Semaine 51


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Last week, the Depository Trust & Clearing Corporation (DTCC) received a No Action Letter from the U.S. Securities and Exchange Commission. The relief allows DTCC to run a three-year pilot of a blockchain-based post-trade layer, while keeping its core clearing, settlement, and risk-management infrastructure firmly offchain.


Why it matters

DTCC sits at the centre of U.S. capital markets. It safeguards more than $100 trillion in assets and processes over $3.7 quadrillion in securities transactions each year. Because virtually every major exchange and broker relies on its infrastructure, even incremental changes to how DTCC operates can carry system-wide implications.

“Recently, we have seen many market participants move to tokenize different asset classes,” explained Frank La Salla, CEO of DTCC, to CNBC. “If the industry moves in a fragmented way, it could hurt liquidity by splitting assets across systems. Given our unique position in the market, we believe it was time to begin tokenization at the foundational level.”

Non-native tokenization

Rather than tokenizing securities themselves, the No Action Letter permits DTCC to issue tokenized entitlements. These digital instruments mirror economic rights and ownership attributes while leaving the underlying securities in traditional custody, preserving existing legal finality and market structure.

To make this model work in practice, DTCC will rely on ComposerX, the tokenization platform developed after its 2023 acquisition of Securrency. ComposerX provides the operational layer for issuance and lifecycle management, while continuously reconciling onchain activity with DTCC’s existing offchain records.


Controlled transfers

Within this architecture, approved participants will be able to transfer tokenized entitlements directly between one another, without submitting settlement instructions to DTCC and potentially outside standard operating hours. To limit both operational and regulatory risk, all activity takes place in a permissioned environment with known counterparties.

That caution extends to settlement itself. Delivery-versus-payment will not involve stablecoins or tokenized deposits at this stage. Instead, final settlement remains offchain, underscoring that the pilot is designed to test operational flows and interoperability, not to replace DTCC’s core settlement function.


Starting point

Although the No Action Letter covers a broad universe of eligible securities, including large-cap equities, the initial pilot will focus on U.S. Treasury securities, with the first minimum viable product planned for the first half of 2026 on the Canton Network.

That choice reflects prior experimentation. In August, a working group including Bank of America and Société Générale successfully exchanged onchain representations of U.S. Treasuries custodied at DTCC against USDC, achieving atomic settlement outside traditional market hours.


Over the three-year pilot, DTCC plans to expand gradually into additional asset classes and use cases. While the firm has indicated a long-term ambition to support both permissioned and permissionless blockchains, any step beyond the current scope of the No Action Letter would require fresh SEC approval, keeping the experiment deliberately constrained.