分类： Bitcoin

Coinbase’s new token pre-reserve platform reopens US retail participation in public token sales for the first time since regulators shut down the ICO boom in 2018.

The mechanism looks familiar, with curated projects, fixed sale windows, and algorithmic allocation. Every purchase is settled in USDC, and every token launched through the platform receives a guaranteed listing on Coinbase.

However, it introduces new structural constraints, such as prohibiting issuers from selling tokens on secondary markets for six months after launch.

Additionally, users who flip allocations within 30 days get deprioritized in future sales.

The bet is behavioral: if you punish early exits and reward patience, you can suppress the “dump-on-listing” pattern that has destroyed credibility in every previous initial exchange offering (IEO) cycle.

If the incentives hold, Coinbase builds a recurring primary market for US users who behave like investors rather than airdrop farmers. If they don’t, the platform recreates the same churn dynamics in a compliance-wrapped package that regulators might still classify as unregistered securities offerings.

The first test runs from November 17 to 22 with Monad, a layer-1 blockchain project. The sale window remains open for one week, and allocation is based on a bottom-up algorithm that prioritizes smaller purchase requests, progressively filling larger orders until the supply is exhausted.

Coinbase charges issuers, not participants, and frames the entire structure as an “IPO-lite for tokens,” featuring disclosure-heavy listings that are guaranteed by the platform and designed to prevent insiders from exiting into retail demand.

Lockup logic

The issuer-side restriction is straightforward. Teams and affiliates cannot sell tokens over-the-counter or on secondary markets for a period of six months following the public sale.

Any exception requires Coinbase approval, public disclosure, and a vesting structure that ensures tokens unlock only after the six-month window closes.

This directly targets the playbook used between 2017 and 2021, where founding teams and venture backers quietly liquidated into the first price spike, leaving retail holding tokens backed by nothing but a Discord server and a roadmap deck.

The user-side mechanism is softer but equally deliberate. Participants who sell allocations within 30 days of listing receive reduced priority in future sales.

Coinbase does not ban flippers outright; instead, it deprioritizes them. That turns post-launch behavior into a reputation signal, benefiting holders who remain patient, while those who exit quickly forfeit future allocation advantages.

The structure assumes that token sales will recur monthly, creating a game-theoretic loop where rational participants trade short-term gains for long-term access to the platform.

Together, these rules anchor supply and block insiders from dumping immediately. Early participants face a soft penalty for doing the same.

The freely tradable float on day one contracts, which should dampen the violent listing spikes and crashes that defined Binance Launchpad’s run between 2019 and 2021.

The question is whether that discipline survives contact with actual price action. If early cohorts deliver multiples, many users will rationally accept future penalties in exchange for realized profits.

The platform cannot force behavior. It can only make flipping marginally more expensive.

Differences from established platforms

Binance Launchpad is the most established launchpad fueled by a centralized exchange, so a comparison is only natural. In this case, their differences are structural, not just cosmetic.

Binance gates participation through BNB holdings. Users commit or stake BNB to earn lottery tickets, with ticket counts scaled to average balances over a snapshot period.

That design creates a built-in advantage for large BNB holders, and doubles as a utility flywheel for Binance’s native token. Allocation follows a lottery or pro-rata system, where larger BNB positions have historically yielded larger allocations.

Coinbase decided to run a different architecture. Participation requires full KYC and account-in-good-standing status, with no house token requirement. Payment settles exclusively in USDC.

The allocation algorithm works bottom-up, filling smaller requests first and progressively allocating larger orders until supply is exhausted.

That design should flatten holder distribution, fueling fewer mega-allocations and more addresses with modest stakes, and remove the structural skew toward exchange token whales.

Cadence differs as well. Coinbase stated that it would commit to roughly one sale per month and explicitly added launched tokens to its listings roadmap, which the market will treat as a de facto listing guarantee.

Binance Launchpad operates opportunistically, with a cadence dependent on deal flow and no formal rule requiring projects to list. Launchpad tokens typically appear on Binance, but the commitment is implicit rather than contractual.

The behavioral constraints separate the two models most clearly. Coinbase imposes platform-level discipline, including six-month issuer lockups and anti-flip penalties, which are enforced through future allocation scoring.

On the other hand, Binance Launchpad does not include any comparable system-wide restrictions. Project-specific vesting exists, but Binance does not penalize users for selling Launchpad allocations quickly, and issuers face no standardized lockup enforced by the platform itself.

That structural gap explains why launchpad sales have historically produced sharp listing pops followed by prolonged declines: demand is concentrated among BNB holders, supply is unlocked aggressively, and the lack of a recurring-program incentive keeps early participants from rotating into the next opportunity.

Potential changes in concentration, liquidity, and price behavior

If Coinbase’s design functions as intended, the concentration of whales should decline relative to other platforms.

The KYC requirement, bottom-up allocation, and absence of native token gating remove the obvious structural advantages for exchange token holders. Sybil attempts and OTC pre-accumulation remain possible, but the platform is engineered to produce more small holders and fewer dominant positions than a BNB-weighted lottery.

Day-one liquidity presents a trade-off, as guaranteed Coinbase listing and wide distribution should support order-book depth from launch. However, the issuer lockup and soft penalties for flipping mean that a portion of the supply stays functionally frozen through incentives.

That dampens the extreme first-day blow-offs seen in classic IEOs, but it also thins the freely tradable float early on, which makes the market more sensitive to any real sell pressure that does materialize. Less dump risk, but more fragility if conviction wavers.

Post-listing price behavior should diverge from Binance’s boom-bust pattern. Their launchpad historically delivered strong BNB-fueled demand, sharp listing premiums, then gravity once farming incentives faded and insiders rotated.

Coinbase appears to be aiming for a different outcome, characterized by slower and disclosure-heavy sales, constrained insider exits, recurring rewards for holding, and alignment with US compliance standards.

If that structure holds, the result is smaller but more durable listing premiums, tighter correlation between project fundamentals and token performance, and a stronger link between real user behavior and primary market access.

Unresolved risks

The platform’s success depends on two variables Coinbase cannot fully control: regulatory classification and user discipline.

US regulators could decide that these offerings constitute unregistered securities sales, despite the structuring, particularly if Coinbase-listed tokens trade primarily as speculative instruments rather than as network utility assets.

The six-month lockup and listing guarantee might reinforce that interpretation rather than deflect it.

User behavior presents the second constraint. If early sales deliver quick multiples, rational participants will accept future allocation penalties in exchange for realized profits.

The platform’s anti-flip mechanism makes quick exits marginally more expensive, but it does not eliminate the incentive to do so. If enough users defect, the same churn dynamics return in a softer form, albeit with improved compliance paperwork and a longer vesting period for insiders.

Coinbase’s design gives this cycle a better structural shot than any US-facing token launch mechanism since 2018. The lockups reduce immediate supply overhang, the bottom-up allocation widens distribution, and the recurring-program incentive rewards patient capital.

However, structure is not destiny. The platform works only if users, issuers, and regulators play along.

The Monad sale is not just a product launch, but a stress test to see if anyone actually wants token sales to work differently this time.

Regardless of what Crypto Twitter says, DTCC pages show operational prep, not permission.

Under the SEC’s new generic-listing regime, the real tells are an effective S-1 and an exchange listing notice, and that is when the clock to launch actually starts.

DTCC pages listing XRP ETFs are not approvals. The entry means the clearing and settlement plumbing is getting ready in case a fund launches, not that the SEC has authorized anything.

The firm made that point during the 2023 Bitcoin frenzy, noting that appearance on its site is not indicative of a regulatory decision, a caution that applies here as well.

Inside the ETF playbook: DTCC workflows and the SEC’s new generic listing rules

According to DTCC, ETF processing encompasses creation, redemption, and post-trade flows once a product is listed and effective. Operational records can exist before the first trade to facilitate connectivity for participants.

The regulatory playbook also shifted in September. The SEC approved generic listing standards for commodity-based trust shares on NYSE Arca, Nasdaq, and Cboe BZX, which allows exchanges to list qualifying spot commodity ETPs without product-by-product 19b-4 approvals.

Issuers still need an effective registration statement, typically an S-1, before they can begin trading. According to the SEC, the exchange rule changes shift the bottleneck from exchange approval to the effectiveness of disclosure and final operations.

For XRP, the message is clear. A plain-vanilla spot trust that fits the generic standards can list once its S-1 is declared effective and the exchange posts a listing circular with the ticker and date.

Leveraged or otherwise novel designs remain outside the generic lane and still tend to require a bespoke 19b-4 review.

From rumor to reality: the real XRP ETF approval checklist

The real-approval checklist now follows a clear sequence that investors can verify in minutes.

1. The SEC must declare the S-1 effective, which finalizes fees, creation unit size, custody, and risk disclosures, and often includes references to Authorized Participant agreements.
2. The listing exchange issues a public notice that sets the ticker and listing date.
3. Operational confirmations appear, including DTC eligibility, NSCC readiness, and a CUSIP assignment, which are necessary for settlement but not dispositive on their own.

There are real XRP filings on EDGAR, and they are recent; however, none of them is an approval.

• Grayscale filed an S-1 for Grayscale XRP Trust in August, with amendments in October and November that reference NYSE Arca listing mechanics and AP.
• Franklin’s S-1 includes a Nov. 4 counsel exhibit tied to its registration number.
• CoinShares submitted an S-1 with details on forks and airdrops.
• Teucrium referenced a 2x daily XRP product in its April filings, and ProShares updated its Ultra and Short XRP materials in April as well, which are leverage-based and more likely to fall outside the new generic standards.

The marketplace rumor that five or nine XRP ETFs are already “on DTCC” blends a true operational observation with the wrong conclusion.

Entries can appear there while issuers and exchanges complete the final documentation, participants test the creation of baskets, and custodial chains are established.

According to DTCC, operational status is not a forward indicator of SEC approvals. Treat any count of entries as unverified marketing noise until each record aligns with a declared-effective S-1 and a public listing circular.

Under the generic-listing regime, the timing compresses once the S-1 becomes effective. A fast-track scenario involves exchanges posting a circular within a few days, APs seeding the fund, and the NSCC processing creations without delay.

A base-case window runs a few weeks if AP onboarding or final exhibits need polish. Slower paths extend when leverage, derivatives, staking, or other non-standard features trigger additional review.

What DTCC limits actually mean once XRP ETFs go live

Market-structure constraints also matter. DTCC has set limits in the past on collateral treatment for crypto-linked ETFs, which does not affect approval but does impact the financing and prime services posture around the funds after launch.

Investors can cut through the noise with a three-receipts rule.

1. Check EDGAR for an S-1 that reads “has been declared effective.”
2. Check the exchange website for a listing circular that names the ticker and the listing date.
3. Only then look to DTCC or DTC records for eligibility and CUSIP as operational confirmation. If steps one and two are missing, there is no approval.

Issuer / Fund	Filing Type	Last Filing Date	Notes	Source
Grayscale XRP Trust	S-1 and amendments	Nov 3, 2025	AP references, NYSE Arca path stated	S-1/A
Franklin XRP Trust	S-1, counsel exhibit	Nov 4, 2025	Exhibit tied to Reg. No. 333-285706	SEC
CoinShares XRP ETF	S-1	2025	Fork and airdrop handling disclosed	SEC
Teucrium XRP ETFs	N-1A and correspondence	Apr 7, 2025	2x daily product outside generic lane	SEC
ProShares Ultra/Short XRP	N-1A post-effective	Apr 30, 2025	Leverage products require bespoke review	SEC
Bitwise XRP ETF	S-1 and amendments	Oct 31, 2025	Amendment No. 4 to S-1 under generic commodity-based trust standards	SEC
Canary XRP ETF	S-1 and amendments	Oct 24, 2025	Pre-effective S-1/A with updated prospectus and expert consent	SEC
21Shares XRP ETF	S-1 and amendments	Nov 7, 2025	Cboe BZX-listed spot trust; latest S-1/A and counsel opinion filed	SEC
WisdomTree XRP Fund	S-1	Dec 2, 2024	Spot XRP ETF registration statement	SEC
Volatility Shares XRP ETFs	N-1A post-effective amendments	May 21, 2025	XRPI (1x) and XRPT (2x) XRP futures ETFs registered via N-1A	SEC

The bottom line is unchanged in the generic-standards era. DTCC entries indicate that the gate is open for settlement once a fund is otherwise ready; however, they are not a proxy for the SEC’s decision.

The real tells are an effective S-1 and a listing circular that names the ticker and the date. Until those two appear, there is no XRP ETF.

Strategy (formerly MicroStrategy) has earned a reputation for making its weekly Bitcoin acquisitions near the local top in recent weeks.

On Nov. 10, CryptoQuant analyst JA Marturn noted that the firm’s most recent acquisition disclosure from Michael Saylor followed the same script.

According to an SEC filing, Strategy announced that it had acquired 487 BTC between Nov. 3 and Nov. 9 for $49.9 million at an average price of $102,557 per coin.

While the flagship asset spent most of the past week trading sideways, Bitcoin had reached a high of above $106,000 on Nov. 3 before sliding more than 9% to trade briefly below $100,000. It continues to battle with the $106,400 support-turned-resistance and the $100,000 local floor.

However, Saylor’s firm was unable to buy at the market bottom. Instead, the purchases arrived at one of the highest prices the top asset traded last week.

This is consistent with the firm’s previous purchases, which coincided with short-term peaks, and raises the question of why the firm continues to “buy the top.”

While the consistency of this visual pattern fuels an impression of mistimed execution, it tells only part of the story.

Why Strategy tends to buy into BTC strength

Strategy’s purchases tend to cluster around moments of elevated liquidity for reasons unrelated to market enthusiasm.

The firm’s corporate treasuries deploy capital at specific points, such as after equity sales, convertible issuances, or internal liquidity events.

These windows rarely align with discounted market conditions. Instead, they often open during periods when Bitcoin is trading with deeper order books and lower execution risk.

Market analysts have noted that this structural reality explains why Strategy’s entries often align with local highs. Large corporate orders are executed when market depth is strongest, which typically corresponds with rallies rather than periods of drawdown.

As a result, acquisition filings can create an optical illusion of systematically buying at peaks, even when the timing is set by liquidity availability and internal controls rather than sentiment.

For Strategy, the marginal price of a given tranche is secondary.

Saylor has consistently framed Bitcoin as a long-duration monetary instrument, and the firm’s operations follow that doctrine. The objective is steady exposure, not precision timing.

So, the firm’s execution windows are defined by corporate processes, and consistency of accumulation is prioritized over opportunistic entry.

Long-term performance vs. structural risks

Over a longer horizon, criticisms of Strategy’s timing lose some force.

Since Strategy began buying Bitcoin in 2020, its treasury has grown into one of the most profitable corporate asset allocations in modern history.

The company now holds 641,692 BTC, valued at approximately $68 billion, which was purchased at an average price of $106,000, resulting in a total cost basis of $67.5 billion. At current prices, that position implies roughly $20.5 billion in paper gains.

Even more striking, Strategy has generated over $12 billion in Bitcoin gains in YTD 2025, despite slowing its pace of accumulation to a few hundred coins in recent weeks.

This is the paradox at the heart of the Saylor strategy: the entries look poor, but the results are exceptional. It shows a corporate dollar-cost averaging on a structural timeline.

Short-term volatility amplifies the impression that Strategy buys tops; the multi-cycle reality shows that those “tops” often become deeply profitable entries over time.

A broader comparison emphasizes the point. Over the past year, Strategy’s equity (MSTR) has shown 87% volatility, sharply higher than Bitcoin’s 44%, and more volatile than the company’s other digital-asset products.

Yet despite this intensity, the cumulative exposure to Bitcoin has turned that volatility into asymmetric upside.

However, the strong returns do not immunize the company from structural vulnerabilities. Barchart data shows that a $10,000 investment in MSTR during the dot-com peak would be worth $7,207 today, illustrating two decades of volatility independent of the Bitcoin strategy.

Moreover, some analysts argue that Strategy’s dependence on capital markets introduces material risks if the cryptocurrency enters a multi-year downturn.

Those concerns have intensified as the company’s balance sheet has evolved.

Chris Millas, an advisor at Mellius Bitcoin, Brazil’s first Bitcoin treasury firm, noted that during the last bear market, the firm carried no interest-bearing debt and had years before its earliest bond maturities. So, its equity volatility was painful but had a limited operational impact.

However, this cycle is different. Strategy now holds interest-bearing obligations that must be serviced regardless of market conditions.

Millas argued that a severe drop in MSTR’s share price, which is historically plausible given the stock’s drawdowns of 70–80% in prior cycles, would limit the company’s flexibility and increase the likelihood of dilutive capital issuances.

According to him, that dilution, in turn, could pressure the stock further, creating a feedback loop that magnifies downside risk.

Indeed, Strategy faces roughly $689 million in interest payments due in 2026. Without new capital, the company cannot meet that obligation.

Moreover, recent fundraises highlight how financing conditions have shifted, with preferred-share offerings pricing yields around 10.5%, above the initial guidance of near 10%. The widening spread signals that capital is becoming more expensive, complicating the economics of debt-funded Bitcoin accumulation.

Due to this, skeptics have pointed out that the model resembles a leveraged carry trade with limited margin for error. In fact, some have labeled the process “Ponzi-like”, while arguing that the firm’s liabilities are growing faster than operating income.

According to them, this leaves Strategy dependent on either rising Bitcoin prices or continued investor appetite for high-yield instruments.

Signal power and narrative strategy

Even with these risks, Strategy’s purchases continue to exert outsized narrative influence. The company files frequent and transparent disclosures, and its visibility allows the acquisitions to function as a form of market signaling.

So, Strategy’s buying into strength reinforces the message that Bitcoin is a long-term monetary asset rather than a timing-sensitive trade.

Moreover, as several of Strategy’s higher-price filings in recent weeks have coincided with periods of market hesitation, the filings contribute to stabilizing sentiment by demonstrating steady institutional demand.

This has allowed Strategy to effectively position itself as the market’s most consistent large-scale buyer, and its disclosures serve both operational and symbolic purposes.

This dual role explains why Saylor continues to accumulate through short-term peaks.

For Strategy, the purchase price of any given week is secondary to the multi-year trajectory of both Bitcoin and the company’s identity as its largest corporate holder.

The optics may draw criticism, especially during periods of elevated volatility. Still, the framework guiding the purchases remains consistent: Strategy is not positioning for the next quarter, but for the next decade.

China’s National Computer Virus Emergency Response Center just accused the United States of carrying out the 2020 LuBian Bitcoin exploit.

However, Western research ties the event to a wallet random-number flaw and does not name a state actor.

Open-source forensics on the LuBian drain

The core facts of the episode are now well documented across open sources. According to Arkham, approximately 127,000 BTC were moved out of wallets associated with the LuBian mining pool over a period of about two hours on December 28–29, 2020, through coordinated withdrawals across hundreds of addresses.

According to the MilkSad research team and CVE-2023-39910, those wallets were created with software that seeded MT19937 with only 32 bits of entropy, which reduced the search space to approximately 4.29 billion seeds and exposed batches of P2SH-P2WPKH addresses to brute-force attacks.

MilkSad’s Update #14 links a cluster holding roughly 136,951 BTC that was drained beginning on 2020-12-28 to LuBian.com through on-chain mining activity and documents the fixed 75,000 sat fee pattern on the sweep transactions. Blockscope’s reconstruction shows the bulk of the funds then sat with minimal movement for years.

Those same coins now sit in wallets controlled by the U.S. government. According to the U.S. Department of Justice, prosecutors are pursuing the forfeiture of approximately 127,271 BTC as proceeds and instrumentalities of alleged fraud and money laundering tied to Chen Zhi and the Prince Group. The DOJ states that the assets are presently in U.S. custody.

Elliptic shows that addresses in the DOJ complaint map onto the LuBian weak-key cluster that MilkSad and Arkham had already identified, and Arkham now tags the consolidated destination wallets as U.S. government-controlled. On-chain sleuths, including ZachXBT, have publicly noted the overlap between the seized addresses and the earlier weak-key set.

What the forensic record shows about the LuBian exploit

Regarding attribution, technical teams that first identified the flaw and traced the flows do not claim knowledge of who executed the 2020 drain. MilkSad repeatedly refers to an actor who discovered and exploited weak private keys, stating they do not know the identity.

Arkham and Blockscope describe the entity as the LuBian hacker, focusing on method and scale. Elliptic and TRM confine their claims to tracing and to the match between the 2020 outflows and the later DOJ seizure. None of these sources names a state actor for the 2020 operation.

CVERC, amplified by the CCP-owned Global Times and local pickups, advances a different narrative.

It argues that the four-year dormancy period deviates from common criminal cash-out patterns and therefore points to a state-level hacking organization.

It then links the later U.S. custody of the coins to the allegation that U.S. actors executed the exploit in 2020 before converting it into a law enforcement seizure.

The report’s technical sections track closely with independent open research on weak keys, MT19937, address batching, and fee patterns.

Its attribution leap rests on circumstantial inferences about dormancy and ultimate custody rather than new forensics, tooling ties, infrastructure overlaps, or other standard indicators used in state actor attribution.

What we actually know about the LuBian Bitcoin drain

There are at least three coherent readings that fit what is public.

1. One is that an unknown party, criminal or otherwise, found the weak-key pattern, drained the cluster in 2020, left the coins mostly dormant, and U.S. authorities later obtained the keys through seizures of devices, cooperating witnesses, or related investigative means, which culminated in consolidation and forfeiture filings in 2024–2025.
2. A second treats LuBian and related entities as part of an internal treasury and laundering network for Prince Group, where an apparent hack could have been an opaque internal movement between weak-key-controlled wallets, consistent with DOJ’s framing of the wallets as unhosted and within the defendant’s possession, though public documents do not fully detail how Chen’s network came to control the specific keys.
3. The third, advanced by CVERC, is that a U.S. state actor was responsible for the 2020 operation. The first two align with the evidentiary posture presented in the filings of MilkSad, Arkham, Elliptic, TRM, and the DOJ.

The third is an allegation not substantiated by independent technical evidence in the public domain.

A brief timeline of the uncontested events is below.

From a capability standpoint, brute forcing a 2^32 seed space is well within reach for motivated actors. At about 1 million guesses per second, a single setup can traverse the space in a few hours, and distributed or GPU-accelerated rigs compress that further.

Feasibility is central to the MilkSad-class weakness, explaining how a single actor can sweep thousands of vulnerable addresses simultaneously. The fixed-fee pattern and address derivation details published by MilkSad and mirrored in CVERC’s technical write-up reinforce this method of exploitation.

The remaining disputes lie in ownership and control at each step, not in the mechanics. DOJ frames the wallets as repositories for criminal proceeds tied to Chen and states the assets are forfeitable under U.S. law.

Chinese authorities frame LuBian as a victim of theft and accuse a U.S. state actor of the original exploit.

Independent blockchain forensics groups connect the 2020 outflows to the 2024–2025 consolidation and seizure, and stop short of naming who pressed the button in 2020. That is the status of the record.

Earlier this year, President Donald Trump promised a “21st Century” payments upgrade without requiring a central bank digital currency, putting the GENIUS Act at the center of the plan.

The law is already on the books; the operating rulebook is not yet.

In July, Trump praised the crypto industry, declaring:

“You have certainly as an industry gone up more than anybody. Nobody’s gained the respect in such a short period of time.”

He went on to make an enormous promise to the industry he now greatly admires,

“Many Americans are unaware that behind the scenes, the technical backbone of the financial system is decades out of date[…] but payments and money transfers are costly and take days or even weeks to clear.

Under this bill, the entire ancient system will be eligible for a 21st-century upgrade using the state-of-the-art crypto technology[…]

This will increase demand for US treasuries, lower interest rates and secure the dollar’s status as the world’s reserve currency for generations to come.”

Trump also stated that he believes stablecoins help protect the dollar. He asserted that he is “not going to let the dollar slide,” because with a “smart president, you’re never going to let the dollar slide.”

When he gave that speech, the dollar had fallen 12% since he took office in January. After, it increased by 3% over the subsequent months.

Notably, when the dollar slid, Bitcoin soared. Now the dollar is recovering, and Bitcoin is in decline.

Can Trump have his dollar cake without eating crypto, too?

The Treasury initiated GENIUS Act processes on September 18 with an advance notice of proposed rulemaking that seeks input on how to license issuers, establish capital and liquidity requirements, and define bank-permissible activities.

The consultation window is the first step toward binding standards that would allow banks and payments firms to issue fully backed dollar stablecoins under federal oversight.

From banning CBDCs to rewiring the payments stack

The original promise was framed as upgrading an “ancient” stack without building a CBDC.

In an executive action signed Jan. 23, Trump created a CBDC ban, and bills to codify it have cleared the House but are not yet law. The policy direction is set, while statutory endpoints and detailed implementation are pending.

Supervision has shifted in a way that matters for banks seeking to integrate with crypto rails. This spring, the OCC, Federal Reserve, and FDIC withdrew earlier “ask permission first” guardrails and reopened custody, stablecoin, and payment DLT activities, which will reduce friction once the Treasury finalizes the standards.

The OCC also issued specific bulletins on bank activities related to digital assets, reestablishing permissible paths under review for safety and soundness. According to the OCC, clarity on permissible activities will sit alongside the GENIUS regime for issuers and payment stablecoin service intermediaries.

Throughput on public stablecoin rails is already substantial by on-chain measures, although a significant share is intra-exchange and automated, rather than point-of-sale spending. Industry research from McKinsey frames the stablecoin thesis as tokenized cash for settlement and treasury, not a consumer swipe replacement on day one.

According to McKinsey, distribution and last-mile integration drive real-economy impact once backing standards converge under rules like GENIUS. After reserves are standardized, competition shifts to who controls distribution between merchants, acquirers, and wallets.

Instant rails catch up to crypto speed

Legacy instant rails are not standing still. According to the Federal Reserve’s FedNow statistics, the network settled 2.5 million payments totaling $307 billion in the third quarter.

The private Real-Time Payments network processed $481 billion in the second quarter, with a single-day record of 1.81 million transactions and $5.2 billion on October 3. Swift states that 90% of cross-border payments now reach the destination bank within one hour on GPI, which narrows the speed gap that once separated public chains from correspondent banking.

The competitive wedge for crypto rails centers on 24/7 uptime, weekend and cross-border settlement, programmability, and capital efficiency at the treasury layer, rather than raw domestic speed.

The pipes that connect those advantages to everyday commerce are turning on. Visa has expanded stablecoin settlement support across more currencies and chains, and is extending this capability with additional acquirers.

Mastercard unveiled end-to-end capabilities to power stablecoin transactions from wallets to checkouts, and began regional settlement rollouts for USDC and EURC in corridors where cross-border friction is highest.

According to Visa Investor Relations and Mastercard, these integrations enable the movement of stablecoins into acquirer-ledgers and settlement files without altering the consumer checkout experience.

Pilots with fintech infrastructure providers, including those with Finastra and regional partners, demonstrate that operating rails are live in limited forms. Acquirer and PSP adoption can scale with more explicit rules on liability, capital, and reserve composition.

When the ‘replacement’ becomes measurable

Policy timing sets the boundary for when a “replacement” rail can be measured in production. Based on the administrative sequence, Treasury’s ANPRM in September is typically followed by a notice of proposed rulemaking in the subsequent quarters, then a final rule after a comment cycle.

According to the Treasury docket, the final GENIUS rules are scheduled for implementation in 2026, pending adherence to timelines. In parallel, banking agencies must set capital, liquidity, and supervision standards for PPSIs and for banks that hold reserves or intermediate stablecoin settlement.

Market-structure legislation, including the Digital Asset Market Clarity Act that passed the House in July, would clarify the treatment of exchanges and commodities versus securities, but has less direct impact on payments on day one.

Forward adoption will depend on whether card networks and acquirers shift their settlement to stablecoins, which can reduce costs or shorten the time. The realistic near-term path is replacement in settlement, not at the point of sale.

PSPs and acquirers can net merchant receivables in USDC or EURC on weekends or across borders, then utilize bank funds where they are cheaper or where policy requires it.

If that approach scales, the front end remains the same for consumers while the back end routes across multiple rails. According to Mastercard, multi-rail acceptance is already a program goal.

For banks, the revived OCC guidance means that reserve custody, tokenized cash activities, and payments DLT can be situated under existing risk frameworks once final rules define eligibility and oversight.

Stablecoins, Treasuries, and the dollar strategy behind GENIUS

The dollar strategy embedded in GENIUS relies on fully backed reserves held in Treasury bills and cash. If supply and distribution expand under federal licensing, the reserve base forms a recurring bid for short-dated U.S. government debt.

A larger stablecoin float channels demand into 1- to 3-month bills, thereby reinforcing dollar distribution abroad, provided that par convertibility and intraday liquidity are robust.

J.P. Morgan has published a conservative forecast around the scale of the market, while McKinsey and Standard Chartered outline larger end states. The range matters less than convertibility, audits, and narrow-banking-style safeguards that address bank supervisors’ concerns about the singleness of money, elasticity, and integrity.

There is a competing path where public stablecoins cap out and bank-led tokenized deposits take the lead. The Bank for International Settlements outlines a next-generation system built around tokenized deposits and unified ledgers anchored in central bank reserves.

Along this path, most real-economy flows utilize FedNow, RTP, and SWIFT GPI both domestically and cross-border, with tokenization integrated within bank balance sheets and wholesale platforms. Public stablecoins then remain a crypto-native rail with ring-fenced use.

The outcome hinges on how U.S. rules resolve bank access, capital, and liquidity, as well as how card and acquirer networks price weekend and foreign exchange corridors.

The early scorecard on Trump’s ‘replacement’ system

Near-term scorecards point to motion, not completion. Rules are in consultation, OCC and the Fed have softened posture on bank participation, SEC leadership has turned over, and the card networks are deploying.

Missing pieces are the final GENIUS regulations, coordinated bank capital and liquidity treatments for PPSIs and bank intermediaries, and scaled acquirer adoption inside the largest merchant processors.

Meanwhile, instant rails are compounding. According to FRB Services, FedNow value and volume are expanding quarter over quarter. RTP’s throughput and transaction limits have risen, which reduces the domestic gap crypto once exploited.

For readers tracking whether the replacement is genuine, watch metrics that test the settlement thesis rather than relying on consumer-facing anecdotes. The key dates to log are Treasury’s NPRM and final rule milestones, OCC and Fed capital and liquidity specifics, and acquirer dashboards that display the share of merchant settlements routed to stablecoins by corridor and day of the week.

Monitor the number of banks that hold stablecoin reserves and operate on- and off-ramps under OCC guidance. Compare stablecoin weekend and FX costs against Swift GPI routes at the corridor level. Track aggregate Treasury bill holdings by licensed issuers against auction sizes. These are the gauges that convert political promises into measurable payments infrastructure.

Rail	Recent datapoint	Source
FedNow	$307B settled in Q3 2025, 2.5M payments	FRB Services
RTP	$481B in Q2 2025, Oct. 3 record 1.81M tx / $5.2B	PYMNTS
Swift GPI	90% reach destination bank within one hour	Swift
Visa	Expanded stablecoin settlement support, more coins and chains	Visa IR
Mastercard	End-to-end stablecoin capabilities live in select regions	Mastercard
GENIUS rules	ANPRM opened Sept. 18, 2025	U.S. Treasury

In short, crypto is emerging as a settlement layer within multi-rail payments, while the consumer experience remains the same.

The real turning point occurs once GENIUS rules are finalized and acquirer adoption is reflected in measurable settlement flows.

Is Trump on track to deliver a true ‘replacement’?

So far, Trump has set a direction rather than built a finished system. The CBDC ban, the GENIUS framework, and a friendlier stance from the OCC and Fed toward bank participation all move U.S. policy toward crypto-based settlement rails.

Card networks and PSPs are wiring those rails into production, and banks are being told what “permissible” looks like. That is real progress toward a crypto-native settlement layer.

But a full replacement of legacy rails is nowhere near done (nor what Trump actually promised). FedNow, RTP, and Swift GPI are scaling in parallel, not being switched off. GENIUS standards are still under consultation, bank capital rules for PPSIs remain unresolved, and acquirer adoption is in early pilots rather than being system-wide mandates.

Even on an aggressive timeline, most of the heavy lifting, including final rules, bank balance-sheet treatment, and cross-border corridor build-out, will occur in 2026, and realization is likely to extend beyond his second term.

The most realistic outcome is not a clean swap of one system for another, but a multi-rail stack where stablecoins and tokenized deposits handle settlement in the background while cards and instant bank transfers remain the consumer touch points.

In that world, Trump can credibly argue that he pushed the system toward crypto rails and away from a CBDC, but the “replacement” he promised will look more like a gradually rewired back end than a flag day where legacy rails disappear.

So is he on track?

At this stage, he is on track to influence how the next-generation stack is wired, rather than entirely replacing legacy rails in a single term.

The scorecard today reads: policy momentum and live pilots, but no decisive break where the bulk of U.S. and global retail payments move onto crypto settlement.

Until bank capital and liquidity standards are finalized, and acquirer dashboards show stablecoins carrying a meaningful share of settlement, Trump’s replacement remains a thesis in progress, not a fully developed system.

Bitcoin rose 290% in the five months after the end of the last major US government shutdown. That 2019 move, from roughly $3,500 in late January to nearly $14,000 by June, now circulates as a template for what comes next.

The Senate advanced a deal to end the current 40-day shutdown, the longest on record, and Bitcoin trades around $105,000 as Washington prepares to reopen. Odds on Polymarket of the shutdown ending between Nov. 12 and 15 are at the all-time high of 87%.

Applying the 2019 playbook mechanically points to $400,000 or higher within six months. The problem is that 2019’s surge had almost nothing to do with the shutdown ending.

The rally emerged from an 80% bear-market bottom, rode the Federal Reserve’s pivot from hiking to easing, and unfolded in a market with no spot ETFs, minimal institutional custody, and leverage structures that resembled frontier equity markets more than macro asset classes.

The shutdown’s conclusion provided narrative symmetry, but the real drivers were capitulation, valuation reset, and monetary accommodation. Bitcoin ripped because it had nowhere to go but up, not because the government turned the lights back on.

In 2025, the setup inverts. Bitcoin reached an all-time high of $126,200 on Oct. 6, driven by spot ETF inflows and a pro-crypto policy environment.

Additionally, the shutdown fueled the rally, as it left data pieces unrevealed, leading investors to flee towards assets that could maintain their buying power, such as gold and Bitcoin.

However, the shutdown became the longest in US history, and started affecting a developing crypto regulatory agenda. This resulted in a 20% correction, but the drawdown started from record territory, not from a devastation floor.

The market now holds tens of billions of dollars in spot ETF assets, record corporate treasury positions, and a $73.6 billion crypto lending book, larger than the 2021 cycle peak and more than double the 2019 levels.

This is not a washed-out, underowned asset poised for reflexive melt-up. This is a trillion-dollar, institutionally intermediated market where basis trades, derivatives hedging, and profit-taking anchor price action as much as speculative momentum.

Why 2019 happened

The last shutdown ran from Dec. 22, 2018, to Jan. 25, 2019. Bitcoin entered that period trading in the $3,500 range after an 80% collapse from its late-2017 peak. Miners capitulated, weak hands exited, and leverage unwound.

By the time the government reopened, Bitcoin had formed a multi-year low with asymmetrically skewed upside: valuations were cheap, positioning was light, and the only sellers left were committed long-term holders.

The Federal Reserve provided the macro tailwind. In January and March 2019, Chair Jerome Powell shifted from a tightening stance to “patient,” signaling the end of rate hikes and the start of easier policy.

Markets read that pivot as a green light for risk assets, and Bitcoin benefited from lower real-rate expectations and a weaker dollar.

The crypto-specific backdrop reinforced the move, as institutional custody infrastructure was launched, derivatives markets matured, and the 2020 halving was approaching on the forward calendar.

Facebook’s Libra announcement in mid-2019 added a legitimacy narrative that pulled capital off the sidelines.

The shutdown’s end aligned with those forces but did not cause them. Bitcoin’s rally was a post-capitulation reflation trade that coincided with Washington’s reopening.

The narrative stuck because it was clean and symmetrical, with government dysfunction ending and risk appetite returning, which led to Bitcoin’s explosive growth. Yet, the mechanism was leverage reset and Fed accommodation, not fiscal policy normalization.

What changed between cycles

The November 2025 shutdown ends with Bitcoin above $100,000, not below $4,000. That valuation gap alone eliminates most of the asymmetry that made 2019’s rally possible.

There is meaningful overhead supply from ETF holders, corporate treasuries, miners who locked in forward sales during the rally, and retail participants sitting on unrealized gains.

Additionally, the market structure has become increasingly professionalized, with spot ETFs now dominating flows, derivatives volumes dwarfing spot, and the lending market expanding to a record size.

That depth improves liquidity and reduces volatility, but it also dampens the kind of violent, undercapitalized blow-offs that defined earlier cycles.

The macro backdrop diverges as well. In 2019, the Fed pivoted cleanly into easing with subdued inflation and no external shocks. In late 2025, inflation remains elevated, tariff policies introduce uncertainty, and the Fed faces constraints on how much further it can ease without risking price stability.

The shutdown itself compromised data transparency and delayed regulatory approvals, creating an overhang that will be alleviated when operations resume. But that release looks more like removing a negative impulse than adding a positive catalyst.

The risk-premium compression from reopening matters, but it does not replicate the dovish macro regime that turbocharged 2019.

Corporate and institutional behavior adds another constraint. In 2019, a few large holders took profits. In 2025, public companies, funds, and ETF sponsors manage billions in Bitcoin exposure.

Those entities optimize for risk-adjusted returns, rather than maximizing upside. They sell into strength, rebalance on volatility, and hedge via derivatives.

That professionalization stabilizes the market but caps reflexive moves. A 290% rally off $105,100 would require those actors to either hold or buy more aggressively than they did on the way to $126,000.

Furthermore, we are at a completely different point in the cycle than we were in 2019. We are still over 500 days away from the next halving in 2028, which typically indicates that winter is coming. In contrast, in 2019, the thaw was already on the horizon.

Neither assumption holds without a macro shock far larger than a shutdown ending.

The bullish case still exists

A government reopening removes uncertainty. Data releases resume, agency activity restarts, and regulatory processes for ETF approvals, exchange listings, and corporate actions proceed on schedule.

That clarity matters for institutional flows, which have been the marginal price setter since the launch of spot ETFs. If the shutdown’s end coincides with positive macroeconomic surprises, such as stronger growth, contained inflation, and further easing by the Fed, Bitcoin could experience a significant rally.

The pro-crypto policy environment remains intact, corporate adoption continues, and the halving supply shock is still working its way through the system.

The Oct. 10 washout cleared some leveraged longs. Positioning entering a reopening may be cleaner than it was at the October highs. If pent-up ETF demand and institutional flows return quickly, Bitcoin could grind higher toward new records.

The narrative reflex also matters, as the 290% projection from the last shutdown attracts speculative capital in the short term, even if the analogy is structurally weak. Traders love symmetry, and the story is clean enough to pull flows.

If 2019’s move repeats exactly, Bitcoin trades at $413,400 within six months, a 3.9x multiple from its current price of $105,100. That outcome requires institutional holders to buy more aggressively than they did during the run to $126,000, retail to re-enter at scale, and macro conditions to improve dramatically.

It also requires no meaningful profit-taking, no unwinding of leverage, and no external shocks. Those assumptions are heroic.

A more grounded framework scales down the 2019 effect. If the reopening catalyzes half of the relative move, Bitcoin will land near $260,000. If it delivers one-third of the impact, call it a 97% gain to just above $200,000.

Those scenarios assume the shutdown’s end acts as a reset of local sentiment, rather than the start of a multi-cycle reflation trade.

They also assume that institutional and corporate holders behave rationally, taking profits into strength, hedging against tail risk, and rebalancing exposure rather than chasing momentum.

The realistic question is not whether Bitcoin repeats 2019’s 290% move, but whether reopening marks a local macro low that allows a structurally driven leg higher fueled by ETF inflows, corporate adoption, and regulatory clarity, without the leverage excesses that defined earlier cycles.

Bitcoin does not need a government shutdown to rally. It needs demand to exceed supply at prevailing prices, and the shutdown’s end removes one impediment to that balance.

However, it does not recreate the capitulation, Fed pivot, and underowned market structure that made 2019’s surge possible.

The $400,000 scenario exists, but it is just very unlikely.

Behind every wild Bitcoin candle in 2025 is a quiet shift in collateral, basis, and ETF flows.

Funding rates, margin haircuts, and spot ETF hedging now have as much impact on the price as any macroeconomic headline.

Collateral settings across futures and lending venues influence the Bitcoin spot price through forced hedging and liquidations. The October shakeout put the link back in view, with approximately $19 billion of positions liquidated on October 10–11 as funding and basis compressed and then reset.

October’s shakeout in funding, collateral, and ETF flows

Since mid-September, exchanges have also adjusted funding formulas and collateral parameters, altering carry economics and liquidation thresholds for margin trading. The macro hurdle for carry has eased after the Federal Reserve’s late-October cut and a move in three-month bills toward about 3.8%.

ETF and ETP flows also fluctuated during October, shifting from record inflows to outflows and back, which in turn affects spot inventories and dealer hedging flows.

However, that October pattern has already reversed again: by early November, CoinShares data show digital asset funds experiencing renewed net outflows, led by nearly $1 billion out of Bitcoin ETFs, emphasizing how quickly ETF hedging flows can change direction.

The mechanism is straightforward. When the perpetual or futures premium widens, basis traders buy spot and short perps or listed futures to lock the spread. That pulls coins off exchanges, tightens resting liquidity, and lifts the cash print.

When funding turns negative and the basis compresses, the same books unwind by selling spot and covering short-perpetuals, which adds inventory to exchanges and puts pressure on the price. Funding is tied to the perp premium versus the underlying index and is settled at fixed intervals.

In late October, medium-term annualized basis on March BTC futures was running around 6–6.5%, a few hundred basis points above three-month bills.

How tighter basis, funding, and haircuts feed back into spot

That pickup has since compressed, with March basis now closer to the mid-5% area and only about 150–200 bps over bills, still enough to keep carry capital engaged as long as borrow costs are controlled and collateral haircuts remain unchanged.

Financing and haircuts determine how much leverage that spread can support. Borrow costs on DeFi remain low in places, with Aave v3 WBTC borrow near 0.2% and low utilization, according to Aavescan.

Centralized venues exhibit a wide dispersion in margin borrow rates for BTC and stablecoins, which can either erode or enhance net carry. Haircuts and portfolio margin settings then determine how far positions can extend before the maintenance margin is triggered.

A change in a collateral ratio or a funding clamp shifts the liquidation bands closer to or further from the spot, and venues have made such adjustments through September and October.

Liquidations and insurance funds serve as accelerants. Maintenance-margin math can force exits on small percentage moves at high leverage, and insurance funds absorb losses until thresholds are reached.

In a prior episode in 2023, dYdX tapped about $9 million from its v3 insurance fund to absorb losses in the YFI market, with balances remaining, illustrating how these buffers throttle, rather than remove, deleveraging pressure.

The Oct. 10–11 cascade demonstrated how perp leverage transmits to the cash market quickly as positions are forced out.

The liquidity backdrop: exchange reserves, depth, and carry capacity

On the other side of the book, exchange reserves and depth shape how these flows print. CryptoQuant’s dashboard shows Bitcoin exchange netflows at three-year extremes, with sustained outflows that have pushed exchange reserves to multi-year lows in October.

This reduction in the for-sale supply occurs when basis draws coins off-venue and then feeds back when the unwinding of that flow reverses.

Kaiko’s earlier depth study pegs 1% BTC market depth at about $500 million, a useful yardstick for how a $1 billion basis-driven spot bid could traverse multiple buckets intraday if passive liquidity steps back, according to Kaiko.

Capacity for the short leg of carry remains available on regulated venues, with CME reporting record crypto futures open interest and volumes as of late October.

Carry math helps frame participation. A simple delta-neutral template is: net carry equals annualized basis minus financing cost minus fees and slippage minus any borrow APR.

For example, with a 6.3% medium-term basis (roughly where March traded in late October) and a 3.8% bill rate, a cash-financed book yields roughly 2.5% before considering frictions. If a desk funds with an exchange stablecoin and borrows at 3–6%, the same spread can fall near zero or even go negative after fees.

For perps, eight-hour funding annualizes by multiplying by three, then by 365, so a 0.01% eight-hour rate works out to about 11% per year, according to ApeX.

How collateral, basis, and ETF flows now drive Bitcoin’s spot price

Haircuts map directly to leverage. If effective leverage scales with the sum of initial margin and the haircut applied to collateral, a 5–10 percentage point haircut increment can reduce usable leverage by roughly 10–20% and lift liquidation risk, forcing de-risking flows even without a price change.

ETP and ETF activity is the other valve. CoinShares reported $5.95 billion of inflows in the week ending October 4, followed by $513 million of outflows in the week of October 20, and then $921 million of inflows in the week of October 27, which altered dealer hedge requirements and the spot bid within days.

When those flows run positive while the basis is wide, carry desks compete with ETF creations to source coins, and exchange balances trend lower. When flows flip or funding turns negative, the unwind adds to reserves and pushes the price toward liquidation clusters.

Over the next month, three paths matter for spot.

• If the basis expands to 8–12% for several sessions, carry desks typically add long spot and short perps or CME, which drains exchange balances and can keep funding positive until new inventory arrives.
• If the basis compresses to 3% or less and ETF flows turn negative over several days, the unwind pushes spot supply back onto exchanges and concentrates pressure around maintenance-margin bands.
• A haircut or portfolio-margin update can produce faster de-risking, even without a macroeconomic shift, since collateral value falls, effective leverage drops, and the same price range triggers liquidations.

These outcomes depend on where the spread sits relative to the bill rate, the cost of borrowing, and the direction of ETF flows.

Three real-time gauges for Bitcoin’s next move

For real-time context, watch three gauges.

1. An annualized basis above 8% on medium tenors for more than a day or two often attracts new carry demand.
2. A broad patch of negative funding across major perps on the CoinGlass heatmap lines up with spot selling and reserve rebuilds as basis books unwind.
3. Support-center posts on collateral ratios or portfolio margin changes provide early warnings of leverage clamps.

The practical takeaway is that options are not required to push the cash market around when basis, funding, borrow, and haircuts reset together. With a basis now around 5–5.5% over bills, the carry door remains open but is more sensitive to shifts in collateral demand and borrowing costs.

XRP jumped roughly 12% in the past 24 hours to around $2.52 after the Depository Trust & Clearing Corporation (DTCC) added five spot XRP ETFs to its “active and pre-launch” list.

These listings, visible on DTCC’s public database, have sparked speculation that the long-anticipated exchange-traded products for XRP are moving closer to launch, following the model set earlier this year by Bitcoin and Ethereum ETFs.

Why the DTCC listing matters, but doesn’t mean launch yet

The DTCC listing is a major milestone. The corporation is the core settlement and clearing utility for US securities markets, processing over $3.7 quadrillion in transactions in 2024.

Every ETF that trades on a US exchange must be registered through DTCC, making it the central node where Wall Street connects to digital assets.

However, it’s essential to note that inclusion on the DTCC site doesn’t imply that the funds are approved or ready to trade.

It signals that issuers and their custodians have completed the preparatory legwork, including creating tickers, CUSIPs, and back-end infrastructure, while awaiting approval from the SEC.

This is an important distinction. When spot Bitcoin ETFs first appeared on DTCC’s site in late 2023, markets reacted immediately, pushing BTC higher even before the products went live.

What an XRP ETF could mean for market structure and access

The same pattern repeated with Ethereum ETFs, which were listed weeks ahead of their June approval.

The XRP case follows a similar playbook: early infrastructure setup, speculative enthusiasm, and then a waiting game for regulatory approval.

If the SEC approves these funds, they would open new institutional channels to XRP exposure. Traditional brokers and asset managers could route liquidity through familiar ETF vehicles instead of navigating crypto exchanges.

This shift could reduce friction for retirement accounts and mutual fund allocators, who are typically barred from buying crypto directly.

It would also cement XRP’s status as a regulated investment product, expanding its market depth and linking it more tightly to the US financial system.

Regulatory roadblocks between listing and launch

However, several hurdles remain for XRP. The SEC has yet to formally rule on any XRP ETF filing, and no public 19b-4 submissions or S-1 forms have been cleared for trading. The DTCC listing alone doesn’t imply endorsement, as some entries on the database never progress to launch.

What it does confirm is that issuers are preparing in parallel, betting on eventual regulatory clarity following Ripple’s partial court victory last year, which classified programmatic XRP sales as non-securities.

The price reaction shows how sensitive markets remain to even small steps in institutional integration. After weeks of muted trading, XRP broke to a higher high on the hourly chart, extending gains that began earlier in the week.

The move is a breakout from consolidation, fueled by the ETF headline. Whether those gains hold will depend less on DTCC’s database and more on whether the SEC allows these products to cross from pre-launch status to live trading.

If and when that happens, XRP’s market structure could shift. ETF inflows would add a layer of demand independent of spot exchange flows, thereby smoothing volatility and linking XRP performance more closely to fund creations and redemptions.

For issuers, it’s a chance to capture yield from the asset’s liquidity and attract the same kind of institutional capital that has reshaped Bitcoin’s trading ecosystem.

The market is now waiting for the next milestone: the day the “pre-launch” label is removed and replaced with “live”. Until then, the DTCC listings remain a promise that the market is already starting to price in.

AsiaStrategy said Sora Ventures CEO Jason Fang is now its largest shareholder following a change to the ownership of its major shareholder, Pride River Limited.

According to a company statement dated Nov. 10, Pride River’s cap table will shift under an agreement signed Nov. 7. It will move from 70% held by Mr. Ngai Kwan and 30% by Sora Vision Limited to 49% held by Mr. Ngai, 30% by Sora Vision Limited, and 21% by Sora Ventures II Master Fund.

As Sora Vision Limited and Sora Ventures II Master Fund are aligned with Fang, he holds the largest effective interest in AsiaStrategy.

The company stated that the update does not alter management, operations, or strategy. AsiaStrategy added that it has purchased Bitcoin gift cards to reward VIP watch customers as it explores links between its luxury watch business and its Bitcoin initiatives.

Pride River Limited ownership	Before	After (pending consummation)
Mr. Ngai Kwan	70%	49%
Sora Vision Limited	30%	30%
Sora Ventures II Master Fund	—	21%

AsiaStrategy, which trades on Nasdaq under the ticker SORA, pivoted in 2025 from its legacy watch distribution business to a listed Bitcoin treasury and institutional strategy vehicle in Asia.

The transition followed a merger path involving Top Win, the former listed entity, and Sora Ventures, with the ticker change to SORA and Fang’s appointment as board chairman forming part of the shift to Bitcoin-focused corporate strategy.

Those steps were detailed when Top Win announced plans to rebrand to AsiaStrategy and when the company confirmed the ticker change and leadership updates through the spring of 2025.

The firm later framed a cross-border execution stack connecting U.S. and Asian market rails, naming Anchorage Digital as custodian and settlement partner. It disclosed an initial 30 BTC on the balance sheet with plans to scale the treasury over time.

AsiaStrategy also described an ambition to build a large regional Bitcoin position as part of an Asia-facing version of the corporate treasury thesis popularized by U.S. peers.

On the operational side, the company linked consumer activity to its treasury model by enabling Bitcoin payments for luxury watch sales, thereby aligning retail flows with long-term accumulation goals.

That capability followed a $10 million convertible investment from Taiwan-based WiseLink in August 2025, which provided additional capital flexibility during the pivot. The company has since continued to reference cross-border institutional strategy as its core mandate, while maintaining the legacy watch business as a channel through which customer rewards and payments can integrate with Bitcoin initiatives.

AsiaStrategy has also been cited in regional corporate efforts to expand Bitcoin treasury adoption. In May 2025, the company outlined strategic investments in Asian Bitcoin sector names, including exposure to Metaplanet and Moon Inc, and positioned itself as an Asia-focused public vehicle for treasury and corporate participation in the asset class.

The firm’s network has intersected with consortium activity pursuing market entries in Southeast Asia, including moves tied to Thailand that involved related parties across Sora Ventures and Metaplanet entities.

The shareholding update focuses on maintaining effective control around Fang-aligned entities without altering the stated plan. For a listed vehicle that utilizes a qualified U.S. custodian for settlement and storage, governance alignment can impact capital deployment pace, risk settings, and deal flow in markets where regulatory and banking access vary by venue.

AsiaStrategy has repeatedly emphasized the value of combining U.S. infrastructure and Asian distribution, and the firm’s watch business offers a consumer-facing on-ramp that can integrate with corporate treasury operations through controlled procurement and reward structures. The announcement that Bitcoin gift cards will be used for VIP customers is an example of that bridge between retail and treasury.

Market participants tracking public company Bitcoin treasuries will watch for subsequent filings that reflect any changes once the Pride River transaction closes. AsiaStrategy previously disclosed a starting point of 30 BTC and a plan to scale, with Anchorage Digital serving as the settlement and custody provider.

Additional capital instruments, including convertibles and cross-border syndicates, have been part of the playbook described this year, alongside direct investments in regional Bitcoin-linked companies. Execution against that playbook, if accompanied by concentrated governance, could affect the speed at which the firm adds Bitcoin or deploys into equity positions tied to the asset.

AsiaStrategy stated that the shareholding changes are pending the consummation of the agreement signed on November 7. The company reiterated that its management team and strategic direction remain unchanged, and that it has begun rewarding VIP watch customers with Bitcoin gift cards.

Disclaimer: Sora Ventures is an investor in CryptoSlate.

In crypto, MEV typically refers to bots and searchers on chains like Ethereum reordering, inserting, or censoring transactions around DEX trades and liquidations to extract value from users in the form of worse prices, failed transactions, and higher costs.

However, did you know that Bitcoin also has MEV-like dynamics at the mempool and policy layer? It’s akin to its own quiet version of MEV, without DeFi-style bots front-running swaps. Instead, miners and pools use fee signals, mempool policies, and block templates to determine which transactions clear first.

Bitcoin Core v28 turned full replace-by-fee mempool policy on by default (mempoolfullrbf=1) and added limited 1-parent-1-child package relay. Miners and pools that run Core or compatible software inherit these defaults, but they can still choose alternative policies.

Yet, the public mempool is only part of the auction that determines which transactions are cleared in the next block, as out-of-band routes to pools and wallet-level fee controls also play a role.

Within the Bitcoin network, miners and pools are effectively the decision-makers. They ultimately decide which consensus-valid transactions are included in blocks, based on the mempool and policy settings they use.

Bottom line: Bitcoin has a soft form of MEV for everyday users. Small fee changes, package construction (parent + child), and direct-to-pool paths can nudge your transaction ahead of others, even when they were broadcast first.

When a miner assembles a block template, transactions are effectively selected in this rough order:

• Transactions or packages they have seen and verified as consensus-valid.
• Packages with the highest effective fee rate when ancestors and children are combined.
• Replacements that pay more than conflicting transactions under BIP125.
• Any out‑of‑band deals or pool‑level policy filters that override the pure fee rate.

In practice, this is how miners quietly decide which transactions ‘win’ the next block.

Compared with Ethereum and DeFi MEV, where searchers run arbitrage, sandwich, and liquidation bots to extract value from smart‑contract interactions, Bitcoin’s “soft MEV” is quiet.

There is no front-running of DEX swaps or liquidation auctions; instead, miners and pools adjust their ordering via fee-based incentives, package selection, and occasional off-chain payments. That contrast is why this MEV is far less visible to the average user.

How miners pick winners in your mempool

Recent fee and mempool data frame why small ordering edges matter. According to YCharts, the average on-chain fee stands at $0.68, down from the previous year.

Hourly windows in October showed bursts and near-empty gaps on mempool.space’s block fee rate view, creating periods where a minor absolute fee delta can move a transaction to the top of a template.

According to Hedge With Crypto, fees fell to about 0.96% of block rewards in June 2025, the lowest share since January 2022. According to BitInfoCharts, hashrate sits around 1.1 zettahash per second, keeping competition steady for any incremental advantage in template yield.

With ancestor-feerate mining and package relay, the practical fee auction is increasingly package-based rather than naively per-transaction.

Since Bitcoin Core’s ancestor-feerate mining (PR #7600), block templates consider the combined ancestor and descendant package feerate. That’s why CPFP lets a low-fee parent plus a high-fee child beat an isolated high-fee transaction.

This is why child-pays-for-parent routinely pulls stuck parents into a block when the combined package clears the miner threshold.

According to No Bullshit Bitcoin’s v28 release recap, default full RBF means any unconfirmed transaction can be replaced by a higher-fee version that pays more than all conflicts and the bandwidth increment set by BIP125.

The same release also introduced opportunistic 1-parent, 1-child package relay and made TRUC (version 3) transactions and P2A outputs the standard by default, along with a limited form of package RBF.

Later Core versions (v29+) maintain full-RBF as the default mempool policy and continue to evolve package relay.

Out-of-band fee lanes, policy filters, and soft MEV

Out-of-band payment rails widen the gap between public mempool order and what gets mined. ViaBTC’s accelerator submits transactions directly to the pool, a path that can elevate a transaction with a lower in-band fee rate because the missing fee is paid off-chain.

These arrangements can skew template selection and reduce transparency when they occur frequently, as the on-chain feerate alone no longer explains inclusion.

Miningpool.observer publishes template and block pairs, highlighting missing or extra transactions and conflicts, which provides public evidence of inclusion choices that did not align with a simple max-feerate view.

Policy filters, which govern relay but not consensus validity, are a second lever that affects which transactions reach miners on time. Standardness policies are not consensus rules; miners can include any consensus-valid transaction even if relay nodes drop it.

The recent OP_RETURN change illustrates how defaults shape propagation. Developers merged a shift in the v30 cycle, removing the long-standing ~80-byte default limit for OP_RETURN in policy, raising the default data carrier size, and later tweaking how node operators can configure it.

Soft MEV in Bitcoin’s long-run fee economy

Public episodes also illustrate discretionary filtering at the pool layer. OCEAN chose to filter inscription-style data, and Marathon’s 2021 OFAC-compliant experiment showed template selection can deviate from a pure max-fee ranking when pools pursue policy or public relations goals.

The rules governing replacements and packages establish the practical limits of priority. BIP125 requires a replacement to pay a higher absolute fee than all conflicts and also cover a minimal incremental relay fee.

Yet, RBF rules (including BIP125) are mempool policy, not consensus. Miners can always mine any consensus-valid replacement they see first.

Wallets that fee bump often aim to leap to the next block’s fee rate bucket with a material increase to avoid repeated churn, a heuristic rather than a rule. CPFP remains a direct way to source a fee when a parent is stuck, and a 1-parent, 1-child relay in v28 raises the probability that a fee-sponsoring child arrives in peer mempools quickly enough to change the following template.

According to the opt-in RBF FAQ, zero-confirmation acceptance remains a risk that grows when full RBF is widely deployed, since there is no global first seen, and asynchronous relay means replacements can reach a miner before the original reaches that miner’s template builder.

What this means for everyday users

From your perspective as a wallet user, tiny decisions in how you set fees or structure transactions can quietly move you up or down the miner’s queue.

Queue-jumping via RBF is commonplace: a higher-fee replacement can overtake earlier broadcasts. CPFP allows you to sponsor a stuck parent by paying from a child, thereby raising the package’s effective fee rate. Direct-to-pool accelerators act as an emergency lane when public mempools are congested.

In practice, small fee deltas and package construction are the “soft MEV” edges that decide who clears first.

Consider two similar transactions: Alice sends a payment with a modest fee while Bob uses RBF to bump his fee by a few sats/vB. Even if Alice broadcasts first, Bob’s higher replacement can leapfrog into the next block under BIP125.

Or imagine a stuck parent transaction rescued by a child; if you attach a child with a high fee, the combined package often wins inclusion sooner than a single high‑fee transaction with no dependencies.

Likewise, a transaction with a low on‑chain fee rate can still win if you use a pool accelerator to pay the fee out‑of‑band.

Template visibility is improving, which narrows the information gap on soft ordering choices. Bitcoin Optech noted work on cluster mempool heuristics that detect feerate increases in block templates and covered proposals for nodes to share templates, allowing peers to compare what miners plan to include.

These ideas aim to make deviations from fee maximization easier to spot, whether due to OOB compensation, policy filters, or simple latency.

The forward path depends on fee levels and burst frequency, and the incentives scale as the block subsidy shrinks below 3.125 BTC over future halvings.

If average fees remain around $1–$2 and fee share holds near low single digits, most soft MEV activity will come from modest RBF bumps and CPFP around anchors, with OOB used as an emergency lane.

If bursts recur around inscriptions, headlines, or a looser OP_RETURN policy environment, average fees can jump into higher brackets for short windows. Fee share can reach the high single digits on spike days, and out-of-band paths and package bidding will become more apparent in template and block diffs.

If a sustained high-fee regime emerged and fee share trended higher, theory from Carlsten et al. on time-bandit incentives becomes more relevant, although Bitcoin’s large hashrate and pool structures temper execution in practice.

The mechanics remain straightforward. Miners build templates using ancestor-aware scoring, wallets, and service source fees, with RBF and CPFP as specified in BIP125. Package relay was introduced in Core v28 onward, and OOB lanes provide pools with a direct channel for priority.

That’s the quiet MEV of Bitcoin: miners and pools don’t front‑run your swaps, but they do quietly pick winners in your mempool using fees, packages and side channels.