Understanding the SEC: From "Project Crypto" to "Peanut Butter and Watermelon"

8/21/2025, 11:03:38 AM
Intermediate
Blockchain
The article explores the key elements and goals of U.S. regulatory policies. It also compares the regulatory frameworks of other regions. Readers gain a comparative, global perspective on cryptocurrency regulation.

Just five days apart, two landmark speeches have realigned the direction of U.S. crypto finance.

On July 31, SEC Chair Paul S. Atkins launched “Project Crypto,” formally embedding the goal of “moving the entire U.S. capital markets on-chain” into the regulatory agenda.

Then, on August 4, Commissioner Hester M. Peirce tackled the redefinition of financial privacy and regulatory principles at UC Berkeley’s “Peanut Butter & Watermelon.”

Viewed together, these moments reveal that the U.S. is advancing not only by clarifying rules to make capital markets more competitive but also by redefining core rights to attract top talent.

Two Landmark Speeches

Atkins’ “Project Crypto” is a bold declaration of structural reform at the market level.

He traced the thread from the NYSE’s historic Buttonwood Agreement to the rise of Alternative Trading Systems (ATS), anchoring his vision in the present: moving all of America’s asset issuance, custody, and trading on-chain.

The initiative centers on three main points:

First, it aims to solve the longstanding “is it a security?” dilemma with clear, actionable standards, carving out specific regulatory lanes for different tokens—digital commodities, stablecoins, and yield-bearing security tokens.

Second, it proposes modernizing custody rules, while asserting that “self-custody is a core American value,” and would include on-chain activities like staking as compliant investment options.

Third, it introduces the concept of regulating a “super-app”—a single, regulated platform that can simultaneously handle securities and non-securities digital assets, thus minimizing inefficiencies caused by fragmented oversight.

Atkins repeatedly underscored the importance of “bringing businesses and teams back onshore to the U.S.,” and he positioned Project Crypto alongside the President’s Working Group (PWG) and recent federal stablecoin legislation.

In contrast, Peirce’s “Peanut Butter & Watermelon” was a framework for reimagining financial privacy at the level of the social contract in the digital era.

She dissected the third-party doctrine and BSA/AML reporting, highlighting a crucial error: copying large-scale bank surveillance and pasting it blindly onto peer-to-peer crypto networks.

As technology reduces the need for intermediaries, rights boundaries must evolve too; otherwise, compliance becomes a “report anything you can” exercise—raising costs without necessarily improving outcomes.

Peirce cited landmark cases and data to show that in digital environments, the privacy-regulation boundary must be redrawn, and she opposed the default addition of ordinary users and developers to the surveillance chain.

While recognizing the necessity of preventing crime, she insisted on proportionality, targeted enforcement, and made the case for the legitimacy of privacy-enhancing technologies.

Profile of the Leaders

Atkins is best described as a “market structure engineer.”

He was an SEC commissioner from 2002 to 2008, served as Non-Executive Chairman of BATS Global Markets from 2012 to 2015, and led his own compliance and market structure consultancy, Patomak, until being appointed the 34th SEC Chair in April 2025.

His public track record demonstrates an unwavering focus on “promoting competition” and “eliminating redundant regulation”—which is why “Project Crypto” reads like a blueprint that integrates exchanges, brokers, clearing, custody, and on-chain settlement into a cohesive system.

Peirce, often called “Crypto Mom,” is even more notable for her “dual vantage point” from both inside and outside the system.

Serving as SEC Commissioner since 2018, she previously conducted research at the Mercatus Center, served as senior counsel to the Senate Banking Committee, and earlier was a lawyer in the SEC’s Investment Management Division—including as legal counsel to Atkins.

This background lets her grasp both legislative boundaries and enforcement realities, while framing updates as matters of legal theory, not just regulation.

These experiences—and Atkins’s trust in her—led to her appointment as head of the SEC’s Crypto Task Force.

Capital and Talent: Twin Engines

If American competitiveness is charted on two axes—capital market appeal and talent attraction—these speeches each move one axis, converging for a compounding effect.

Atkins pinpoints capital market appeal as: definitive token classification, parallel tracks for custody and self-custody, unified trading venues and cross-category compatibility, and compliance for on-chain settlements.

All of these directly enhance the efficiency of “issuance–trading–clearing–custody,” unleashing on-chain liquidity for U.S. dollar assets.

Peirce’s vision for talent attraction is rooted in first principles: financial privacy is part of civil rights and should not be “silently relinquished” with technological change.

While regulation requires auditability and accountability, it must never come at the expense of basic freedoms.

In other words, Atkins lays the tracks, while Peirce makes people want to board the train.


Global Regulatory Comparison

Global competition today isn’t about whether to regulate, but whose rules operate like a “computable, composable operating system.”

Europe’s MiCA, live in 2024, established two main stablecoin classes (ART and EMT) and set uniform standards for whitepaper obligations, capital, reserves, disclosures, and redemption timelines—enabling cross-border “passporting.” The system excels at “trading licenses for certainty,” but continues to define DeFi interaction through service providers.

The UAE’s dual track—Dubai VARA’s 2023 “Virtual Asset and Related Activities Regulation” and Abu Dhabi ADGM’s fiat-referenced token framework—stands out for “high transparency and rapid iteration,” offering a checklist approach to licensing exchanges, custodians, and issuers. Their method builds the business pipeline first, tweaking via new guidelines along the way.

Hong Kong’s new “Stablecoin Regulation,” effective August 1, 2025, places fiat-referenced stablecoin issuance under licensing, led by the HKMA, prioritizing stablecoins as the entry point to a broader token market. Its strength is clear legal hierarchy and lead regulator, but its ability to accommodate public-chain-native applications and cross-border collaboration still needs to be observed.

Singapore’s MAS finalized its stablecoin framework in 2023—requiring 100% high-quality reserves, five-day redemption, independent audits, and capital requirements. Japan’s amended Payment Services Act, also in 2023, treats yen stablecoins as “monetary assets,” restricts issuance to banks, trusts, and funds transfer firms. Korea’s draft Digital Asset Basic Act emphasizes bankruptcy segregation, reserve custody, and audits.

The commonality: payment stablecoins come first to make money programmable, then tokenized securities and real-world assets follow.

The U.S. first-principles story unfolds on two interlocking fronts.

First, the money layer: On July 18, Trump signed the GENIUS Act, giving payment stablecoins a federal home, mandating 1:1 high-liquidity reserves, periodic disclosure, and “super-priority” bankruptcy protection. From payment and settlement to safeguarding funds and qualifying issuers (bank/federal non-bank), it unifies the treatment of programmable dollars for the first time.

Second, the rights layer: Peirce isn’t just advocating for “light-touch” oversight—she puts the real-world effects of the third-party doctrine and BSA on the table, arguing for “proportionality plus precision enforcement” in place of one-size-fits-all surveillance—a return to privacy as a basic right.

Unlike Europe’s license focus, the Middle East’s business-list regime, and Asia’s payments-led model, the U.S. seeks to set “rights and market structure” as twin pillars. That’s what gives developers and entrepreneurs real long-term confidence.


Go-to-Market Strategy

Drawing on over fifteen years’ experience in U.S. and global financial and fintech sectors, here are focused strategic recommendations for Chinese capital and Web3/RWA enterprises:

First: Layer your strategy.

Near-term, use Hong Kong, Singapore, the UAE, and Europe as regulatory and growth staging grounds. But the U.S. must be your long-term high ground; planning and positioning start now.

The U.S. represents the deepest profit pool, valuation anchor, and global norm setter—avoidance guarantees a permanent valuation discount.

Entry barriers are not just about cost, but about respect for first principles: products must be designed for privacy by default; compliance must be auditable and accountable.

Second: Build on both product and licensing fronts.

The GENIUS Act’s federal framework for payment stablecoins means that dollar-backed on-chain cash and short-term funds will become standard for B2B, cross-border settlement, and on-chain finance.

For stablecoin, RWA, and brokerage infrastructure companies, the priority is to make reserves, redemption processes, independent audit, and bankruptcy segregation compliant with U.S. regulations, while practicing operational KPIs and risk controls with real funds and clients in Singapore, the UAE, Europe, etc.—turning compliance records and audit trails into long-term compliance records.

Third: Build U.S.-style channels and ecosystem links.

Atkins’ “super-app” vision hints that the U.S. may adopt a more unified licensing stack—raising new interoperability requirements for trading, market making, brokerage, advisory, synthetic assets, and custody.

Pragmatic action is to partner early with the U.S. financial system through whitelisting, clearing integration, and on-chain settlement pilots, positioning your company as a plug-and-play node rather than a capital-intensive, vertically integrated firm.

Fourth: Localize narrative and team composition.

Peirce’s speech signals that U.S. regulators are shifting the “privacy/ compliance/ efficiency” triangle towards scientific quantification and proportionality.

Your risk, data, and legal teams must deliver value in minimizing unnecessary reporting and maximizing the audit trail. Your top engineers should thrive in cultures that “embed rights into the product”—the key to recruiting top U.S. tech talent.

Just as crucial: your business and operations teams must deeply understand local narratives and business culture—translating regulatory concepts into commercial value propositions and technological strengths into client solutions—building long-term trust with industry groups, state and federal regulators, institutional compliance, and procurement.


In Summary

America’s Unique Advantage: Market Structure and Rights Standards

When you read Atkins’ “Project Crypto” alongside Peirce’s “Peanut Butter & Watermelon,” you see a U.S. that appeals to both capital and talent:

Atkins’ institutional certainty and market engineering draw back liquidity and offerings; Peirce’s steadfast defense of privacy and freedom makes the U.S. the market of choice for developers, users, and brands.

For Chinese capital and enterprises, the U.S. may not be today’s only arena, but it is the strategic high ground that must be conquered for the long run.

Perfect your compliance and tech stack in neighboring markets, then enter the U.S. when ready—where regulation and narrative align. This approach bridges Web3 and Web2 finance in the U.S. and unlocks the full value of digitalized U.S. assets.

Disclaimer:

  1. This article is republished with permission from [Charlie]. Copyright belongs to the original author [Charlie]. For reprint inquiries, please contact the Gate Learn team for prompt handling per relevant process.
  2. Disclaimer: The views and opinions in this article are solely those of the author and do not constitute investment advice.
  3. All other language versions are translated by the Gate Learn team. No reproduction, dissemination, or copying of translations permitted unless Gate is acknowledged as source.

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