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Re-examining different DAT strategies in the context of tightened Nasdaq regulation
Movemaker
特邀专栏作者
7hours ago
This article is about 8691 words, reading the full article takes about 13 minutes
Judging from market performance, BTC-related DATs have experienced a brief downturn, the ETH narrative seems to have completed its first roller-coaster ride, and SOL's treasury model appears poised for a surge. What logic and risks lie hidden behind this glamor?

Original article by @BlazingKevin_, the Researcher at Movemaker

Nasdaq announced new regulations for digital asset companies last Thursday. Specifically, if such companies want to fund their cryptocurrency purchases by issuing new shares, the plan must first be submitted to a shareholder meeting for a vote to ensure investors are informed.

This undoubtedly poured cold water on the crypto market, as the "DAT strategy" was widely viewed as the new secret to wealth. From the outside, it appears to be a simple, crude financial tool: companies raise funds through IPOs, use the proceeds to buy cryptocurrencies, and then rely on market appreciation to achieve positive feedback loops in stock prices. In a short period of time, this model quickly ignited public opinion, even being portrayed as a "financial stunt" conspired by Wall Street and the crypto community. Market performance suggests that BTC-related DATs experienced a brief lull, the ETH narrative appears to have completed its first roller-coaster ride, and SOL's treasury model appears poised for a surge. What logic and risks lie hidden behind this glamor?

The development model of DAT enterprises

The core idea behind DAT (Digital Asset Treasury) is straightforward: a listed company raises capital through new share issuance, then uses the proceeds to purchase cryptocurrencies, filling its balance sheet with mainstream tokens like BTC, ETH, and SOL. In an ideal cycle, a company can repeatedly execute the spiral of "raising capital - buying cryptocurrencies - rising crypto prices - rising stock prices - further raising capital," acting as an infinitely multiplying capital accelerator.

To make this narrative self-consistent, there are usually three paths for treasury operations:

  1. Business rebranding : Companies on the verge of bankruptcy transform themselves into "crypto financial service providers," for example, by tying themselves to new narratives through staking or yield strategies.
  2. Merger and acquisition : Put a private enterprise focusing on encryption business into a listed shell company to obtain a compliance identity at a low cost.
  3. SPAC model : Using a special purpose acquisition company to enter the capital market as a "shortcut".

While the first two methods are not new, the one that has truly resurfaced is the SPAC tool, once used by Circle. Its appeal lies in the fact that even without customers, products, or even a mature business logic, as long as a portfolio is filled with Bitcoin, it can quickly list a stock ticker on an exchange and, in the most direct way, package and sell Bitcoin dividends to public investors.

This approach is a stark departure from Strategy's original strategy. While the latter at least emphasized Bitcoin's "store of value" properties, today's new entrants almost always buy up all the major tokens first and then improvise a business story. These companies are more like hedge funds disguised as public companies, yet they continue to attract waves of crypto-chasing capital.

The true value of SPACs isn't simply that they allow companies to quickly go public, bypassing the lengthy IPO process. The key lies in the fact that, without actual business, companies can sell investors on highly imaginative plans—such as "BTC holdings reaching $1 billion by year-end." In this process, founding teams can even secure pre-IPO private placements (PIPEs) from major investors like Galaxy and lock in impressive valuations before the merger. While ostensibly complying with SEC regulations, the underlying sensitive nature of the "investment fund" identity is circumvented.

More importantly, SPACs offer companies the opportunity to leverage their investments very early on: first, they can accumulate cryptocurrencies and then double down on their investments through equity or debt financing, leveraging crypto assets to continuously amplify their momentum. This mechanism allows founders to completely bypass the traditional path of "building the product first, then proving its value," instead driving growth directly through narrative and financial instruments. Compared to IPOs, SPACs offer them greater scope for imagination and operational freedom.

The combination of PIPE and convertible bonds is an important addition to the overall playbook:

  1. First, look for a suitable shell company or SPAC.
  2. Work with them to tailor-make a crypto asset reserve strategy.
  3. Cooperate with investment banks to issue PIPE and convertible bonds, and sell shares directly to institutions.
  4. PIPEs often sell stocks at a discount, leaving room for institutions to profit from arbitrage.
  5. Convertible bonds protect investors from downside risks while providing some upward returns, making them the first choice for stable funds.

Unlike Strategy's original narrative of "anti-inflation reserves," today's PIPE investors are more aggressive. They not only buy tokens but also incorporate staking, lending, and other operations to accelerate the release of paper profits. The secondary market's reaction is also extremely direct: whenever such transactions are disclosed, company stock prices often surge several times in an instant. For Wall Street, this is a sophisticated financial packaging technique—translating "coin purchases" into a complex financial structure, then exploiting information asymmetry to extract expensive premiums from investors.

Of course, not all companies are focused on large-cap coins like BTC, ETH, and SOL. For smaller businesses, the mid- to low-end tokens ranked in the top 50 are more exciting targets. Their high volatility and impressive potential returns have attracted a wave of smaller companies to gamble, but more often than not, their success is short-lived, ultimately leading to market failure.

How are DATs like ETH and SOL different from BTC?

The backgrounds of businesses holding cryptocurrency are increasingly diverse, extending beyond crypto-native industries. For example, among BTC holders, there are traditional businesses like Strategy (business intelligence) and Metaplanet (hotel real estate), which use Bitcoin as a strategic store of value, as well as closely related industry companies like Mara (intellectual property/mining) and Bullish (digital asset trading).

BTC DAT is experiencing a cold snap, but mNAV is the most stable

Strategy's stock price has fallen 16.8% since August, wiping out the valuation premium the company enjoyed years ago due to its Bitcoin holdings. This isn't just a simple stock price correction, but rather a sign that the Bitcoin corporate treasury story is gradually losing its luster.

In fact, as emerging DAT strategies like Ethereum gradually gain a foothold, Strategy's industry leadership as a pioneer is being diluted. Even more devastating is the shift in its financing method. The company originally planned to purchase Bitcoin through preferred stock financing, but only raised $47 million, far below public expectations. This funding shortfall forced it to relaunch a common stock offering, undoubtedly violating its previously promised principle of "controlled dilution." In the context of the capital markets, this represents a loss of credibility.

This shift isn't an isolated one. Observing the capital flows of BTC, ETH, and SOL reveals a trend toward market diversification, with Bitcoin treasury companies bearing the brunt of the pressure of capital diversion. As early adopters of this model, they are also the first to enter a period of adjustment and pain. Currently, approximately one-third of publicly traded companies holding Bitcoin have share prices that are even lower than the Bitcoin's stated value. This is particularly devastating for small businesses: tight liquidity makes every equity financing extremely difficult, while heavy convertible bond interest payments and approaching repayment deadlines further squeeze their survival space.

Companies that truly thrive often share two characteristics: strong community consensus and the ability to continuously increase their Bitcoin holdings per share and build financial engineering around this. Conversely, companies lacking consistent strategic support are often eliminated by the market. For example, after SOS Limited transitioned from crypto mining to commodities trading, not only did its core business struggle, but its Bitcoin strategy also became unsustainable, ultimately falling far behind its peers. This demonstrates that a heavy Bitcoin holding model is more favored by the market than a token allocation.

Of course, these companies still face the impact of extreme volatility. When a company's net assets exceed its market capitalization, a turnaround may emerge. However, for financially precarious companies, simply holding a small amount of Bitcoin on their books is unlikely to stave off bankruptcy. Furthermore, when a company's strategy expands to include lower-tier tokens, the risk is exacerbated. These assets lack both Bitcoin's hard asset attributes and the stable support of buying, making them vulnerable to collapse during market corrections.

ETH DAT's income is diversified, but mNAV is discounted across the board

According to the latest Strategic ETH Reserve data, over 70 companies, listed companies, or institutions worldwide have included ETH in their strategic reserves (with individual holdings exceeding 100 tokens). Their combined holdings have exceeded 4.7 million ETH, representing approximately $20 billion in market capitalization and 3.89% of the total ETH supply. Of these, approximately 14 companies have publicly announced their "Ethereum Treasury Strategy," collectively holding nearly 3 million ETH, valued at approximately $12.86 billion.

Unlike Bitcoin treasury companies, which primarily adopt a "single holding" approach, these companies entering the ETH treasury market exhibit significant differences in their asset utilization models. Their strategies can be broadly divided into four categories: "delegated" reliance on third-party staking services for stable returns; "self-operated" direct integration into the network through proprietary nodes and liquidity staking; more aggressive approaches combine lending, liquidity provision, and MEV optimization to maximize capital efficiency; and still others explore advanced leverage strategies such as revolving loans to maximize asset returns.

Among the current holdings, the trends of the top five are particularly representative:

  • Just two months after launching its ETH treasury strategy, BitMine became the largest corporate holder, with holdings jumping to over 1.52 million, targeting 5% of the total ETH supply. Notably, Peter Thiel has acquired a 9.1% stake. If staking is subsequently enabled, the profit potential is substantial.
  • SharpLink Gaming , formerly a sports betting company, officially designated ETH as its core reserve asset in June and appointed Ethereum co-founder Joseph Lubin as chairman of its board. Its holdings are now nearly fully staked, providing a stable source of passive income.
  • The Ether Machine was formed through a SPAC merger and plans to hold more than $1.5 billion in ETH. Management has publicly stated that it will focus on staking, re-staking and DeFi operations, and even mentioned trying revolving loans on Aave.
  • Bit Digital has completed its transformation from a traditional mining company to an Ethereum asset management and staking platform, with a clear strategic positioning.
  • ETHZilla has shifted from biotechnology to the entertainment and gaming industries, while developing ETH-related accumulation tools. Peter Thiel's investment team is also behind it.

Overall, the logic behind the ETH treasury differs from that of Bitcoin. Bitcoin's core value lies more in its role as a reserve asset, while ETH's advantage lies in its inherent income streams. The current nominal yield on Ethereum staking is approximately 2.95%, and the inflation-adjusted real yield is 2.15%. If 30% of existing corporate holdings were staked, and the ETH price remained at $4,000, the corresponding annualized return would be approximately $79 million. This figure demonstrates that ETH treasury companies can generate relatively stable cash flow despite price fluctuations.

On an operational level, companies have two primary options: directly operating a validator node; or leveraging liquidity staking protocols (such as Lido, Coinbase, and RocketPool). The US SEC has clarified that such protocols are not considered securities, clearing regulatory barriers for institutional participation and enabling them to obtain additional liquidity tokens as derivative assets.

These derivative assets, such as Lido's stETH, are highly composable in the DeFi market and can be further used as lending or liquidity mining tools. For example, Aave v 3's ETH and stETH pool has surpassed 1.1 million ETH. With the influx of more corporate treasuries, the pool is expected to continue to expand, significantly enhancing market liquidity while boosting yields.

The core competitiveness of ETH DAT lies in its hierarchical and scalable revenue structure, which gives it a stronger latecomer advantage compared to Bitcoin DAT.

SOL DAT is trying to catch up, but its scale is still small.

An increasing number of publicly listed companies are adding Solana to their balance sheets. Solana's total market capitalization is currently approximately $107 billion. According to data, publicly listed companies currently hold over 4 million Sol, valued at over $800 million. However, these companies' stock prices haven't performed well. This may be due to the lack of a leading strategy in Solana's reserve market and the pending approval of a Solana ETF.

However, a new wave of capital is rushing in. Currently, publicly traded companies hold only 0.69% of the circulating supply of SOL. However, Pantera Capital recently pledged $1.25 billion, and Galaxy, Multicoin, and Jump have jointly pledged $1 billion. Together, these funds represent 3.5 times the amount currently held by publicly traded companies.

More specifically, Galaxy, Multicoin, and Jump plan to acquire a publicly traded company to create a digital asset finance company focused on Solana. Pantera, led by former Tiger Management executive Dan Morehead, also plans to raise $1.25 billion to acquire a Nasdaq-listed company and transform it into a Solana-focused investment company, tentatively named "Solana Co." Pantera and Galaxy previously profited handsomely by purchasing a significant amount of Solana at a low price from the bankrupt FTX. Simply put, their new moves can be understood as a sign of having earned enough money and preparing to up the ante.

The rise of the DAT model offers these institutions a new and advanced way to capture value. Through DAT, they can not only hold SOL and wait for price increases, but also earn steady returns through various DeFi protocols, achieving multiple asset appreciation.

Bitcoin's performance over the past two years shows that when institutions begin systematically accumulating a particular cryptoasset, it often enters a relatively stable upward trend. Ethereum's example illustrates this point. The difference between Solana and Ethereum DAT companies is also clear: institutions choose ETH largely for its decentralization, while Solana is drawn to its public blockchain attributes and potential for user-facing applications.

Judging by the DAT's efficiency in absorbing trading supply, the $2.5 billion SOL DAT initiative, brought about by Galaxy and Pantera, is equivalent to the $30 billion raised by ETH or the $91 billion raised by BTC. SOL DAT's efficiency is higher than ETH for two reasons: First, circulating supply does not equal tradable supply. Currently, 63.1% of Solana's tokens are staked, leaving very little available for trading. Meanwhile, ETH's stake rate is only 29.6%, resulting in a high tradable volume and making it more difficult to drive price. Second, the relative impact of capital. SOL's market capitalization is far lower than that of ETH and BTC. From a relative valuation perspective, investing $1 in SOL DAT far outperforms the same investment in ETH and BTC.

Moreover, with the SOL ETF expected to be approved by the end of this year, the impact of this buying on prices may be even more pronounced.

DAT expectations for BNB and other tail assets

BNB DAT

CEA Industries: Targeting 1% of BNB's Total Supply

CEA Industries (ticker: BNC) recently announced that it has increased its BNB holdings to 388,888, with a market capitalization of approximately $330 million. The company plans to hold approximately 1% of the total BNB supply, or approximately 10 million BNB, by the end of 2025. This move underscores its commitment to digital assets as part of its core strategy, similar to MicroStrategy's approach to Bitcoin. Additionally, CEA Industries, in partnership with 10X Capital, has received a $500 million private investment from YZi Labs, consisting of $400 million in cash and $100 million in crypto assets, to further expand its BNB reserves.

Nano Labs: Steadily increasing BNB reserves

Nano Labs (NASDAQ: NA) currently holds approximately 128,000 BNB, with an average acquisition cost of $713 per coin, for a total market capitalization of approximately $108 million. The company added 8,000 BNB via over-the-counter trading, demonstrating its commitment to BNB as a long-term store of value. This strategy may lay the foundation for further expansion into the digital asset space.

Liminatus Pharma: Establishment of a subsidiary company for the US BNB strategy

Liminatus Pharma (NASDAQ: LIMN) plans to raise up to $500 million in phased funding over the next few years through its newly established subsidiary, "American BNB Strategy," to strategically invest in BNB. This move signals a move by traditional biopharmaceutical companies to actively embrace digital assets and explore the potential of incorporating BNB into their asset allocations.

Windtree Therapeutics: Using $520 million in financing for BNB strategy

Windtree Therapeutics (NASDAQ: WINT) announced plans to raise up to $520 million, 99% of which will be used to purchase BNB to bolster its digital asset treasury. The company has also reached an agreement with Kraken to serve as the custody provider for its BNB holdings. This move demonstrates the traditional biotech company's active transition into the digital asset space.

China Renaissance: Hong Kong's first listed company to directly hold BNB

In August 2025, Huaxing Capital signed a memorandum of understanding with YZi Labs, planning to invest $100 million in BNB, becoming the first Hong Kong-listed company to directly hold BNB. Furthermore, Huaxing Capital plans to launch a compliant BNB fund product and establish a BNB-based stablecoin and on-chain application (RWA).

B Strategy: Plans to raise $1 billion to establish the BNB Treasury Company

B Strategy plans to go public in the United States and establish a treasury company focused on BNB investment, aiming to raise $1 billion. The company has received strategic support from YZi Labs.

Amber International and Hash Global: Launch BNB Fund

Amber International (NASDAQ: AMBR), in partnership with Hash Global, has launched the BNB Fund, which aims to invest its $100 million cryptocurrency reserves in BNB. The fund, a blockchain-native income product, aims to provide a stable income stream for institutional investors.

DAT layout of Ethena and SUI

Ethena (ENA): A strategic investment from StablecoinX and Mega Matrix

Ethena's native token, ENA, is attracting the attention of institutional investors. StablecoinX plans to raise $895 million through a SPAC merger to fund its ENA token reserve. Additionally, MegaMatrix has filed a $2 billion structured registration statement with the U.S. Securities and Exchange Commission (SEC) for its USDe and ENA reserve.

SUI: Sui Group Holdings' strategic layout

Sui Group Holdings, the only publicly listed company backed by the Sui Foundation, holds approximately 102 million SUI tokens with a market capitalization of approximately $345 million. The company plans to continue raising capital to purchase more discounted locked SUI tokens, increasing the amount of SUI held per share and creating value for shareholders.

Whether non-mainstream DATs can generate sufficient influence, or even sustain a positive flywheel, is crucial. The key isn't whether their mNAV remains consistently above 1, maintaining a premium. mNAV could fall below 1, leading to a discount. However, for these companies, selling crypto assets at a discount is a recipe for disaster.

The core aspects of evaluating non-mainstream DATs should be their financing capabilities and buying power:

The former represents the company's level of optimism and confidence in the cryptoasset. Whether the company has good financing channels to purchase cryptoassets during periods of price discount or downturn is the best endorsement for DAT companies. The positive impact of financing scale can, to a certain extent, boost mNAV. Looking at the DAT progress of the three aforementioned cryptoassets, BNB and Ethena's DAT companies both have very strong and extensive financing capabilities, making them more likely to promote long-term positive price growth.

Secondly, the ability to consistently buy is crucial. Consistently and disciplined execution of an investment strategy, demonstrating research and timing prowess to the market, is fundamental to building a brand and earning premium pricing. Having sufficient ammunition to consistently buy when discounts occur is the best way to demonstrate confidence to the market.

BNB, Ethena, and Sui haven't yet experienced this stage. However, once the FOMO (Fear of Monetization) of mainstream DATs subsides, the survival of DATs focused on tail assets will depend not only on the two factors mentioned above but also on whether they can provide crypto protocols with more asset-based gameplay. This may be a watershed in the competition for these DATs. Wall Street merely brings in incremental capital; leveraging this capital pool is crucial. Maximizing asset efficiency, innovating programmable liquidity, and capturing value across multiple dimensions are key. Precise financial engineering and tangible returns will set the leaders of these DATs apart.

A Rational Look at the DAT Flywheel

DATs aren't some high-flying financial innovation; they're essentially a regulatory arbitrage tool: In the absence of full clarity on existing crypto asset regulations, Wall Street and some publicly listed companies are using DATs to rapidly deploy crypto assets. While this wave of DAT enthusiasm may superficially mimic MicroStrategy's strategic strategy, its core driving force stems more from market fear of monetization (FOMO) amidst a period of lax official regulation. In other words, the DAT boom is clearly short-term speculative, and its sustainability depends on the dual influence of market sentiment and regulatory policies.

In terms of a flywheel mechanism, DATs can amplify returns during bull markets: asset market capitalization increases, mNAV premiums increase, and liquidity strengthens, creating a positive feedback loop. However, this mechanism can also amplify risks in the event of a market reversal. When mNAV discounts or premiums disappear, some DAT companies may be forced to liquidate assets, triggering a chain reaction of selling pressure and amplifying short-term price fluctuations. While DATs' complex structures attract institutional capital, they also exacerbate information asymmetry, making it difficult for retail investors to fully understand their risk exposure and the true value of their assets.

From a valuation perspective, DATs could potentially return the market to a narrative-driven phase: in the short term, prices will be more dependent on market expectations, concept popularity, and institutional participation. Hot money influxes may drive prices higher, but such increases lack underlying value support. While the rise of Ethereum DATs is expected to boost on-chain staking, DeFi activity, and ecosystem participation, their long-term impact on corporate profitability and the overall health of the ecosystem remains highly uncertain.

Overall, the DAT flywheel can generate short-term gains and attract market attention during market booms, but investors need to rationally understand its limitations: high leverage amplifies both upside gains and downside risks, while regulatory pressure, liquidity tightening, and mNAV discounts are all key factors that could disrupt this inflated structure at any time.

About Movemaker

Movemaker, authorized by the Aptos Foundation and co-founded by Ankaa and BlockBooster, is the first official community organization dedicated to promoting the development of the Aptos ecosystem in the Chinese-speaking region. As the official representative of Aptos in the Chinese-speaking region, Movemaker is committed to building a diverse, open, and prosperous Aptos ecosystem by connecting developers, users, capital, and numerous ecosystem partners.

Disclaimer:

This article/blog is for informational purposes only and reflects the author's personal views and does not necessarily represent the views of Movemaker. This article is not intended to provide: (i) investment advice or a recommendation; (ii) an offer or solicitation to buy, sell, or hold digital assets; or (iii) financial, accounting, legal, or tax advice. Holding digital assets, including stablecoins and NFTs, carries a high degree of risk and carries significant price volatility, potentially becoming worthless. You should carefully consider whether trading or holding digital assets is appropriate for you based on your financial circumstances. If you have questions regarding your specific situation, please consult your legal, tax, or investment advisor. The information provided in this article (including market data and statistics, if any) is for general informational purposes only. While reasonable care has been taken in preparing these data and charts, no liability is assumed for any factual errors or omissions contained therein.

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