Digital assets are moving into production, and financial institutions are no longer experimenting – they are mobilizing.
Over the past 12 months, we’ve partnered with global banks, super regionals, community banks, and credit unions to run strategy and educational sessions, plan proofs of concept, and stand-up programs in digital assets. With the GENIUS Act establishing the first US federal framework for payment stablecoins – requiring reserves, disclosures and compliance – executives now have the regulatory signal many were waiting for to move from exploration to implementation.
Below, we outline Capco’s perspective on where the industry stands and what we see as the 12 most important takeaways for US financial institutions.
It’s not too late to enter – but it’s no longer early either. Even with the GENIUS Act accelerating adoption, banks do not believe they have missed the window. With federal rules for stablecoin issuance in place and broader market structure legislation advancing (via the CLARITY Act), institutions are treating the next 12 to 24 months as a window to build foundational capabilities without ceding ground to faster movers.
Banks are mobilizing. Banks are evaluating digital asset capabilities as a strategic defense against deposit flight and preserve competitive market share in an evolving financial landscape. We see dedicated teams forming across treasury, payments, securities services, and technology - often with a first on ramp through vetted vendors – wallets, custody, tokenization – to move quickly while evaluating longer term build options.
Digital assets have joined AI, core modernization and simplification in the top tier of C suite agendas. The play is to pursue interoperability with broader transformation, not create a standalone island.
Use cases must solve real client problems. The most compelling initiatives target faster cross border settlement, intraday liquidity optimization, streamlined collateral mobility and improved transparency in asset servicing.
Institutional adoption depends on traditional strengths. Security, compliance, risk and governance are decisive advantages. The GENIUS Act establishes reserve, disclosure and AML/sanctions obligations for issuers – all controls that align with banks’ operating DNA.
Third party vendor ecosystems are becoming the on ramp. This vendor-driven model is especially appealing to institutions that want to enter the market quickly while avoiding heavy upfront infrastructure investments. To date, we have seen significant demand for specialized third parties that offer:
- Custodial stablecoin issuance support
- Institutional-grade wallets
- Digital asset custody
- Tokenization platforms.
Crypto-native firms are adapting to the pace and expectations of traditional finance (TradFi). Crypto-native infrastructure providers are increasingly aligning with the control expectations of regulated institutions - something that was not the case five years ago. However, we continue to advise clients to conduct rigorous due diligence, as risk management maturity still varies widely between providers.
Stronger compliance and risk controls are a non-negotiable priority. No bank wants to be the first “FTX of TradFi”. With clearer obligations under the GENIUS Act – such as risk management standards, reserve disclosures, and audit requirements – banks are prioritizing enhancements across operational risk, model risk, compliance and cybersecurity.
Regulatory harmonization: the next competitive frontier. Banks need a global regulatory architecture, not just a product roadmap. That includes cross border policy mapping (issuance, custody, disclosures), data sharing constraints and standards for chain/network interoperability. Early movers who operationalize multi-jurisdictional compliance orchestration will become the natural bridges across settlement networks.
Federated pilots vs. enterprise platforms. The optimal path is federated exploration by banks’ business lines, centralized foundation, and then differentiated business scaling. In practice: banks should consolidate onto an enterprise wallet/custody tier with policy and key management patterns; standardize onboarding for digital assets; and enforce common controls (KYC/AML, sanctions, reconciliation) across use cases.
Two tracks, two speeds: tokenized money and tokenized assets. Lumping everything under ‘digital assets’ hides an important distinction between two ‘lanes’ that should strategically be treated as adjacent programs with shared horizontal services (identity/keys, policy, monitoring) but different product owners, economics, and control stacks:
- Tokenized money – payment stablecoins, tokenized deposits etc that are driving instant settlement, treasury benefits and programmable cash; US clarity on stablecoin issuance is accelerating this lane.
- Tokenized assets – real world assets (RWAs), money market funds (MMFs) and securitized products all have strong momentum, but with more complex custody, valuation, disclosure and transfer restriction patterns, as well as divergent jurisdictional treatments.
Talent will determine winners. Blockchain, DLT and digital asset operations expertise is in short supply. The institutions that win will be those that:
- Retrain existing TradFi teams (treasury, payments and risk)
- Build internal blockchain/DLT competency centers to sustain capabilities
- Partner with vendors for skills augmentation.
Looking ahead
We expect continued acceleration as regulatory clarity deepens and the next wave of legislation advances. The toughest work is not picking a technology, chain or a wallet. It’s designing the operating model - one that combines clear ownership across treasury, payments, markets and risk management – and ensures global compliance orchestration and reporting across jurisdictions.
We remain optimistic. Digital assets represent not only a new product set but a fundamentally improved way of settling value, moving liquidity and reimagining financial infrastructure. At a minimum, the industry is turning the page on a new chapter – one where long-standing legacy processes for asset safekeeping, settlement and cross border movement are reshaped by blockchain enabled capabilities. Thos banks that prepare now will be best positioned to lead in this emerging digital financial ecosystem.
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