Weekly Newsletter, 3 October 2025

Will every company have a token?

One eye-catching announcement this week came from SWIFT: the messaging layer that moves over $150 trillion across 11,000+ banks is building a blockchain-based shared ledger into its infrastructure. The goal is to enable real-time, 24/7 cross-border payments, without giving up on trust or compliance. It’s a notable step from one of TradFi’s most entrenched institutions, and they’re working with our blockchain-native portfolio company Consensys on the first prototype. Clearly another signal that traditional and blockchain finance are converging.

But perhaps the more important story of the week flew under the radar: the SEC issued a No Action letter to DoubleZero, a core blockchain infrastructure project that uses a token to coordinate activity within its network. A No Action letter means the SEC will not pursue enforcement if the project operates as described as the token will not be considered a security. This is a breakthrough development as it clears the way for projects to get clarity before launching their token.

The reasoning is important: tokens distributed for activity in a network are functional incentives, not investment contracts. They compensate for work performed rather than raising capital with an expectation of profit, so the Howey Test, which is used to determine if something is a security, is not met.

This is another very strong signal that the use of tokens is allowed under the new SEC, and in a fairly broad sense. We may be moving to a world where every company has a token, much quicker than anyone expected.

Also this week

Relevant financial updates

Anoma*, a distributed operating system for intent-centric applications that unifies underlying blockchains into a single development environment, had its TGE and is now trading at a $1.05bln FDV
DoubleZero*, a high-performance global network that reduces latency and increases bandwidth, had its TGE and is now trading at a $5.15bln FDV
Flying Tulip*, an onchain exchange offering spot trading, perpetuals, lending, options, and structured yield, has raised $200mln in a Seed funding round with investments from CoinFund, DWF Labs, Lemniscap, Hypersphere Ventures, Nascent and 8 others, valuing the company at $1bln
Talus*, an AI network that enables developers to launch revenue-generating agents, has raised $10mln in a funding round with investments from Polychain Capital, Foresight Ventures, dao5, Inception Capital, Sui Foundation and 2 others.
xMoney (formerly Utrust), a centralized custodial platform for businesses to accept payments in cryptocurrency and settle the transactions as stablecoins or fiat currency in a bank account, has raised $21.50mln in a Strategic funding round from the Sui Foundation
KGeN*, a company focused on creating micro-gaming communities in emerging markets and integrating them with blockchain technology, has raised $13.50mln in a funding round with investments from Jump Crypto, Accel and Prosus Ventures.
Lava, a financial services platform that enables users to save in bitcoin and spend in dollars securely and simply, has raised $17.50mln in an Extended Series A funding round with investments from 9 business angels
Lighter*, an extremely fast decentralized perpetuals exchange, has raised an undisclosed amount in a funding round with investments from Dragonfly, Founders Fund, and Haun Ventures

*Underlying TBV portfolio position | Prices as per 03/10

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