When the US Treasury Secretary and the UK Chancellor appear together in London to announce a joint initiative on digital assets, markets take notice. The launch of the Transatlantic Taskforce for Markets of the Future, unveiled December 2025 by US Treasury Secretary Scott Bessent and UK Chancellor Rachel Reeves, signals a decisive shift in how the world’s two most influential financial centres intend to shape the next phase of global market infrastructure. The taskforce, operating under the long-standing UK-US Financial Regulatory Working Group, aims to deliver its first recommendations within 180 days. Its remit is both ambitious and pragmatic: align oversight of digital assets, reduce cross-border frictions in capital markets and reconcile regulatory approaches that have increasingly diverged since the post-crisis era. At stake is more than crypto policy; New York and London are effectively asserting that they intend to remain the rule-setters for global finance as markets migrate toward tokenisation, programmable money and always-on settlement.
By late 2025, digital assets have moved from the periphery of finance into its operational core. Stablecoins are approaching systemic scale, tokenised funds are being issued by the world’s largest asset managers and wholesale market experiments are migrating into production environments. Yet regulation has often struggled to keep pace. The result has been fragmentation: firms operating across jurisdictions face overlapping and sometimes conflicting requirements around custody, disclosures, market abuse and consumer protection. The taskforce’s agenda directly targets these fault lines by accelerating regulatory alignment on stablecoins, tokenisation and wholesale infrastructure. It also seeks to ease cross-border fundraising, particularly for digital-native issuance, whilst harmonising disclosures to reduce duplicative compliance burdens. If successful, the initiative could become the most consequential regulatory coordination effort in digital finance to date. Certainly, this move is timely as major European economies have pivoted toward more aggressive pro-market reforms and a renewed push for a European Capital Markets Union, therefore putting pressure on the Anglo-American axis to maintain its competitive edge. Stablecoins sit at the centre of the transatlantic agenda because they now intersect with payments, capital markets and monetary policy. In the US, the legislative landscape shifted dramatically in 2025 with the passing of the GENIUS Act, which established a formal regulatory framework for dollar-backed stablecoins. This legislation allowed regulated issuers to operate under federal supervision whilst reinforcing the dollar’s dominance in digital commerce. In the UK, the Financial Services and Markets Act 2023 has been bolstered by the Property (digital assets, etc) Act 2025, which provides clear legal status for digital assets as personal property. And this legal certainty is the bedrock upon which Rachel Reeves is building a regime designed to make the UK a “global destination” for digital finance.· Case study: Circle and the USDC evolution
The philosophical divergence between the US and UK is narrowing as both jurisdictions converge on key principles: high-quality reserve backing, clear redemption rights, segregation of client assets and robust operational resilience. This matters for issuers such as Circle, whose USDC stablecoin operates globally. Circle has already secured status as a regulated e-money token issuer under the EU’s MiCA framework but without the transatlantic alignment promised by the Bessent-Reeves taskforce, then issuers risk building bespoke, expensive compliance stacks for each major market. By harmonising standards, the taskforce ensures that a stablecoin regulated in London can more easily interface with the US financial system without redundant vetting. Moreover, tokenisation (once dismissed as a mere efficiency experiment) is now being deployed at scale by mainstream institutions. The shift is visible in the explosive growth of real world assets (RWAs) on-chain, where traditional securities are wrapped in digital formats to allow for 24/7 trading and fractional ownership.
· Case study: BlackRock’s BUIDL Fund
BlackRock’s USD Institutional Digital Liquidity Fund (BUIDL), a tokenised money market vehicle launched on the Ethereum and Avalanche blockchains, serves as the definitive case study for this transition. By mid-2025, the fund had already tripled in size, capturing nearly 40% of the tokenised US Treasury market. BlackRock’s success, achieved in partnership with Securitize, demonstrated that institutional investors are hungry for regulated, high-yield cash instruments on public blockchains. London and New York now face a strategic choice: either allow tokenised markets to fragment across jurisdictions or jointly define the rules of the road. The taskforce’s focus on wholesale infrastructure suggests regulators recognise tokenisation’s systemic implications. The UK’s Digital Securities Sandbox and the Bank of England’s experiments with “moving central bank money on-chain” offer early models for how this might work at a sovereign level. However, it is not only asset managers who are moving on-chain: the global banks providing the underlying plumbing are also transforming. The shift from ‘testing’ to ‘operating’ is evidenced by the rebranding and expansion of major bank platforms.
· Case study: JP Morgan Kinexys
JP Morgan’s evolution of its Onyx platform into Kinexys marks a significant milestone in 2025. Kinexys provides the infrastructure for “atomic settlement” where the exchange of cash and collateral happens simultaneously - this eliminates the multi-day settlement risks inherent in traditional finance. Through the Tokenized Collateral Network, JP Morgan has enabled clients to use tokenised money market fund shares as collateral in repo transactions, settled in minutes rather than days. This case study highlights why the Bessent-Reeves taskforce is prioritising “always-on” settlement: if the world’s largest bank is already running billions in daily volume through these rails, the regulators must ensure those rails are cross-border compatible.
Perhaps the most delicate task for the 180-day mandate is reconciling the regulatory philosophies of the US Securities and Exchange Commission (SEC) and the UK Financial Conduct Authority (FCA). Historically, the SEC has emphasised enforcement through litigation, applying decades-old securities law to new technology. The FCA, by contrast, has leaned toward an “ex-ante” approach, using sandboxes and explicit regime design to provide clarity before products launch. The taskforce does not imply an institutional merger or the creation of a harmonised law - rather, it aims to reduce uncertainty where firms operate across both regimes. Disclosure expectations, market-abuse surveillance, custody standards and governance frameworks are all prime candidates for convergence. For global firms such as Coinbase, which holds FCA registration in the UK whilst navigating a complex regulatory landscape in the US, this alignment could significantly lower the cost of doing business across the Atlantic. Furthermore, one of the taskforce’s less publicised but potentially most impactful goals is easing cross-border capital raising. Tokenisation promises near-instant issuance and global distribution but regulatory divergence has constrained these benefits. Differing prospectus rules and investor classification thresholds often limit secondary liquidity to a single jurisdiction.
· Case study: Hamilton Lane and private credit
Asset management firm, Hamilton Lane, has been a pioneer in using tokenisation to broaden access to private markets. In 2025, it expanded access to its Senior Credit Opportunities Fund (SCOPE) via the Sei Network, using KAIO’s institutional-grade infrastructure. This allows for monthly liquidity and lower investment minimums in a sector (private credit) that was previously the exclusive domain of large institutions. However, the firm’s 2025 Market Overview noted that whilst technology allows for global access, “jurisdictional barriers” remain the primary friction. If the US and UK can align disclosure and investor-protection standards, tokenised funds could become meaningfully more tradable across the Atlantic, unlocking a massive pool of liquidity for mid-sized firms.
In essence, the Transatlantic Taskforce is more than simply another working group; it is an attempt to hard‑code the “special relationship” into the next generation of market plumbing. If New York and London can align on stablecoins, tokenisation and always‑on settlement, they will not merely tidy up regulatory frictions - they will choose which forms of programmable money achieve true reserve‑asset status and which remain peripheral. However, for policymakers, the risk is complacency: a half‑finished framework could simply export today’s fragmentation into code. And for investors, the challenge is to recognise that the real contest is no longer over individual tokens or platforms, but over whose legal and institutional standards become the default for digital collateral, liquidity and price discovery. The axis that wins that contest will shape global finance for decades.
This article first appeared in Digital Bytes (6th of January, 2026), a weekly newsletter by Jonny Fry of Team Blockchain.