, with peaks above 80%. The protocol's aggregate market share versus centralized exchanges reached 6.1%, a record for any DEX.

User Growth: 609,000 new users onboarded during the year, with $3.8 billion in net inflows.

TVL: Approximately $4.15 billion, making it one of the largest DeFi protocols by locked value.

Token Performance: HYPE launched at $3.50 in November 2024 and peaked above $35 in January 2025—a 10x return in under three months.

The revenue model is elegantly simple. The platform collects trading fees and uses 97% of them to buy and burn HYPE tokens. This creates constant buy pressure that scales with trading volume, turning Hyperliquid into a revenue-sharing machine for token holders.

The JELLY Wake-Up Call

Not everything was smooth. In March 2025, Hyperliquid faced its most serious crisis when a sophisticated exploit nearly drained $12 million from the protocol.

The attack exploited how Hyperliquid handled liquidations for illiquid tokens. An exploiter deposited $7 million across three accounts, took leveraged long positions on JELLY (a low-liquidity token) on two accounts, and opened a massive short on the third. By pumping JELLY's price 429%, they triggered their own liquidation—but the position was too large to liquidate normally, forcing it onto Hyperliquid's insurance fund.

What happened next revealed uncomfortable truths. Within two minutes, Hyperliquid's validators reached consensus to delist JELLY and settled all positions at $0.0095 (the attacker's entry price) rather than the $0.50 market price. The attacker walked away with $6.26 million.

The rapid validator consensus exposed significant centralization. Bitget's CEO called the response "immature, unethical, and unprofessional," warning Hyperliquid risked becoming "FTX 2.0." Critics pointed out that the same protocol that ignored North Korean hackers trading with stolen funds acted immediately when its own treasury was threatened.

Hyperliquid responded by refunding affected traders and implementing stricter controls on illiquid asset listings. But the incident revealed the tension inherent in "decentralized" exchanges that can freeze accounts and reverse transactions when convenient.

Hyperliquid vs. Solana: Different Games

The comparison between Hyperliquid and Solana illuminates different visions for crypto's future.

Solana pursues the general-purpose blockchain dream: a single high-performance network hosting everything from memecoins to DeFi to gaming. Its $1.6 trillion in spot DEX volume during 2025 came from hundreds of applications and millions of users.

Hyperliquid bets on vertical integration: one chain, one application, one mission—being the best perpetual futures exchange in existence. Its $2.95 trillion in volume came almost entirely from derivatives traders.

The revenue comparison is instructive. Solana processed roughly $343 billion in 30-day perp volume through multiple protocols. Hyperliquid processed $343 billion through a single platform—and generated comparable revenue despite lower spot trading activity.

Where Solana wins: broad ecosystem diversity, consumer applications, and memecoin speculation. Solana's DEX volume exceeded $100 billion monthly for six consecutive months, driven by platforms like Pump.fun.

Where Hyperliquid wins: professional trading execution, perpetual futures liquidity, and institutional-grade infrastructure. Professional traders migrated specifically because Hyperliquid rivals centralized exchanges in execution quality.

The verdict? Different markets. Solana captures retail enthusiasm and speculative activity. Hyperliquid captures professional trading flow and derivatives volume. Both generated massive revenue in 2025—suggesting there's room for multiple approaches.

Competition Is Coming

Hyperliquid's dominance isn't guaranteed. By late 2025, competitors Lighter and Aster briefly surpassed Hyperliquid in perpetual trading volume by capturing memecoin liquidity rotations. The protocol's market share fragmented from 70% to a more contested landscape.

This mirrors Hyperliquid's own history. In 2023-2024, it disrupted incumbents dYdX and GMX with superior execution and zero-fee trading. Now new entrants apply the same playbook against Hyperliquid.

The broader perpetual market tripled to $1.8 trillion in 2025, suggesting rising tides could lift all participants. But Hyperliquid will need to defend its moat against increasingly sophisticated competitors.

The real competition may come from centralized exchanges. When analysts were asked who could realistically challenge Hyperliquid, they pointed not to other DEXs but to Binance, Coinbase, and other CEXs that might copy its features while offering deeper liquidity.

What Hyperliquid's Success Means

Hyperliquid's breakout year offers several lessons for the industry.

Application-specific chains work. The thesis that dedicated L1s optimized for single use cases would outperform general-purpose chains just received a $844 million proof point. Expect more projects to follow this model.

Professional traders want real exchanges, not AMMs. The success of on-chain order books validates that sophisticated traders will use DeFi when it matches CEX execution quality. AMMs may be adequate for casual swaps, but derivatives require proper market structure.

Revenue beats TVL as a metric. Hyperliquid's TVL is modest compared to Ethereum DeFi giants like Aave or Lido. But it generates far more revenue. This suggests crypto is maturing toward businesses valued on actual economic activity rather than locked capital.

Centralization concerns persist. The JELLY incident showed that "decentralized" protocols can act very centralized when their treasuries are threatened. This tension will define DeFi's evolution in 2026.

Looking Forward

Analysts project HYPE could reach $80 by late 2026 if current trends continue, assuming the stablecoin market expands and Hyperliquid maintains its trading share. More conservative estimates depend on whether the protocol can fend off emerging competitors.

The broader shift is unmistakable. Ethereum's declining revenue share, Solana's memecoin-driven growth, and Hyperliquid's derivatives dominance represent three different visions of how crypto creates value. All three are generating meaningful revenue—but the application-specific approach is punching far above its weight.

For builders, the lesson is clear: find a specific high-value activity, optimize relentlessly for it, and capture the entire value chain. For traders, Hyperliquid offers what DeFi always promised—permissionless, non-custodial, professional-grade trading—finally delivered at scale.

The question for 2026 isn't whether decentralized trading can generate revenue. It's whether any single platform can maintain dominance in an increasingly competitive market.


This article is for educational purposes only and should not be considered financial advice. The author holds no positions in HYPE, SOL, or ETH.

The Yield-Bearing Stablecoin Revolution: How USDe, USDS, and USD1 Are Redefining Dollar Exposure

· 9 min read
Dora Noda
Software Engineer

There's no such thing as free yield. Yet yield-bearing stablecoins now command $11 billion in supply—up from $1.5 billion in early 2024—with JPMorgan predicting they could capture 50% of the entire stablecoin market. In a world where USDT and USDC offer 0% returns, protocols promising 6-20% APY on dollar-pegged assets are rewriting the rules of what stablecoins can be.

But here's the uncomfortable truth: every percentage point of yield comes with corresponding risk. The recent USDO depeg to $0.87 reminded markets that even "stable" coins can break. Understanding how these next-generation stablecoins actually work—and what can go wrong—has become essential for anyone allocating capital in DeFi.

Inside the $1.5 Billion Bybit Heist: How North Korea Pulled Off History's Largest Crypto Theft

· 10 min read
Dora Noda
Software Engineer

On February 21, 2025, North Korean hackers stole $1.5 billion in cryptocurrency from Dubai-based exchange Bybit in approximately 30 minutes. It wasn't just the largest crypto heist in history—if Bybit were a bank, it would rank as the largest bank robbery ever recorded by Guinness World Records.

The attack didn't exploit a smart contract bug or brute-force a private key. Instead, hackers compromised a single developer's laptop at a third-party wallet provider, waited patiently for weeks, and struck when Bybit employees were approving what looked like a routine internal transfer. By the time anyone realized something was wrong, 500,000 ETH had vanished into a labyrinth of wallets controlled by North Korea's Lazarus Group.

This is the story of how it happened, why it matters, and what it reveals about the state of crypto security in 2025.

The Attack: A Masterclass in Patience and Precision

The Bybit hack wasn't a smash-and-grab. It was a surgical operation that unfolded over weeks.

Phase 1: Compromising the Developer

On February 4, 2025, a developer at Safe{Wallet}—a widely-used multi-signature wallet platform that Bybit relied on for securing large transfers—downloaded what appeared to be a legitimate Docker project called "MC-Based-Stock-Invest-Simulator-main." The file likely arrived via a social engineering attack, possibly disguised as a job opportunity or investment tool.

The malicious Docker container immediately established a connection to an attacker-controlled server. From there, the hackers extracted AWS session tokens from the developer's workstation—the temporary credentials that grant access to Safe{Wallet}'s cloud infrastructure.

With these tokens, the attackers bypassed multi-factor authentication entirely. They now had the keys to Safe{Wallet}'s kingdom.

Phase 2: The Dormant Code

Rather than act immediately, the attackers injected subtle JavaScript code into Safe{Wallet}'s web interface. This code was specifically designed for Bybit—it would lie dormant until detecting that a Bybit employee had opened their Safe account and was about to authorize a transaction.

The sophistication here is remarkable. The entire Safe{Wallet} application functioned normally for every other user. Only Bybit was targeted.

Phase 3: The Heist

On February 21, 2025, Bybit employees initiated what should have been a routine transfer from a cold wallet (secure, offline storage) to a warm wallet (for active trading). This required multiple signatures from authorized personnel—a standard security practice called multisig.

When the signers opened Safe{Wallet} to approve the transaction, the interface displayed what appeared to be the correct destination address. But the malicious code had already swapped in a different command. The employees unknowingly approved a transaction that drained Bybit's entire cold wallet.

Within minutes, 500,000 ETH—worth approximately $1.5 billion—flowed to addresses controlled by the attackers.

The Technical Exploit: Delegatecall

The key vulnerability was Ethereum's delegatecall function, which allows a smart contract to execute another contract's code within its own storage context. The attackers tricked Bybit's signers into changing their wallet's contract logic to a malicious version, effectively granting full control to the hackers.

This wasn't a bug in Ethereum or in Safe{Wallet}'s core protocol. It was an attack on the human layer—the moment when trusted employees verify and approve transactions.

North Korea's Lazarus Group: The World's Most Profitable Hackers

Within 24 hours of the attack, blockchain investigator ZachXBT submitted evidence to Arkham Intelligence definitively connecting the hack to North Korea's Lazarus Group. The FBI confirmed this attribution on February 26, 2025.

Lazarus Group—also known as TraderTraitor and APT38—operates under North Korea's Reconnaissance General Bureau. It's not a criminal gang seeking profit for personal enrichment. It's a state-sponsored operation whose proceeds fund North Korea's nuclear weapons and ballistic missile programs.

The numbers are staggering:

  • 2025 alone: North Korean hackers stole $2.02 billion in cryptocurrency
  • Bybit's share: $1.5 billion (74% of North Korea's 2025 haul from a single attack)
  • Since 2017: North Korea has stolen over $6.75 billion in crypto assets
  • 2025 vs 2024: 51% year-over-year increase in stolen value

North Korea accounted for 59% of all cryptocurrency stolen globally in 2025 and 76% of all exchange compromises. No other threat actor comes close.

The Industrialization of Crypto Theft

What makes North Korea different isn't just the scale—it's the sophistication of their operation.

Social Engineering Over Technical Exploits

The majority of 2025's major hacks were perpetrated through social engineering rather than technical vulnerabilities. This represents a fundamental shift. Hackers are no longer primarily hunting for smart contract bugs or cryptographic weaknesses. They're targeting people.

Lazarus Group operatives have embedded themselves as IT workers inside crypto companies. They've impersonated executives. They've sent job offers containing malware to developers. The Bybit attack began with a developer downloading a fake stock trading simulator—a classic social engineering vector.

The Chinese Laundromat

Stealing crypto is only half the challenge. Converting it to usable funds without getting caught is equally complex.

Rather than cash out directly, North Korea has outsourced money laundering to what investigators call the "Chinese Laundromat"—a sprawling network of underground bankers, OTC brokers, and trade-based laundering intermediaries. These actors wash stolen assets across chains, jurisdictions, and payment rails.

By March 20, 2025—less than a month after the Bybit hack—CEO Ben Zhou reported that hackers had already converted 86.29% of the stolen ETH to Bitcoin through multiple intermediary wallets, decentralized exchanges, and cross-chain bridges. The 45-day laundering cycle following major thefts has become a predictable pattern.

Despite these efforts, Zhou noted that 88.87% of the stolen assets remained traceable. But "traceable" doesn't mean "recoverable." The funds flow through jurisdictions with no cooperative relationship with U.S. or international law enforcement.

Bybit's Response: Crisis Management Under Fire

Within 30 minutes of discovering the breach, CEO Ben Zhou took command and began providing real-time updates on X (formerly Twitter). His message was blunt: "Bybit is Solvent even if this hack loss is not recovered, all of clients assets are 1 to 1 backed, we can cover the loss."

The exchange processed over 350,000 withdrawal requests within 12 hours—a signal to users that despite the catastrophic loss, operations would continue normally.

Emergency Funding

Within 72 hours, Bybit had replenished its reserves by securing 447,000 ETH through emergency funding from partners including Galaxy Digital, FalconX, and Wintermute. Bitget loaned 40,000 ETH to ensure withdrawals continued uninterrupted—a loan Bybit repaid within three days.

Cybersecurity firm Hacken conducted a proof-of-reserves audit confirming that Bybit's major assets were backed by more than 100% collateral. The transparency was unprecedented for a crisis of this magnitude.

The Bounty Program

Zhou declared "war against Lazarus" and launched a global bounty program offering up to 10% rewards for information leading to frozen assets. By year's end, Bybit had paid $2.18 million in USDT to contributors who helped trace or recover funds.

The Market's Verdict

By the end of 2025, Bybit had crossed 80 million users globally, recorded $7.1 billion in daily trading volume, and ranked 5th among cryptocurrency spot exchanges. The crisis response had become a case study in how to survive a catastrophic hack.

2025: The Year Crypto Theft Hit $3.4 Billion

The Bybit hack dominated headlines, but it was part of a broader pattern. Total cryptocurrency theft reached $3.4 billion in 2025—a new record and the third consecutive year of increases.

Key statistics:

  • 2023: $2 billion stolen
  • 2024: $2.2 billion stolen
  • 2025: $3.4 billion stolen

North Korea's share grew from roughly half to nearly 60% of all crypto theft. The DPRK achieved larger thefts with fewer incidents, demonstrating increasing efficiency and sophistication.

Lessons Learned: Where Security Failed

The Bybit hack exposed critical vulnerabilities that extend far beyond a single exchange.

Third-Party Risk Is Existential

Bybit didn't have a security failure. Safe{Wallet} did. But Bybit suffered the consequences.

The crypto industry has built complex dependency chains where exchanges rely on wallet providers, wallet providers rely on cloud infrastructure, and cloud infrastructure relies on individual developer workstations. A compromise anywhere in this chain can cascade catastrophically.

Cold Storage Isn't Enough

The industry has long treated cold wallets as the gold standard of security. But Bybit's funds were in cold storage when they were stolen. The vulnerability was in the process of moving them—the human approval step that multisig was designed to protect.

When transfers become routine, signers develop a false sense of security, treating approvals as formalities rather than critical security decisions. The Bybit attack exploited exactly this behavioral pattern.

The UI Is a Single Point of Failure

Multisig security assumes that signers can verify what they're approving. But if the interface displaying transaction details is compromised, verification becomes meaningless. The attackers showed signers one thing while executing another.

Pre-signing simulations—allowing employees to preview the actual destination of a transaction before approval—could have prevented this attack. So could delays for large withdrawals, giving time for additional review.

Social Engineering Beats Technical Security

You can have the most sophisticated cryptographic security in the world, and a single employee downloading the wrong file can bypass all of it. The weak point in cryptocurrency security is increasingly human, not technical.

Regulatory and Industry Implications

The Bybit hack is already reshaping the regulatory landscape.

Expect mandatory requirements for:

  • Hardware security modules (HSMs) for key management
  • Real-time transaction monitoring and anomaly detection
  • Regular third-party security audits
  • Enhanced AML frameworks and transaction delays for large transfers

Security and compliance are becoming thresholds for market access. Projects that cannot demonstrate strong key management, permission design, and credible security frameworks will find themselves cut off from banking partners and institutional users.

What This Means for the Industry

The Bybit hack reveals an uncomfortable truth: crypto's security model is only as strong as its weakest operational link.

The industry has invested heavily in cryptographic security—zero-knowledge proofs, threshold signatures, secure enclaves. But the most sophisticated cryptography is irrelevant if an attacker can trick a human into approving a malicious transaction.

For exchanges, the message is clear: security innovation must extend beyond technology to encompass operational processes, third-party risk management, and continuous employee training. Regular audits, collaborative threat intelligence sharing, and incident response planning are no longer optional.

For users, the lesson is equally stark: even the largest exchanges with the most sophisticated security can be compromised. Self-custody, hardware wallets, and distributed asset storage remain the safest long-term strategies—even if they're less convenient.

Conclusion

North Korea's Lazarus Group has industrialized cryptocurrency theft. They've stolen over $6.75 billion since 2017, with 2025 marking their most successful year yet. The Bybit hack alone—$1.5 billion in a single operation—demonstrates capabilities that would make any intelligence agency envious.

The crypto industry is in an arms race with state-sponsored hackers who have unlimited patience, sophisticated technical capabilities, and no fear of consequences. The Bybit attack succeeded not because of any novel exploit but because attackers understood that humans, not code, are the weakest link.

Until the industry treats operational security with the same rigor it applies to cryptographic security, these attacks will continue. The question isn't whether another billion-dollar hack will happen—it's when, and whether the target will respond as effectively as Bybit did.


This article is for educational purposes only and should not be considered financial advice. Always conduct your own research and prioritize security when interacting with cryptocurrency exchanges and wallets.

China's Blockchain Legal Framework 2025: What's Allowed, Banned, and the Gray Areas for Builders

· 9 min read
Dora Noda
Software Engineer

China presents the world's most paradoxical blockchain landscape: a nation that has banned cryptocurrency while simultaneously investing $54.5 billion annually in blockchain infrastructure, processed $2.38 trillion in digital yuan transactions, and deployed over 2,000 enterprise blockchain applications. For builders trying to navigate this environment, the difference between success and legal jeopardy often comes down to understanding precisely where the lines are drawn.

As of 2025, China's regulatory framework has crystallized into a distinctive model—one that aggressively suppresses decentralized crypto while actively promoting state-controlled blockchain infrastructure. This guide breaks down exactly what's permitted, what's prohibited, and where the gray areas create both opportunity and risk for Web3 developers and enterprises.


The Hard Bans: What's Absolutely Prohibited

In 2025, China reaffirmed and strengthened its comprehensive ban on cryptocurrency. There's no ambiguity here—the prohibitions are explicit and enforced.

Cryptocurrency Trading and Ownership

All cryptocurrency transactions, exchanges, and ICOs are banned. Financial institutions are prohibited from offering any crypto-related services. The People's Bank of China (PBoC) has made clear that this includes newer instruments like algorithmic stablecoins.

The crypto ban decree became effective from June 1, 2025, introducing:

  • Suspension of all crypto transactions
  • Asset seizure measures for violators
  • Enhanced enforcement mechanisms
  • Significant financial penalties

Stablecoins Under the Ban

In November 2025, the PBoC explicitly clarified that stablecoins—once perceived as a potential gray area—are equally forbidden. This closed a loophole that some had hoped might allow compliant stablecoin operations within mainland China.

Mining Operations

Cryptocurrency mining remains completely prohibited. China's 2021 mining ban has been consistently enforced, with operations forced either underground or offshore.

Foreign Platform Access

Platforms like Binance, Coinbase, and other international exchanges are prohibited in mainland China. While some users attempt to access these via VPNs, doing so is illegal and can result in fines and further legal consequences.

Banking and Financial Services

New 2025 regulations require banks to actively monitor and report suspicious crypto transactions. When risky crypto activity is identified, banks must:

  • Uncover the user's identity
  • Assess past financial behaviors
  • Implement financial restrictions on the account

What's Explicitly Permitted: Enterprise Blockchain and the Digital Yuan

China's approach isn't anti-blockchain—it's anti-decentralization. The government has made massive investments in controlled blockchain infrastructure.

Enterprise and Private Blockchain

Enterprise blockchain applications are explicitly permitted within the CAC (Cyberspace Administration of China) filing regime and cybersecurity laws. Private chains see more deployment than public chains in both public and private sectors because they allow centralized management of business operations and risk control.

Permitted use cases include:

  • Supply chain management and provenance tracking
  • Healthcare data management
  • Identity verification systems
  • Logistics and trade finance
  • Judicial evidence storage and authentication

The Chinese government has invested heavily in private and consortium blockchain applications across the public sector. Judicial blockchain systems in Beijing, Hangzhou, Guangzhou, and other cities now support digital evidence storage, contract execution automation, and smart court management.

The Blockchain Service Network (BSN)

China's Blockchain Service Network represents the country's most ambitious blockchain initiative. Established in 2018 and launched in 2020 by the State Information Center under the National Development and Reform Commission, China Mobile, China UnionPay, and other partners, BSN has become one of the world's largest enterprise blockchain ecosystems.

Key BSN statistics:

  • Over 2,000 blockchain applications deployed across enterprises and government organizations
  • Nodes established in 20+ countries
  • Resource costs reduced 20-33% compared to conventional blockchain cloud services
  • Interoperability across different blockchain frameworks

In 2025, Chinese officials announced a roadmap for national blockchain infrastructure targeting approximately 400 billion yuan ($54.5 billion) in annual investments over the next five years. BSN sits at the center of this strategy, providing the backbone for smart cities, trade ecosystems, and digital identity systems.

The Digital Yuan (e-CNY)

China's central bank digital currency represents the permitted alternative to private cryptocurrency. The numbers are substantial:

2025 Statistics:

  • $2.38 trillion in cumulative transaction value (16.7 trillion yuan)
  • 3.48 billion transactions processed
  • 225 million+ personal digital wallets
  • Pilot program covering 17 provinces

The digital yuan's evolution continues. Starting January 1, 2026, commercial banks will begin paying interest on digital yuan holdings—marking a transition from "digital cash" to "digital deposit currency."

However, adoption challenges persist. The e-CNY faces stiff competition from entrenched mobile payment platforms like WeChat Pay and Alipay, which dominate China's cashless transaction landscape.


The Gray Areas: Where Opportunity Meets Risk

Between the clear prohibitions and explicit permissions lies significant gray territory—areas where regulations remain ambiguous or enforcement is inconsistent.

Digital Collectibles (NFTs with Chinese Characteristics)

NFTs exist in a regulatory gray area in China. They're not banned, but they can't be bought with crypto and can't be used as speculative investments. The solution has been "digital collectibles"—a uniquely Chinese NFT model.

Key differences from global NFTs:

  • Labeled as "digital collectibles," never "tokens"
  • Operated on private blockchains, not public chains
  • No secondary trading or resale permitted
  • Real-identity verification required
  • Payment in yuan only, never cryptocurrency

Despite official restrictions, the digital collectibles market has exploded. By early July 2022, approximately 700 digital collectibles platforms operated in China—up from around 100 just five months earlier.

For brands and enterprises, the guardrails are:

  1. Use legally registered Chinese NFT platforms
  2. Describe items as "digital collectibles," never "tokens" or "currency"
  3. Never allow or encourage trading or speculation
  4. Never imply value appreciation
  5. Comply with real-identity verification requirements

The Ministry of Industry and Information Technology has indicated that digital collectibles represent a business model to be encouraged "in line with the country's conditions"—though comprehensive regulations haven't yet been released.

Underground and VPN-Based Activity

A vibrant underground market exists. Collectors and enthusiasts trade through peer-to-peer networks, private forums, and encrypted messaging apps. Some Chinese users employ VPNs and pseudonymous wallets to participate in global NFT and crypto markets.

This activity operates in a legal gray area. Participants take on significant risk, including potential detection through enhanced banking surveillance and the possibility of financial restrictions or penalties.

Hong Kong as a Regulatory Arbitrage Opportunity

Hong Kong's Special Administrative Region status creates a unique opportunity. While mainland China prohibits crypto, Hong Kong has established a regulated framework through the Hong Kong Monetary Authority (HKMA) and Securities and Futures Commission (SFC).

In August 2025, Hong Kong implemented the Stablecoin Ordinance, establishing a licensing regime for stablecoin issuers. This creates interesting possibilities for enterprises that can structure operations to leverage Hong Kong's more permissive environment while maintaining compliant operations in the mainland.


Filing Requirements and Compliance

For enterprises operating permissible blockchain applications in China, compliance requires understanding the registration framework.

CAC Filing Requirements

The Blockchain Provisions require service providers to file a recordal with the Cyberspace Administration of China within ten working days from the commencement of blockchain services. Importantly, this is a filing requirement, not a permit requirement—blockchain services don't require special operating permits from regulators.

What Must Be Filed

Blockchain service providers must register:

  • Basic company information
  • Service description and scope
  • Technical architecture details
  • Data handling procedures
  • Security measures

Ongoing Compliance

Beyond initial filing, enterprises must maintain:

  • Compliance with cybersecurity laws
  • User real-identity verification
  • Transaction record keeping
  • Cooperation with regulatory inquiries

Potential Policy Evolution

While 2025 has seen enforcement strengthen rather than relax, some signals suggest future policy evolution is possible.

In July 2025, the Shanghai State-owned Assets Supervision and Administration Commission indicated that the rapid evolution of digital assets could result in softening of China's strict position on crypto. This is notable as an official acknowledgment that the current framework may need adjustment.

However, any policy changes would likely maintain the fundamental distinction between:

  • Prohibited: Decentralized, permissionless cryptocurrency
  • Permitted: State-controlled or enterprise blockchain with proper oversight

Strategic Recommendations for Builders

For developers and enterprises looking to operate in China's blockchain ecosystem, here are the key strategic considerations:

Do:

  • Focus on enterprise blockchain applications with clear business utility
  • Use BSN infrastructure for cost-effective, compliant deployment
  • Structure digital collectibles projects within established guidelines
  • Maintain comprehensive compliance documentation
  • Consider Hong Kong structures for crypto-adjacent activities

Don't:

  • Attempt cryptocurrency trading or exchange operations
  • Issue tokens or facilitate token trading
  • Build on public, permissionless blockchains for mainland users
  • Encourage speculation or secondary trading in digital assets
  • Assume gray areas will remain unenforced

Consider:

  • The regulatory arbitrage opportunity between mainland China and Hong Kong
  • BSN's international expansion for projects targeting multiple markets
  • Digital yuan integration for payment-related applications
  • Joint ventures with established Chinese blockchain enterprises

Conclusion: Navigating Controlled Innovation

China's blockchain landscape represents a unique experiment: aggressive promotion of controlled blockchain infrastructure alongside complete suppression of decentralized alternatives. For builders, this creates a challenging but navigable environment.

The key is understanding that China isn't anti-blockchain—it's anti-decentralization. Enterprise applications, digital yuan integration, and compliant digital collectibles represent legitimate opportunities. Public chains, cryptocurrency, and DeFi remain firmly off-limits.

With $54.5 billion in planned annual blockchain investment and 2,000+ enterprise applications already deployed, China's controlled blockchain ecosystem will remain a significant global force. Success requires accepting the framework's constraints while maximizing the substantial opportunities it does permit.

The builders who thrive will be those who master the distinction between what China bans and what it actively encourages—and who structure their projects accordingly.


References

Hong Kong vs Mainland China: A Tale of Two Crypto Policies Under One Country

· 9 min read
Dora Noda
Software Engineer

Fifty kilometers apart, two regulatory systems govern crypto with such stark opposition that they might as well exist in different universes. Mainland China bans all cryptocurrency trading, mining, and as of November 2025, even stablecoins—while Hong Kong actively courts the industry with an expanding licensing framework, spot ETFs, and ambitions to become Asia's preeminent digital asset hub. The "One Country, Two Systems" principle has never been more dramatically illustrated than in how these jurisdictions approach Web3.

For builders, investors, and institutions navigating the Greater China market, understanding this regulatory divergence isn't just academic—it's existential. The difference between operating 50 kilometers north or south of the border can mean the difference between building a licensed, regulated business and facing criminal prosecution.


The Mainland Position: Total Prohibition Reinforced

China's stance on cryptocurrency has hardened into one of the world's most comprehensive bans. What began as restrictions in 2013 has evolved into blanket prohibition covering virtually every aspect of the crypto ecosystem.

The 2025 Crackdown Intensifies

On November 28, 2025, Chinese financial and judicial authorities convened to reinforce their position: all crypto-related business activities are illegal in mainland China. The enforcement decree, effective June 1, 2025, established clear penalties including transaction suspension and asset seizure.

The most significant development was the explicit ban on stablecoins—including those pegged to major global or domestic fiat currencies. This closed what many considered the last gray area in Chinese crypto regulation.

Key prohibitions now include:

  • Mining, trading, and even holding crypto assets
  • Issuing, exchanging, or raising funds using tokens or stablecoins
  • RWA (Real-World Asset) tokenization activities
  • Domestic staff participation in offshore tokenization services

The enforcement framework is formidable. The People's Bank of China (PBOC) leads regulatory efforts, directing financial institutions to block crypto-related transactions. The Cyberspace Administration of China (CAC) polices the internet, shutting down websites, apps, and social media accounts promoting crypto. Technical infrastructure enabling tokenization faces active monitoring and disruption.

The Blockchain Exception

Yet China's policy isn't anti-blockchain—it's anti-crypto. Officials announced a roadmap for national blockchain infrastructure targeting 400 billion yuan ($54.5 billion) in annual investments over five years. The distinction is clear: permissioned, state-controlled blockchain good; permissionless, token-based systems bad.

The digital yuan (e-CNY) continues receiving state backing and active development, representing China's vision for controlled digital currency innovation. By separating blockchain infrastructure from tradeable tokens, China maintains technological competitiveness while preserving capital controls and monetary sovereignty.

Underground Reality

Despite comprehensive prohibition, enforcement faces practical limits. China is estimated to have approximately 59 million crypto users as of 2025, operating through P2P platforms and VPN-based wallet access. The gap between policy and reality creates ongoing challenges for regulators and opportunities—albeit illegal ones—for determined participants.


Hong Kong's Contrasting Vision: Regulated Embrace

While the mainland prohibits, Hong Kong regulates. The Special Administrative Region has constructed an increasingly sophisticated framework designed to attract legitimate crypto businesses while maintaining robust investor protections.

The VASP Licensing Framework

Since June 2023, all Virtual Asset Service Providers (VASPs) serving Hong Kong investors must hold an SFC-issued license. The requirements are stringent:

RequirementDetails
Asset CustodyAt least 98% of client assets in cold storage
Fund SegregationComplete separation of client and company assets
KYC/AMLMandatory checks and suspicious transaction reporting
Travel RuleCompliance for transfers exceeding HKD 8,000
ManagementFit and proper personnel with cybersecurity safeguards

Licensed exchanges include HashKey Exchange, OSL Digital Securities, and HKVAX—platforms that can legally serve both retail and institutional investors.

The Stablecoin Ordinance

Effective August 1, 2025, Hong Kong introduced dedicated licensing for fiat-referenced stablecoin issuers. Requirements include:

  • Minimum paid-up share capital of HKD 25 million
  • Full reserve backing with high-quality, liquid assets
  • Regulatory approval from the Hong Kong Monetary Authority

This positions Hong Kong to host compliant stablecoin issuers at a time when mainland China has explicitly banned all stablecoin activities.

Spot ETF Success

Hong Kong made history on April 30, 2024, launching Asia's first spot Bitcoin and Ethereum ETFs. Six virtual asset ETFs began trading on the Hong Kong Stock Exchange, issued by Harvest Global Investments, HashKey Capital/Bosera Asset Management, and China Asset Management's Hong Kong unit.

By late December 2024, Hong Kong crypto ETF assets reached $467 million—modest compared to U.S. ETF assets exceeding $122 billion, but significant for the region. The spot Bitcoin ETFs accumulated 4,560 BTC ($444.6 million), while Ether funds held 16,280 ETH ($59.6 million).

In 2025, the expansion continued with Pando Finance launching the city's first Bitcoin ETF of the year and Hong Kong approving its first Solana ETF—a product category not yet available in the United States.

The ASPIRe Roadmap

The SFC's "ASPIRe" roadmap articulates Hong Kong's ambitions to become a global digital asset hub. On June 26, 2025, the Financial Services and Treasury Bureau (FSTB) issued its second policy statement advancing this strategic vision.

Key November 2025 developments included:

  • Expansion of products and services for licensed VATPs
  • Integration of order books with global affiliate platforms
  • Enabling shared global liquidity for Hong Kong exchanges

2026 Legislative Plans

Hong Kong plans to introduce legislative proposals for virtual asset dealers and custodians in 2026. The new licensing framework under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance will create requirements modeled on existing Type 1 securities rules—meaning crypto dealers will follow the same strict standards as traditional finance.

Consultations on regulating virtual asset advisory and management services closed in January 2026, with implementation expected later in the year.


Side-by-Side Comparison

The regulatory contrast couldn't be sharper:

DimensionMainland ChinaHong Kong
Crypto TradingBanned (criminal penalties)Legal (licensed exchanges)
MiningBannedNot explicitly prohibited
StablecoinsExplicitly banned (Nov 2025)Regulated (HKMA licensing)
ICOs/Token IssuanceBannedRegulated case-by-case
Retail AccessProhibitedAllowed on licensed platforms
Spot ETFsNot availableApproved (BTC, ETH, SOL)
RWA TokenizationBannedUnder development
Regulatory ApproachProhibition + enforcementRegulation + innovation
CBDCe-CNY (state-controlled)HKD stablecoins (private)
Estimated Users~59 million (underground)Growing (licensed)

Strategic Implications

For Exchanges and Trading Platforms

Mainland operations are impossible. Hong Kong offers a legitimate path to serving Chinese-speaking markets, but strict licensing requirements demand significant investment. The passporting potential—reaching global liquidity through Hong Kong licenses—makes compliance economically attractive for serious operators.

For Stablecoin Issuers

The contrast creates clear routing: Hong Kong welcomes compliant issuers with substantial reserve requirements; mainland China criminalizes the entire category. For projects targeting Greater China, Hong Kong licensing is the only legitimate option.

For Institutional Investors

Hong Kong's ETF framework and expanding product offerings create regulated access points. The combination of spot ETFs, licensed custody, and traditional finance integration makes Hong Kong increasingly attractive for institutional allocation to digital assets.

For Web3 Builders

The arbitrage opportunity is geographic. Hong Kong permits innovation within regulatory bounds; mainland China permits blockchain innovation only without tokens. Projects requiring token economics must locate in Hong Kong; pure blockchain infrastructure may find mainland resources and market access valuable.

For the Industry

Hong Kong's regulatory development represents a proof-of-concept for comprehensive crypto regulation within the Chinese legal tradition. Success could influence other Asian jurisdictions and potentially—though this remains speculative—inform eventual mainland policy evolution.


The Equilibrium Question

How long can such divergent policies coexist? The "One Country, Two Systems" framework permits significant regulatory divergence, but mainland authorities have historically shown willingness to intervene when Hong Kong policies conflict with national interests.

Several factors suggest the current equilibrium may be stable:

Arguments for stability:

  • Hong Kong's role as international financial center requires regulatory compatibility with global markets
  • Digital asset regulation doesn't threaten core mainland concerns (territorial integrity, political control)
  • Hong Kong serves as a controlled experiment and potential release valve
  • Capital controls remain enforceable through mainland banking systems

Arguments for potential convergence:

  • Mainland enforcement increasingly targets offshore service providers with domestic staff
  • Success in Hong Kong could attract mainland capital through gray channels
  • Political pressure could align Hong Kong more closely with mainland positions

The November 2025 mainland statement extending enforcement to "domestic staff of offshore service providers" suggests authorities are aware of and actively countering regulatory arbitrage.


Conclusion: Navigating the Divide

The Hong Kong-Mainland divide offers a stark lesson in regulatory philosophy. Mainland China prioritizes capital controls, financial stability, and monetary sovereignty—choosing prohibition as the simplest enforcement mechanism. Hong Kong prioritizes international competitiveness and financial innovation—choosing regulation as the path to managed participation.

For market participants, the practical implications are clear:

  1. Mainland China: Zero legal tolerance for crypto activity. The 59 million estimated users operate entirely outside legal protection.

  2. Hong Kong: Expanding opportunities within a demanding regulatory framework. Licensed operations gain access to both local and global markets.

  3. The border matters: 50 kilometers creates entirely different legal realities. Corporate structuring, staff location, and operational jurisdiction require careful consideration.

As Hong Kong continues building its regulatory infrastructure through 2026 and beyond, it offers an increasingly compelling case study in how jurisdictions can embrace digital assets while maintaining robust investor protections. Whether this experiment influences broader regional or even mainland policy remains to be seen—but for now, the tale of two crypto policies continues to unfold just 50 kilometers apart.


References

Korea's 15-20% Exchange Ownership Caps: A Regulatory Earthquake Reshaping Asia's Crypto Landscape

· 10 min read
Dora Noda
Software Engineer

South Korea just dropped a regulatory bombshell that could fundamentally restructure the world's second-largest crypto trading market. On December 30, 2025, the Financial Services Commission (FSC) unveiled plans to cap major shareholder ownership in cryptocurrency exchanges at 15-20%—a move that would force the founders of Upbit, Bithumb, Coinone, and Korbit to sell billions of dollars in equity.

The implications extend far beyond Korea's borders. With Korean won already rivaling the US dollar as the world's most-traded fiat currency for crypto, and $110 billion already fleeing to foreign exchanges in 2025 alone, the question isn't just how Korean exchanges will adapt—it's whether Korea will retain its position as Asia's retail crypto powerhouse, or cede ground to Singapore, Hong Kong, and Dubai.


The Numbers Behind the Bombshell

The FSC's proposal targets exchanges classified as "core infrastructure"—defined as platforms with over 11 million users. This captures Korea's Big Four: Upbit, Bithumb, Coinone, and Korbit.

Here's what the current ownership structure looks like versus what compliance would require:

ExchangeMajor ShareholderCurrent StakeRequired Reduction
Upbit (Dunamu)Song Chi-hyung25%~5-10%
CoinoneCha Myung-hoon54%~34-39%
BithumbHolding Company73%~53-58%
KorbitNXC + SK Square~92% combined~72-77%
GOPAXBinance67.45%~47-52%

The math is brutal. Coinone's founder would need to sell more than half his stake. Bithumb's holding company would need to divest over 70% of its position. Binance's control of GOPAX becomes untenable.

The FSC frames this as transforming founder-controlled private enterprises into quasi-public infrastructure—similar to Alternative Trading Systems (ATS) under Korea's Capital Markets Act. The proposal also signals a shift from the current registration system to a full licensing regime, with regulators conducting fitness reviews of major shareholders.


A Market Too Big to Ignore—and Too Concentrated to Ignore

Korea's crypto market is a paradox: massive in scale, dangerously concentrated in structure.

The numbers tell the story:

  • $663 billion in crypto trading volume in 2025
  • 16 million+ users (32% of the nation's population)
  • Korean won ranks as the #2 fiat currency for global crypto trading, sometimes surpassing USD
  • Daily trades frequently exceeded $12 billion

But within this market, Upbit dominates with near-monopoly force. In H1 2025, Upbit controlled 71.6% of all trading volume—833 trillion won ($642 billion). Bithumb captured 25.8% with 300 trillion won. The remaining players—Coinone, Korbit, GOPAX—collectively account for less than 5%.

The FSC's concern isn't abstract. When a single platform handles 70%+ of a nation's crypto trading, operational failures, security breaches, or governance scandals don't just affect investors—they become systemic risks to financial stability.

Recent data reinforces this worry. During Bitcoin's December 2024 rally to all-time highs, Upbit's market share spiked from 56.5% to 78.2% in a single month as retail traders consolidated on the dominant platform. That's the kind of concentration that keeps regulators awake at night.


The Capital Flight Already Happening

Korea's regulatory posture has already triggered a capital exodus that dwarfs the proposed ownership restructuring in significance.

In the first nine months of 2025 alone, Korean investors transferred 160 trillion won ($110 billion) to foreign exchanges—triple the outflow from all of 2023.

Why? Domestic exchanges are limited to spot trading. No futures. No perpetuals. No leverage. Korean traders who want derivatives—and the volume data suggests millions of them do—have no choice but to go offshore.

The beneficiaries are clear:

  • Binance: ₩2.73 trillion in fee income from Korean users
  • Bybit: ₩1.12 trillion
  • OKX: ₩580 billion

Combined, these three platforms extracted ₩4.77 trillion from Korean users in 2025—2.7x the combined revenue of Upbit and Bithumb. The regulatory framework designed to protect Korean investors is instead pushing them to less-regulated venues while transferring billions in economic activity abroad.

The FSC's ownership caps could accelerate this trend. If forced divestments create uncertainty about exchange stability, or if major shareholders exit the market entirely, retail confidence could collapse—pushing even more volume offshore.


The Asia Crypto Hub Competition

Korea's regulatory gamble plays out against a fierce regional competition for crypto industry dominance. Singapore, Hong Kong, and Dubai are all vying to become the definitive Asian crypto hub—and each has different strategic advantages.

Hong Kong: The Aggressive Comeback

Hong Kong has emerged from China's shadow with surprising momentum. By June 2025, the city had granted 11 Virtual Asset Trading Platform (VATP) licenses, with more pending. The Stablecoin Ordinance, implemented August 2025, created Asia's first comprehensive licensing regime for stablecoin issuers—with the first licenses expected in early 2026.

The numbers are compelling: Hong Kong led Eastern Asia with 85.6% growth in crypto activity in 2024, according to Chainalysis. The city is explicitly positioning itself to attract crypto talent and firms from competitors like the US, Singapore, and Dubai.

Singapore: The Cautious Incumbent

Singapore's approach is the opposite of Korea's heavy-handed intervention. Under the Payment Services Act and Digital Payment Token regime, the Monetary Authority of Singapore emphasizes stability, compliance, and long-term risk management.

The tradeoff is speed. While Singapore's reputation for regulatory clarity and institutional trust is unmatched, its cautious stance means slower adoption. The June 2025 Digital Token Service Provider framework set strict requirements that restrict many overseas-focused issuers.

For Korean exchanges facing ownership caps, Singapore offers a potential safe harbor—but only if they can meet MAS's exacting standards.

Dubai: The Wild Card

Dubai's Virtual Asset Regulatory Authority (VARA) has positioned the emirate as the "anything goes" alternative to more restrictive Asian jurisdictions. With no personal income tax, a dedicated crypto regulatory framework, and aggressive courting of exchanges and projects, Dubai has attracted major players looking to escape regulatory pressure elsewhere.

If Korea's ownership caps trigger a wave of exchange migrations, Dubai is well-positioned to capture the flow.


What Happens to the Exchanges?

The FSC's proposal creates three possible paths for Korea's major exchanges:

Scenario 1: Forced Divestment and Restructuring

If the regulations pass as proposed, major shareholders face a stark choice: sell down stakes to comply, or fight the law in court. Given the political momentum behind the proposal, compliance seems more likely.

The question is who buys. Institutional investors? Foreign strategic acquirers? A distributed pool of retail shareholders? Each buyer profile creates different governance dynamics and operational priorities.

For Bithumb, already pursuing a 2026 NASDAQ IPO, forced divestment might actually accelerate the public listing timeline. Going public naturally diversifies ownership while providing liquidity for existing shareholders.

For Upbit, a potential merger with internet giant Naver could provide cover for ownership restructuring while creating a formidable combined entity.

Scenario 2: Regulatory Rollback

The crypto industry isn't accepting the proposal quietly. Exchange operators have responded with sharp criticism, arguing that forced ownership dispersion would:

  • Eliminate accountable controlling shareholders, creating ambiguity about responsibility when problems arise
  • Infringe on property rights without clear constitutional justification
  • Weaken domestic exchanges against international competitors
  • Trigger investor flight as uncertainty increases

Industry groups are pushing for behavioral regulations and voting rights restrictions as alternatives to forced divestment. Given the proposal's still-preliminary status—the FSC has emphasized that specific thresholds remain under discussion—there's room for negotiation.

Scenario 3: Market Consolidation

If smaller exchanges can't afford the compliance costs and governance restructuring required under the new regime, the Big Four could become the Big Two—or even the Big One.

Upbit's dominant market position means it has the resources to navigate regulatory complexity. Smaller players like Coinone, Korbit, and GOPAX may find themselves squeezed between ownership restructuring costs and inability to compete with Upbit's scale.

The irony: a regulation designed to disperse ownership concentration could inadvertently increase market concentration as weaker players exit.


The Stablecoin Deadlock

Complicating everything is Korea's ongoing battle over stablecoin regulation. The Digital Asset Basic Act, originally expected in late 2025, has stalled over a fundamental disagreement:

  • The Bank of Korea insists only banks with 51% ownership should issue stablecoins
  • The FSC warns this approach could hinder innovation and cede the market to foreign issuers

This deadlock has pushed the bill's passage to January 2026 at earliest, with full implementation unlikely before 2027. Meanwhile, Korean traders who want stablecoin exposure are—once again—forced offshore.

The pattern is clear: Korean regulators are caught between protecting domestic financial stability and losing market share to more permissive jurisdictions. Every restriction that "protects" Korean investors also pushes them toward foreign platforms.


What This Means for the Region

Korea's ownership cap proposal has implications beyond its borders:

For foreign exchanges: Korea represents one of the most lucrative retail markets globally. If domestic regulatory pressure increases, offshore platforms stand to capture even more of that volume. The $110 billion already flowing to foreign exchanges in 2025 could be just the beginning.

For competing Asian hubs: Korea's regulatory uncertainty creates opportunity. Hong Kong's licensing momentum, Singapore's institutional credibility, and Dubai's permissive stance all become more attractive as Korean exchanges face forced restructuring.

For global crypto markets: Korean retail traders are a major source of volume, particularly for altcoins. Any disruption to Korean trading activity—whether from exchange instability, regulatory uncertainty, or capital flight—reverberates through global crypto markets.


The Road Ahead

The FSC's ownership cap proposal remains preliminary, with implementation unlikely before late 2026 at earliest. But the direction is clear: Korea is moving toward treating crypto exchanges as quasi-public utilities requiring distributed ownership and enhanced regulatory oversight.

For the exchanges, the next 12-18 months will require navigating unprecedented uncertainty while maintaining operational stability. For Korean retail traders—16 million of them—the question is whether domestic platforms can remain competitive, or whether the future of Korean crypto trading lies increasingly offshore.

The Asia crypto hub race continues, and Korea just made its position significantly more complicated.


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