CertiK releases Skynet report: US digital asset regulation forms a systematic framework for the first time.
- 核心观点:美国数字资产监管进入体系化新阶段。
- 关键要素:
- 《GENIUS》《CLARITY》法案及SAB121废止构成监管三支柱。
- 明确资产分类与托管规则,降低交易平台合规风险。
- 监管差异或致美欧稳定币市场割裂,代码审计重要性凸显。
- 市场影响:引导行业从规避转向合规内可持续发展。
- 时效性标注:中期影响

On December 4th, CertiK, the world's largest Web3 security company, released the "2025 Skynet U.S. Digital Asset Policy Report," which systematically outlines the overall trend of U.S. digital asset regulation in 2025. The report points out that the U.S. has established a relatively clear and systematic digital asset regulatory framework for the first time, moving the U.S. digital asset market from an "exploratory phase" to a "systematic phase." As the regulatory direction for centralized functions becomes increasingly clear, code auditing will become a key measure for institutions to ensure security and compliance.
As the US federal regulatory framework gradually takes shape, the global landscape begins to diverge.
The enactment of the GENIUS Act, the passage of the CLARITY Act in the House of Representatives, and the repeal of Employee Accounting Bulletin 121 by the Securities and Exchange Commission (SEC) constitute the new three pillars of federal regulation. These three measures establish federal regulatory standards for stablecoins, principles for classifying digital assets, and compliance pathways for banks to conduct custody business. For the first time, the operational requirements of banks, stablecoin issuers, and interstate institutions have received systematic guidance.
As the first federal regulatory framework in the United States specifically targeting payment-based stablecoins, the GENIUS Act sets forth systematic requirements for issuance structure, prudential standards, and technical compliance, including 100% liquidity reserves, a ban on paying yield to holders, role-based access control (RBAC) for smart contracts, and a freeze permission governance mechanism.
Meanwhile, the report points out that the differences between the US GENIUS Act and the EU MiCA Act in terms of reserve asset composition and judicial requirements will lead to a situation where the stablecoin market will have both "US versions" and "EU versions" running in parallel in the future, resulting in a fragmentation of cross-regional liquidity.
Clear asset classification and reforms in custody and accounting are driving market restructuring.
The Clarity Act uses a function-based approach to delineate the regulatory boundaries between the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC): "digital commodities" such as gas tokens and governance tokens will fall under the jurisdiction of the CFTC, while tokens used for fundraising purposes will remain under the regulation of the SEC. The Act clarifies that transactions by non-issuers on the secondary market do not constitute securities offerings, reducing potential compliance risks for trading platforms.
In addition, the Senate’s Responsible Financial Innovation Act (RFIA Act) and the “bipartisan discussion draft” provide supplementary pathways for the future regulation of the digital goods market; the repeal of SAB 121 removes a major accounting barrier for large financial institutions to enter the digital asset custody business.
Upgrading infrastructure and compliance technologies, code auditing becomes a key measure for security and compliance.
The report also highlights recent developments in clearing and settlement infrastructure, including the regulated liabilities network (RLN) being tested by the Federal Reserve Bank of New York and several large banks, and the Monetary Authority of Singapore's Project Guardian initiative promoting global asset tokenization standards. These pilots validate the feasibility of tokenized deposits, wholesale central bank digital currencies, and cross-border financial activities, laying the foundation for future compliant financial infrastructure.
In terms of compliance monitoring, the adoption of regulatory technologies continues to expand: from using Benford's Law to identify abnormal transactions and using clustering algorithms to monitor manipulation, to adding requirements such as freezing function verification in smart contract audits, reflecting that regulatory agencies are improving their ability to monitor on-chain activities in real time.
It is worth noting that as regulators have become increasingly clear about the direction of centralized functions, financial institutions are gradually shifting their strategic focus to permissioned digital assets, and code auditing is becoming an important means of ensuring institutional security and compliance. This trend is driving the continued development of the industry.
Regulation enters a systematic stage
Overall, by 2025, US digital asset regulation will be transitioning from an "exploratory phase" to a "systematic phase," with digital assets steadily integrating into the US financial system. As policy boundaries become clearer, the industry's focus is shifting from regulatory circumvention to finding sustainable development solutions within the regulatory framework. At the same time, market fragmentation caused by regulatory differences will be one of the key challenges that institutions need to address.


