TOKENIZATION POLICY
The Vanderbilt Terminal for Digital Asset Policy & Regulation
INDEPENDENT INTELLIGENCE FOR TOKENIZATION POLICY, LEGISLATION & POLITICAL ECONOMY
GENIUS Act: Signed Law ▲ Jul 18 2025| MiCA Status: Live ▲ Dec 2024| CLARITY Act: Senate Pending ▲ Jul 2025| Crypto Lobbying 2024: $202M PAC ▲ Fairshake| OECD CARF Countries: 75+ ▲ +12| CBDC Projects: 130+ Active ▲ Atlantic Council| FATF Travel Rule: 73% Compliant ▲ Jun 2025| Pro-Crypto Congress: 300+ Members ▲ +91| GENIUS Act: Signed Law ▲ Jul 18 2025| MiCA Status: Live ▲ Dec 2024| CLARITY Act: Senate Pending ▲ Jul 2025| Crypto Lobbying 2024: $202M PAC ▲ Fairshake| OECD CARF Countries: 75+ ▲ +12| CBDC Projects: 130+ Active ▲ Atlantic Council| FATF Travel Rule: 73% Compliant ▲ Jun 2025| Pro-Crypto Congress: 300+ Members ▲ +91|

SEC

Crypto Enforcement Action Tracker

Tracking major regulatory enforcement actions against digital asset firms — SEC, CFTC, OFAC, FCA, ESMA, and international authorities.

Donovan Vanderbilt · February 24, 2026 · 5 min read

FIT21 (Financial Innovation and Technology for the 21st Century Act)

The 2024 House-passed legislation that established the decentralization test for crypto classification, gave the CFTC jurisdiction over digital commodity spot markets, and became the legislative foundation for the CLARITY Act.

Donovan Vanderbilt · February 24, 2026

FIT21: The Digital Asset Market Structure Act That Changed American Crypto Law

FIT21 — the Financial Innovation Technology for the 21st Century Act — passed the House 279-136 in May 2024. The first major US crypto bill to pass a chamber, it became the template for the CLARITY Act.

Donovan Vanderbilt · February 24, 2026 · 8 min read

Howey Test

The four-part legal test derived from a 1946 US Supreme Court case that determines whether a transaction constitutes an 'investment contract' and therefore a security subject to SEC regulation.

Donovan Vanderbilt · February 24, 2026

Notice-and-Comment Rulemaking (US)

The formal process under the US Administrative Procedure Act by which federal agencies propose and finalise binding regulations, including rules governing crypto asset markets.

Donovan Vanderbilt · February 24, 2026

Open Regulatory Consultations Tracker

Tracking open and recently closed regulatory consultations on digital assets and tokenization — opportunities to shape policy before rules are finalized.

Donovan Vanderbilt · February 24, 2026 · 4 min read

Paul Atkins: The SEC Chair Who Reversed a Decade of Crypto Enforcement

Paul Atkins — confirmed SEC Chair in 2025 — launched 'Project Crypto', announced a token taxonomy, and fundamentally reoriented the SEC from enforcement-first to engagement-first on digital assets. A profile of the most consequential crypto regulator in the world.

Donovan Vanderbilt · February 24, 2026 · 9 min read

Regulation A+ (US Mini-IPO Exemption)

The JOBS Act 2012 securities offering exemption permitting retail investor participation up to $75 million annually, with SEC review of the offering document — providing a pathway for tokenized securities to reach non-accredited investors.

Donovan Vanderbilt · February 24, 2026

Regulation by Enforcement Failed: The Gensler Era's Costly Lesson

Donovan Vanderbilt · February 24, 2026 · 8 min

Regulation Crowdfunding (Reg CF)

Regulation Crowdfunding under the JOBS Act permits token issuers to raise up to $5M per year from retail investors through registered funding portals.

Donovan Vanderbilt · February 24, 2026

Regulation D (US Securities Exemption)

The US private placement exemption under the Securities Act 1933, providing the primary legal basis for token sales to accredited investors through Rule 506(b) and 506(c), including the SAFT structure.

Donovan Vanderbilt · February 24, 2026

Regulation S (US Offshore Securities Exemption)

How Regulation S exempts offshore token sales from SEC registration requirements, including compliance requirements and resale restrictions.

Donovan Vanderbilt · February 24, 2026

Regulatory Capture

The phenomenon whereby regulatory agencies come to serve the interests of the industries they regulate rather than the public interest, through mechanisms including the revolving door, lobbying, and information asymmetry.

Donovan Vanderbilt · February 24, 2026

SEC (Securities and Exchange Commission)

The SEC's role in crypto and tokenized securities regulation, from the Howey Test framework through the Gensler enforcement era to the Atkins reform agenda.

Donovan Vanderbilt · February 24, 2026

SEC Crypto Rulemaking: From Enforcement-First to Project Crypto

How the SEC's approach to digital asset regulation transformed from Gary Gensler's enforcement-first era to Paul Atkins' Project Crypto — and what each approach means for the tokenization industry.

Donovan Vanderbilt · February 24, 2026 · 9 min read

Security vs Commodity: The Classification That Determines Everything

The foundational US regulatory classification dispute that determines whether a crypto asset falls under SEC or CFTC jurisdiction, with fundamentally different compliance implications for each outcome.

Donovan Vanderbilt · February 24, 2026

The Political Economy of Tokenization: Lobbying, Power, and Who Writes the Rules

Why tokenization regulation looks the way it does — the interests, coalitions, institutional dynamics, and political forces that shape digital asset law.

Donovan Vanderbilt · February 24, 2026 · 20 min read

The Revolving Door in Crypto Regulation

The movement of personnel between crypto regulatory agencies and the crypto industry, raising questions about regulatory capture while providing genuine expertise to both sectors.

Donovan Vanderbilt · February 24, 2026

The Revolving Door in Crypto Regulation: A Systematic Map

The movement of individuals between crypto industry and government regulatory positions — in both directions — is the most structurally significant feature of US crypto regulatory politics in 2024-2026.

Donovan Vanderbilt · February 24, 2026 · 8 min read

United States: From Enforcement-First to Legislative Leader in Digital Asset Policy

The US digital asset policy landscape — GENIUS Act, CLARITY Act, SEC transformation, Fairshake PAC, and the political economy of American crypto regulation.

Donovan Vanderbilt · February 24, 2026 · 12 min read

US Tokenization Legislation: Every Bill, Every Hearing, Every Vote

The complete guide to US digital asset legislation — from the GENIUS Act to CLARITY, from SEC enforcement to the CFTC's expanding role, and the political forces that shaped each outcome.

Donovan Vanderbilt · February 24, 2026 · 15 min read

Why America Was Losing the Tokenization Race (And Why That Changed in 2025)

Donovan Vanderbilt · February 24, 2026 · 8 min
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