Tokenized U.S. Stocks: Current Market Status and Prospect Analysis
By Lawrence Lee, Researcher at Mint Ventures
Recently, the tokenized US stocks sector has witnessed several new developments: Centralized exchange Kraken announced the launch of its tokenized stock trading platform, xStocks.Centralized exchange Coinbase announced it is seeking regulatory approval for its tokenized stock trading services.Public blockchain Solana submitted a framework for blockchain-based tokenized US stock products. Both US-based public blockchains and exchanges are accelerating their efforts in tokenized US stocks. Combined with the recent enthusiasm following Circle’s IPO, this momentum is fueling optimism about the future prospects of tokenized US equities. In fact, the value proposition of tokenized U.S. stocks is very clear: 1. Expanded the scale of the trading market: It provides a 7×24-hour, borderless, and license-free trading venue for US stock trading, which is currently unavailable to Nasdaq and NYSE (although Nasdaq has applied for 24-hour trading, it is expected to be realized in the second half of 26)2. Superior composability: By combining with other existing DeFi infrastructure, U.S. stock assets can be used as collateral, margin, to build indexes and fund products, and derive many currently unimaginable gameplays.The needs of both supply and demand are also clear:Suppliers (US-listed companies): Through the borderless blockchain platform, they have reached potential investors from all over the world and obtained more potential buying orders.Demand side (investors): Many investors who were unable to trade U.S. Stocks directly in the past for various reasons can now directly allocate and speculate on U.S. stock assets hrough blockchain.Quoted from “U.S. Stocks on the Blockchain and STO: A Hidden Narrative“ In this round of tolerant crypto regulatory cycle, progress is a high probability event. According to RWA.xyz data, the current market value of tokenized stocks is only 321 million US dollars, and there are 2,444 addresses holding tokenized stocks. The huge market space is in sharp contrast to the current limited asset size.
In this article, we will introduce and analyze the product solutions of current players in the tokenized U.S. stock market and other players who are promoting the tokenization of U.S. stocks, and list potential investment targets under this concept. This article is the author’s interim thinking as of the time of publication. It may change in the future, and the views are highly subjective. There may also be errors in facts, data, and logical reasoning. All views in this article are not investment advice, and we welcome criticism and further discussion from colleagues and readers. According to data from rwa.xyz, the current tokenized stock market has the following projects by issuance size:
We will take a look at the business models of Exodus, Backed Finance, and Dinari (Montis Group targets European stocks, and SwarmX is similar to Backed Finance but on a smaller scale), as well as the progress of several other important players who are currently working on tokenized US stock business recommendations. Exodus Exodus (NYSE.EXOD) is an American company that develops non-custodial crypto wallets. Its stock is listed on the New York Stock Exchange (NYSE.EXOD). In addition to its own branded wallets, Exodus has also collaborated with NFT market MagicEden to launch a wallet. As early as 2021, Exodus allowed users to migrate their common shares to the Algorand chain through Securitize, but the tokens migrated to the chain could not be traded or transferred on the chain, nor did they include governance rights or other economic rights (such as dividends). The Exodus token is more like a “digital clone” of real shares, and its symbolic significance on the chain is greater than its actual significance. The current market value of EXOD is US$770 million, of which approximately US$240 million is on-chain.
Exodus is the first stock approved by the SEC to tokenize its common stock (or to be more precise, Exodus is the first tokenizable stock approved by the SEC to be listed on the NYSE). Of course, this process was not smooth sailing. The listing time of Exodus stock was delayed again and again since May 2024, and it was not officially listed on the NYSE until December. However, Exodus’ stock tokenization is only for its own stocks, and the tokenized stocks cannot be traded, which is of little significance to us Web3 investors. Dinari Dinari is a company registered in the United States. They were founded in 2021. Since its establishment, they have been focusing on stock tokenization under the US compliance framework. They completed a $10 million seed round of financing in 2023 and a $12.7 million Series A financing in 2024. Investors include Hack VC and Blockchange Ventures, Coinbase CTO Balaji Srinivasan, F Prime Capital, VanEck Ventures, Blizzard (Avalanche Fund), etc. Among them, F Prime is a fund under the asset management giant Fidelity. The investment of Fidelity and VanEck also shows the recognition of the tokenized US stock market by traditional asset management institutions. Dinari only supports non-US users. The process of trading US stocks is as follows: User completes KYCThe user selects the US stocks they want to buy and pays with USD+ issued by Dinari (a short-term Treasury bond-backed stablecoin issued by Dinari that can be exchanged from USDC)Dinari submits the order to the cooperating broker (Alpaca Securities or Interactive Brokers). After the broker completes the order, the shares are kept in the custodian bank, and Dinari mints the corresponding dShares for the user. Currently, Dinari operates on Arbitrum, Base, and the Ethereum mainnet. All dShares have a 1:1 correspondence with real-world equity. Users can view the equity corresponding to their dShares through the Dinari official website. Dinari can also distribute dividends or stock splits to users holding its dShares. However, dShares cannot be traded on the chain. If you want to sell dShares, you can only trade through the Dinari official website. The actual transaction process is the reverse of the purchase process. dShares transactions must also follow US trading hours and cannot be bought or sold outside of trading hours. In terms of product form, in addition to direct stock trading, they also offer stock trading APIs that can work with other trading front ends. In fact, Dinari’s business process, namely “KYC->payment exchange->clearing and settlement by compliant brokers”, is consistent with the current mainstream way for non-US users to participate in US stock transactions. The main difference is that the asset categories paid by users are Hong Kong dollars, euros, etc., while the asset categories accepted by Dinari are encrypted assets. The rest are completely implemented in accordance with the SEC’s regulatory framework. As a company mainly engaged in the tokenization of US stocks, Dinari’s courage to register the company in the United States (the registration place of the corresponding entities of most other projects is in Europe) shows its confidence in its compliance capabilities. Their US stock tokenization products were officially launched in 2023. At that time, the former SEC Chairman Gary Gensler, who was known for his strict supervision of cryptocurrencies, could not find fault with its business model; and after the new SEC Chairman Paul Atkins took office, the SEC once held a special meeting with Dinari, asking Dinari to demonstrate its system and answer relevant questions (source), which showed that its products were impeccable in terms of compliance and the team’s strong resources in compliance. However, since Dinari’s tokenized US stocks do not enable on-chain trading, cryptocurrency serves merely as an entry point and payment method for Dinari. Functionally, Dinari’s product offers little distinction from platforms like Futu or Robinhood. For its target users, Dinari’s product experience provides no advantage over its competitors. For a user in Hong Kong, trading US stocks on Dinari offers no improved experience compared to using Futu. Additionally, it lacks access to trading features like margin trading, and users may even face potentially higher fees. Perhaps precisely for these reasons, Dinari’s tokenized stock market has remained small in scale. Currently, only the tokenized stock MSTR has a market capitalization exceeding $1 million, and just five tokenized stocks have market caps above $100,000. Presently, the vast majority of its TVL is participating in its floating-rate treasury products.
Dinari’s current market capitalization of tokenized stocks Source Overall, Dinari’s tokenized stock business model has received regulatory certification. However, strict compliance requirements prevent its tokenized stocks from being traded/staked on-chain, eliminating composability. This results in an inferior user experience for dShare holders compared to traditional brokerages, diminishing the product’s appeal to mainstream Web3 users. Among current market players, projects similar to Dinari include the meme coin Stonks community project mystonks.org. According to the project’s self-disclosed reserve report, their U.S. stock portfolio currently exceeds $50 million in market value, with significantly higher user trading activity than Dinari. However, the regulatory framework of mystonks.org remains flawed. For instance, the qualifications of its securities custody account are not clearly specified, and users cannot verify its reserve reports. Backed Finance Backed Finance is a Swiss company, also founded in 2021. Its product launched in early 2023, and in 2024 it completed a $9.5 million funding round led by Gnosis, with participation from Cyber Fund, Blockchain Founders Fund, Blue Bay Capital, and others. Like Dinari, Backed does not serve U.S. users. Its operational process is as follows: Issuers (professional investors) complete KYC verification and review on Backed Finance.The issuer selects the U.S. stocks they wish to purchase and pays in stablecoins.Backed Finance submits the order to a partner brokerage to complete the stock purchase. After the purchase, Backed Finance mints the corresponding bSTOCK token and delivers it to the issuer.Both bSTOCK and its wrapped version wbSTOCK can be freely traded on-chain (the wrapping primarily facilitates handling dividend distributions, etc.). Retail investors can directly purchase bSTOCK or wbSTOCK on-chain. As can be seen, unlike Dinari where retail investors directly purchase stocks, Backed Finance currently relies on professional investors buying the stocks and then transferring them to retail investors. This significantly improves overall operational efficiency and enables 24/7 trading. Another key difference is that the bSTOCK tokens issued by Backed are unrestricted ERC-20 tokens, allowing users to form LP on-chain for others to purchase.
Liquidity of Backed’s Tokenized Stocks Source Backed Finance’s on-chain liquidity primarily derives from the SPX index, Coinbase, and Tesla. Users create liquidity by pairing bSTOCK tokens with stablecoins in AMM pools. The current TVL across all liquidity pools approaches $8 million, with an average APY of 32.91%. Liquidity is distributed across Balancer and Swapr on Gnosis Chain, Aerodrome on Base, and Pharaoh on Avalanche. Notably, the bCOIN-USDC liquidity pool currently offers an APY reaching 149%. A critical operational distinction is that Backed Finance imposes no restrictions on on-chain trading of its bSTOCK tokens. This creates a secondary pathway for token holders, where on-chain users – without undergoing KYC verification – can directly purchase bSTOCK using stablecoins such as USDC or sDAI. This approach effectively bypasses KYC restrictions while delivering a trading experience indistinguishable from trading standard on-chain tokens, making it more readily adoptable by Web3 users. Moreover, by issuing unrestricted ERC-20 tokens, Backed unlocks composability for tokenized stock holders – exemplified by stablecoin pairings generating LP yields averaging 33% APY. This likely explains why Backed Finance’s TVL is nearly 10 times larger than Dinari’s. Regarding compliance, Backed Finance operates through a Swiss-registered entity. Its business model – where “ERC-20 tokens representing tokenized stocks are freely transferable” – has received approval from European regulatory authorities (source). Backed also publishes proof-of-reserve audits conducted by The Network Firm. However, the U.S. SEC has not yet commented on Backed’s operations. Notably, all securities tokenized by Backed are U.S. stocks. While Swiss regulatory approval is certainly beneficial, the more critical factor is how U.S. regulators will ultimately assess this model. Among comparable projects, SwarmX operates under an identical model but falls significantly short of Backed Finance in both operational scale and compliance rigor. Despite Backed Finance’s tokenized stocks having a market cap ten times larger than Dinari’s, its $20 million-plus assets under management and $8 million TVL still represent relatively modest scale, while on-chain trading activity remains notably low. The core reasons for this include: Limited Use Cases: Tokenized stocks currently only serve LP purposes on-chain. Their composability potential remains largely untapped, likely due to concerns from integrated protocols (e.g., lending/stablecoin) regarding regulatory uncertainty.Liquidity Constraints: As Backed itself is not an exchange, its tokenized stocks lack organic liquidity support. Existing liquidity relies entirely on issuers, specifically, their willingness to hold tokenized stocks and provide LP capital. Current data indicates that issuers lack the incentive to increase exposure in these areas. Should the SEC establish clearer regulatory frameworks affirming Backed’s model, both issues could be alleviated. xStocks In May this year, the U.S. exchange Kraken announced plans to collaborate with Backed Finance and Solana to launch xStocks. On June 30th, the xStocks product officially launched. Its partners include Backed, Kraken, and Solana, as well as centralized exchanges Kraken and Bybit, Solana-based decentralized exchanges Raydium and Jupiter, lending protocol Kamino, Bybit-incubated DEX Byreal, oracle Chainlink, payment protocol Alchemy Pay, and brokerage firm Alpaca.
Source: Official Website of xStocks The legal architecture of xStocks is identical to that of Backed Finance. It currently supports over 200 stock products, with Kraken offering 24/5 trading hours. Key partnerships include: Kraken, Bybit, Jupiter, Raydium, and Byreal as supporting exchanges; Kamino enables xStocks to be used as collateral, while Kamino Swap facilitates trading of xStocks; Solana as the underlying blockchain; Chainlink providing reserve attestations; and Alpaca serving as a brokerage partner. Due to its relatively short time since launch, comprehensive data metrics remain limited, and trading volumes are currently modest. However, xStocks demonstrates significantly stronger partner integration compared to Backed Finance’s native offering: CEX like Kraken and Bybit may leverage their existing market makers and user bases to enhance liquidity for xStocks. Within the on-chain ecosystem, multiple DEXs and Kamino support xStocks. Significantly, Kamino has pioneered new use cases for tokenized U.S. stocks beyond liquidity provision. Additional protocols are expected to integrate xStocks in the future, further expanding its composability potential. Given these strategic advantages, the author maintains that despite its nascent launch status, xStocks will rapidly surpass existing providers to become the dominant tokenized U.S. stock issuer. Robinhood Robinhood, which has been actively expanding its cryptocurrency business, submitted a report to the SEC in April 2025 calling for the establishment of an RWA regulatory framework covering tokenized stocks. In May, Bloomberg reported that Robinhood would create a blockchain platform enabling European investors to trade U.S. stocks, with Arbitrum or Solana being candidate public chains. Also on June 30, Robinhood officially announced the launch of its tokenized U.S. stock trading product for European investors. The product supports dividend distributions and offers 5*24 market access. Robinhood’s tokenized stock product was initially issued on Arbitrum. In the future, its tokenized stock infrastructure will operate on Robinhood’s proprietary L2, which is also built on Arbitrum. However, according to Robinhood’s official documentation, its current tokenized stock product does not constitute genuine tokenized equity, but rather derivative contracts tracking the prices of corresponding U.S. Stocks, with the underlying assets securely held by licensed U.S. institutions in Robinhood Europe accounts. Robinhood Europe issues these contracts and records them on the blockchain. Currently, these tokenized stocks can only be traded within Robinhood and are not transferable. Other Players Venturing into the Space Beyond the projects with operational deployments discussed above, numerous other players are venturing into tokenized U.S. equities, including: Solana Solana demonstrates a significant commitment to tokenized equities beyond its involvement with xStocks. It has established the Solana Policy Institute (SPI), which aims to “educate policymakers on why decentralized networks like Solana represent foundational infrastructure for the future digital economy.” Two projects are currently being advanced. One is named Project Open, “enable compliant blockchain-based issuance and tradingof securities. This initiative seeks to harness blockchain technology to create more efficient, transparent, and accessible capitalmarkets while maintaining robust investor protections.” Members of Project Open, besides SPI, include the Solana-based DEX Orca, RWA service provider Superstate, and the law firm Lowenstein Sandler LLP. Since April this year, Project Open has repeatedly submitted public written comments to the SEC’s Crypto Task Force. On June 12, the SEC’s Crypto Task Force held a meeting with them, after which Project Open members separately submitted further explanations regarding their respective business operations. The tokenized U.S. stock issuance and trading process advocated by Project Open is as follows:
Source: SEC official document The process is summarized as follows: Issuers must pre-apply for SEC approval. Upon approval, they may issue tokenized U.S. stocks.Users wishing to purchase tokenized U.S. stocks must complete KYC verification beforehand. After completion, they may use cryptocurrency to purchase these issuer-approved tokenized stocks.SEC-registered transfer agents will record share transfers on-chain. Project Open specifically advocates for SEC permission enabling peer-to-peer trading of tokenized U.S. stocks via smart contracts. This would allow tokenized stock holders to trade through AMM, thereby unlocking on-chain composability. However, per the proposed framework, all holders of tokenized U.S. stock positions must complete KYC. To implement this process, Project Open has requested 18-month exemptive relief or confirmatory guidance for multiple operations (see references for details). Overall, Project Open’s proposal builds upon Backed Finance’s existing framework by adding KYC requirements. From the author’s perspective, approval under the current SEC leadership, which has shown relative tolerance toward DeFi, appears almost certain. The only remaining question is the timing of approval. Coinbase As early as 2020, when Coinbase applied for a Nasdaq listing, its filing included plans for on-chain issuance of tokenized COIN. However, this initiative was abandoned due to non-compliance with SEC requirements at the time. Recently, Coinbase has been seeking a no-action letter or exemptive relief from the SEC for its tokenized stock trading business. While detailed documentation remains unavailable, a key confirmed detail from press releases states: Coinbase’s tokenized stock trading program will be accessible to U.S. users. This represents the key distinction from other current tokenized stock market players and enables Coinbase to directly compete with online brokerages like Robinhood and traditional brokers such as Charles Schwab. For Web3 investors, however, this development holds far less significance than its implications for Nasdaq:COIN. Ondo Ondo, which has established a proven presence in the treasury bond RWA market (see Mint Ventures’ earlier coverage on Ondo), has long planned a tokenized U.S. stocks business. According to their documentation, their tokenized stock product features: Accessibility to non-U.S. users24/7 trading availabilityReal-time token minting and redemptionPermission to use tokenized stock assets as collateral Judging from these specifications, Ondo’s product closely aligns with the new framework proposed by Solana. Ondo has also announced at Solana’s Accelerate conference its intention to launch the tokenized stock product on the Solana network. Ondo’s tokenized stock platform, Ondo Global Markets, is scheduled to launch later this year. The above outlines the current landscape of the tokenized U.S. stock market and key players expanding into this space. Fundamentally, users’ primary motivation for purchasing tokenized stocks is to profit from price fluctuations. Their focus centers on: exchange liquidity, settlement guarantees, and the ability to trade while bypassing KYC. Whether the tokenization is performed by compliant institutions is not a user priority. Consequently, the Web3 market has consistently offered derivative-based solutions for synthetic U.S. stock exposure. U.S. equity trading via derivative-based instruments Platforms providing U.S. stock derivatives services primarily include Gains Network (on Arbitrum and Polygon) and Helix (on Injective). Their users do not actually trade U.S. equities, thus eliminating the need for tokenization. Their core product logic applies perpetual contract mechanisms to U.S. stocks, typically featuring: No KYC requirements for traders, and stablecoins as collateral with leveraged tradingTrading hours synchronized with U.S. market sessionsAsset prices sourced directly from trusted oracles like ChainlinkFunding rates balancing on-platform prices against fair market values However, neither current platforms (Gains/Helix) nor predecessors (Synthetix/Mirror) have achieved significant trading volumes with synthetic stock models. Helix processing under $10 million daily in synthetic U.S. stock derivatives, and Gains Network handling less than $2 million in comparable activity. This underperformance stems from two critical factors: This model carries significant regulatory risks. Although they do not actually facilitate trading of U.S. stocks, they effectively function as exchanges, enabling users to trade U.S. equities. Regulators impose clear requirements on any exchange, with KYC being one of the most fundamental compliance obligations. While regulators may overlook such platforms when they remain under the radar, they will inevitably come under scrutiny if their profile grows substantially.Furthermore, none of these platforms currently possesses sufficient liquidity to meet genuine user trading demands. Their liquidity models rely entirely on internal, self-contained solutions without access to third-party liquidity sources. Consequently, none of them can provide users with viable trading depth.
Trading Volume of Helix’s U.S. Stocks & Forex Products
Order Book for COIN (Highest Volume) On the centralized exchange front, Bybit recently launched a U.S. equities trading platform based on MT5. This product similarly adopts perpetual contract-like mechanics, executing no actual equity transactions but facilitating index trading with stablecoins as collateral. Additionally, the upcoming Shift project introduces the concept of Asset-Referenced Tokens (ART), claiming to enable KYC-free U.S. stock trading through the following operational flow: Shift purchases U.S. stocks and custodies them with regulated brokers (e.g., Interactive Brokers) and uses Chainlink Proof-of-Reserve for asset verificationIssues ART backed by reserved stocks, each ART corresponds to underlying equities, but does not constitute tokenized stocks.Retail investors can purchase ART without KYC Shift’s model maintains 100% reserve backing between ARTs and underlying U.S. equities. However, ARTs do not constitute tokenized stocks and confer no share ownership rights, dividend entitlements, or voting privileges. Consequently, they fall outside existing regulatory frameworks, enabling KYC-free trading (Source). From a regulatory logic perspective, ART is not permitted to be pegged to securities assets. It remains unclear how the Shift team intends to implement ‘pegging ART to U.S. stocks’ in practice, nor is it certain whether the final product design will truly operate according to the above-described mechanisms. However, by leveraging certain loopholes in regulatory provisions, this solution achieves KYC-free U.S. stock trading and warrants ongoing monitoring. What Kind of Tokenized U.S. Stock Products Does the Market Need? Regardless of the tokenization approach, all solutions share this core two-step process: Tokenization: The process is typically managed by regulated entities that provide periodic proof-of-reserves. Fundamentally, it enables KYC-compliant users to access U.S. equities through blockchain representation after traditional acquisition. Minimal divergence exists across current implementation frameworks.Trading: End-users transact with tokenized equities. The critical divergence across solutions manifests here: certain platforms prohibit trading entirely (Exodus); others restrict transactions to licensed broker channels (Dinari and mystonks.org); while several enable native on-chain trading (Backed Finance, Solana, Ondo, Kraken). Notably exceptional is Backed Finance, which currently leverages Swiss regulatory frameworks to allow non-KYC users direct AMM purchases of its tokenized U.S. stock products. For end-users, the tokenization process primarily concerns regulatory compliance and asset security, criteria currently met by most market players. The pivotal differentiator lies in trading mechanisms. Platforms like Dinari restrict transactions to licensed broker channels while offering no liquidity mining or lending, substantially diminishing the utility of tokenized equities. Regardless of compliance rigor or operational refinement, such limitations inherently deter user adoption. Conversely, models like xStocks, Backed Finance, and Solana represent more consequential long-term solutions. By enabling native on-chain trading—bypassing traditional brokerage systems—they fully harness DeFi’s core advantages: 24/7 accessibility and programmable composability. However, on-chain liquidity remains insufficient to rival traditional venues. Low-liquidity exchanges functionally equate to unusable platforms; tokenized equities cannot scale without deeper liquidity pools. This is also why the author is optimistic about xStock. Ultimately, as regulatory clarity emerges and tokenized stocks proliferate across Web3, market share will likely consolidate toward exchanges with pre-existing advantages: superior liquidity and established trader networks. In fact, we can see from the few examples in the previous cycle that Synthetix, Mirror, and Gains all launched products featuring U.S. stock trading in 2020. However, the most influential U.S. stock trading product was FTX. FTX’s approach was actually quite similar to the current solution offered by Backed Finance, but FTX’s trading volume and AUM for stocks were far higher than Backed Finance’s. Potential Investment Targets Although the market potential for tokenized U.S. stocks is significant, there are currently very few investable options available to investors. Among existing players, neither Dinari nor Backed Finance has issued a token. Dinari has even explicitly stated that it will not issue one. The only potential investment target in this category is the meme token STONKS, associated with mystonks.org. As for actively involved players, the tokens of Coinbase, Solana, and Ondo already have relatively high market capitalizations. Moreover, tokenized U.S. stocks are not their core business. While progress in tokenized equities may have some influence on their tokens, the extent of that impact is hard to predict. xStock’s partners include leading Solana-based DEXs such as Raydium and Jupiter, as well as the lending protocol Kamino. However, these collaborations are unlikely to bring significant growth to the mentioned protocols. Among the members of the SPI Project Open initiative, Phantom and Superstate have not issued tokens, while only Orca has. In the derivatives space, Helix has yet to launch a token, leaving GNS as the only investable option. Since these projects vary widely in their business models and approaches to tokenized U.S. stocks, it’s not possible to conduct a meaningful valuation comparison. Instead, we provide a summary of the basic information for the relevant tokens below:
References https://x.com/xrxrisme69677/status/1925366818887409954 https://www.odaily.news/post/5204183 Project Open References: Initial Framework Submitted in April: https://www.sec.gov/files/ctf-written-project-open-wireframe-04282025.pdfJune 12 Meeting Between SEC Crypto Working Group and Project Open Team: https://www.sec.gov/files/ctf-memo-solana-policy-institute-et-al-061225.pdfJune 17 Updates by SPIUpdated Proposal Framework by SPI: https://www.sec.gov/files/project-open-chain-equities-infrastructure-061725.pdfSupplemental Materials from SPI: https://www.sec.gov/files/project-open-061725.pdfPhantom Technologies Submission: https://www.sec.gov/files/phantom-technologies-061725.pdfSuperstate Submission: https://www.sec.gov/files/ctf-superstate-letter-061725.pdfOrca Creative Submission: https://www.sec.gov/files/orca-creative-061725.pdf Project Open submitted an application for exemptive relief or confirmatory guidance, which includes: Blockchain, as a technological tool, does not in itself require or mandate any SEC registration.Network fees on blockchain are considered technical costs and are not treated as securities transaction fees.Peer-to-peer transactions conducted via smart contract protocols are permissible and do not fall under the regulatory definition of exchange or ATS transactions, as they are bilateral transactions, similar to those envisioned under Section 4(a)(1) of the Securities Act of 1933.Relief for broker-dealers to participate in Section 4(a)(1) transactions (serving in a limited administrative role).Non-custodial/self-custodial wallets (and their providers) are not classified as broker-dealers.Holding tokenized equities in non-custodial/self-custodial wallets that have passed proper whitelisting and KYC is allowed.Broker-dealers may create sub-wallets for clients to hold tokenized equities. For custodial purposes, this satisfies the SEC’s requirement for “possession and control” of securities.Transfer agents may fulfill their responsibilities using blockchain if they have access to the KYC information of whitelisted wallet owners and modernized accredited investor educational materials, enabling the enforcement of: a) Transfer restrictions; b) Restrictive legends (e.g., for securities held by affiliates).Registration statements may be used to register tokenized equities, provided appropriate exemptive relief is granted. This includes: a) Proposals on content and format requirements; b) Proposals on methods of periodic reporting.Direct purchases of shares from the issuer, as envisioned above, would not cause purchasers to be considered underwriters or broker-dealers. These purchases are not made in the capacity of a broker or dealer.Requests for appropriate exemptions from Reg NMS, such as: Order Protection Rule, Best Execution, and Access Rule.
A Breakdown of WLFI’s Business, Background, Tokenomics, and Valuation Outlook
By Alex Xu, Mint Ventures' research partner Introduction Circle’s stock price has been soaring since its IPO (though showing a noticeable pullback recently), and stablecoin-related stocks in global markets are also exceptionally volatile. The U.S. stablecoin bill, the Genius Act, has passed the Senate vote and is now making its way through the House of Representatives. Recently, news emerged that tokens for the Trump family’s flagship project, World Liberty Financial (WLF), might be unlocked and enter circulation ahead of schedule. This counts as major news in the recently overall lackluster altcoin market, which has been starved of compelling narratives. So, how is World Liberty Financial actually performing currently? How is its token mechanism designed? And what benchmarks should be used for its valuation? Through this article, the author will attempt to provide a multi-dimensional analysis of World Liberty Financial’s current business status, project background details, tokenomics, and valuation expectations, offering readers several perspectives for evaluating the project. PS: This article represents the author’s preliminary thoughts as of the time of publication and is subject to change. The views expressed are highly subjective and may contain factual, data-related, or logical errors. All opinions herein are in no way investment advice. Constructive feedback and further discussion from industry peers and readers are welcome. Business: Product Status and Core Competitive Advantages World Liberty Financial (WLF) is a decentralized finance DeFi platform co-founded with participation from the family of U.S. President Donald Trump. Its core product is the USD1 stablecoin. USD1 is a 1:1 dollar-pegged stablecoin fully backed by reserves of cash and U.S. Treasury bonds. World Liberty Financial also has plans for lending services (built on Aave) and a DeFi app, though these are not yet live. USD1 Business Data As of June 2025, the circulating supply of the USD1 stablecoin has reached approximately $2.2 billion. Among these, BNB Chain hosts 2.156 billion USD1 in circulation, Ethereum holds 48 million, and Tron maintains 26,000. BNB Chain accounts for 97.8% of the total supply, confirming that the vast majority of USD1 is issued on this network. Regarding on-chain user metrics, BNB Chain leads with 248,000 wallet addresses holding USD1, followed by Ethereum at 66,000 addresses. Tron currently maintains merely one active address with USD1 holdings. Analysis of token distribution reveals that on BNB Chain, 93.7% of USD1 (equivalent to 2.02 billion USD1) is held across two Binance-controlled addresses. Within this, 1.9 billion USD1 is concentrated in a single Binance address (0xF977814e90dA44bFA03b6295A0616a897441aceC). Examining USD1’s historical market capitalization, we observe that prior to May 1, 2025, its market value remained around $130 million. However, on May 1 itself, the value surged to $2.13 billion, representing an overnight increase of nearly $2 billion.
Growth curve of USD1 scale | Source: CMC The explosive growth primarily stems from Abu Dhabi investment firm MGX’s $2 billion equity investment in Binance in May 2025, where USD1 was selected as the payment currency. The current USD1 balance retained in Binance’s addresses aligns precisely with this $2 billion amount. This implies: After receiving MGX’s USD1 investment, Binance did not convert it to USD or other stablecoins, making it USD1’s largest holder with 92.8% of total supply.Excluding this transaction-derived volume, USD1 remains a small-scale stablecoin with a circulating market value barely exceeding $100 million. This business expansion model is likely to recur in future project development. Business Partnerships WLFI has established collaborations with multiple institutions and protocols to expand its market presence. In June 2025, WLFI announced a partnership with London-based crypto fund Re7 to launch USD1 stablecoin vaults on Ethereum lending protocol Euler Finance and BNB Chain staking platform Lista. This initiative aims to amplify USD1’s footprint across Ethereum and BNB Chain ecosystems. Notably, Lista is a leading BNB staking platform backed by Binance Labs. Additionally, Aave – currently the largest decentralized lending platform – has proposed integrating USD1 into its markets on Ethereum and BNB Chain. The draft proposal has already passed community voting. For trading accessibility, USD1 is now listed on centralized exchanges including Binance, Bitget, Gate, and Huobi, as well as decentralized exchanges such as Uniswap and PancakeSwap. World Liberty’s Competitive Advantages World Liberty’s competitive edge is straightforward: the Trump family’s formidable political influence grants the project inherent advantages in specific business expansions unavailable to competitors. This initiative also serves as a potential conduit for interests among individuals, organizations, or even nations with commercial or political ties to Donald Trump. A prime example is Binance’s use of USD1 – issued by World Liberty – as the capital vehicle for Abu Dhabi investment firm MGX’s massive funding. Binance continues to hold these assets interest-free (effectively boosting USD1’s TVL) while rapidly listing USD1 across its platforms. However, World Liberty token holders face three primary risks: The Trump family maintains numerous channels for financial interests, and World Liberty may not be the ultimate choice for contributors. (For context on the Trump family’s diverse revenue streams, refer to Bloomberg’s late-May 2025 exposé: “THE TRUMP FAMILY’S MONEY-MAKING MACHINE“, detailing their multifaceted approaches.)WLFI tokens are fundamentally decoupled from World Liberty’s project value. (Analysed in the “Tokenomics” section below.)Potential operational abandonment by the Trump family post-token sell-off—or even during divestment—mirroring historical patterns observed in all Trump-affiliated crypto assets (from Trump Tokens to various NFTs). Background: Backing and Financing Details Core Team Background World Liberty Financial’s core team hails from political and business circles, forming the foundation of the project’s competitive edge and influence. Undoubtedly, the project’s central figures are Donald Trump—the 45th and 47th President of the United States—and his three sons: Donald Trump Jr., Eric Trump, and Barron Trump (aged 17). However, their listed roles on World Liberty Financial’s official website have undergone subtle yet notable shifts over the past month. As of mid-June, Donald Trump held the symbolic title of “Chief Crypto Advocate,” while his three sons were given equally vacuous roles as “Web3 Ambassadors.” These definitions for all four Trump family members are identically stated in the project’s “Golden Paper”.
Nonetheless, the four Trump members are listed above all project Co-Founders in official placements.
World Liberty Financial Team Profile Page (Mid-June 2025) However, the project’s official team page has recently been updated with revised titles: Donald Trump is now listed as “Co-Founder Emeritus”, while his three sons have been designated as “Co-Founders.”
World Liberty Financial Team Profile Page (Late June 2025) Another subtle detail: both Donald Trump and Steven Witkoff (another “Co-Founder Emeritus” whose title was downgraded from “Co-Founder” in the recent update) now have an almost imperceptible footnote marker “1” appended to their titles. At the bottom of the webpage, fine print clarifies: “Removed upon taking office”, indicating their honorary titles will be revoked if they assume public office. This compliance mechanism aims to prevent conflicts of interest for government-affiliated figures by severing private commercial ties—a standard ethical requirement for U.S. public officials. However, a critical contradiction exists: Donald Trump currently holds public office as the sitting U.S. President. Beyond the Trump family, another pivotal figure is Steven Witkoff—a longtime business associate of Trump and prominent New York real estate magnate—serving as Co-Founder Emeritus. As founder and chairman of the Witkoff Group, he has maintained close ties with Donald Trump since the 1980s, frequently socializing on golf courses as widely recognized “longtime friends and business partners.” Following Trump’s presidential inauguration, Witkoff was appointed “U.S. Special Envoy to the Middle East,” reporting directly to Trump. He played central roles in high-stakes negotiations involving Israel, Qatar, Russia, and Ukraine, additionally acting as Trump’s “private emissary” to Moscow for multiple meetings with Russian leadership. The Witkoff family is deeply embedded in the project: Both sons, Zach Witkoff and Alex Witkoff, are WLFI Co-Founders. Beyond political and business figures, WLFI’s technical and operational operations are primarily managed by crypto industry professionals. Zak Folkman and Chase Herro, both Co-Founders, are serial entrepreneurs in the cryptocurrency space. Their previous venture involved launching the DeFi platform “Dough Finance,” though the project failed following an early-stage hack, rendering their entrepreneurial track record unremarkable. Within WLFI, Folkman and Herro initially held primary control until January 2025, when they relinquished authority to a Trump-family-controlled entity. Another key member is Richmond Teo, heading WLFI’s Stablecoin and Payments division. Teo previously co-founded the renowned compliant stablecoin firm Paxos and served as its Asia CEO. The team further includes blockchain practitioners such as Corey Caplan (Head of Technical Strategy) and Ryan Fang (Growth Lead), alongside traditional finance compliance experts, including Brandi Reynolds (Chief Compliance Officer). The project has also enlisted several advisors, including Luke Pearson (Partner at Polychain Capital) and Sandy Peng (Co-Founder of Ethereum Layer-2 network Scroll). Notably, Peng provided operational support during WLFI’s token sale period. Equity Evolution of the Trump Family in World Liberty Financial The Trump family’s stake in World Liberty Financial has steadily declined, from an initial 75% to the current 40%.
The decline from the initial 75% to 40% stake may involve transfers to Justin Sun, DWF Labs, and the recently announced $100M investor Aqua 1 Foundation (this remains unverified). Financing Journey & Backers Since its September 2024 inception, World Liberty Financial has raised cumulatively over $700 million through multiple funding rounds, with its valuation surging rapidly post-Trump’s inauguration and token launch. I delineate key funding rounds below:
Notably, according to the project’s Gold Paper and website disclosures, the Trump family is entitled to 75% of net proceeds from token sales (through subsequent equity divestments, which represent an indirect resale of token sale proceeds) and 60% of future net profits generated by stablecoin operations. Tokenomics: Allocation, Utility & Protocol Revenue Token Distribution & Vesting Details The governance token $WLFI has a total supply of 100 billion tokens. Per the token economic model outlined in the official “Golden Paper”, the allocation and vesting schedule are structured as follows:
Here are the key points to note: The team allocated 35% of the tokens for the token sale (public sale), but only 25% of that allocation has been completed so far. There is currently no information on how the remaining 10% will be handled. Additionally, while the public sale portion of the WLFI tokens has an additional clause specifying an expected 12-month lock-up period, the tokens in the other allocation categories have no clearly defined unlock conditions or timelines. However, like public sale tokens, they are currently non-transferable. The ambiguity surrounding the specific unlock terms for the non-public sale WLFI tokens creates significant uncertainty for the project. Token Functionality WLFI is a pure governance token. It does not confer any profit-sharing or income rights, nor does it represent equity claims in the project company. Its value primarily derives from governance participation. Protocol Revenue Distribution The official WLFI Gold Paper states the following regarding the handling of protocol revenue: $30 million of initial net protocol revenues will be held in a reserve controlled by a WLF (the project is abbreviated as WLF here but later renamed WLFI) Multisig to cover operating expenses, indemnities, and obligations. Net protocol revenues include revenues to WLF from any source, including without limitation platform use fees, token sale proceeds, advertising or other sources of revenue, after deduction of agreed expenses and reserves for WLF’s continued operations. The remainder of net protocol revenues will be paid to DT Marks DEFI LLC, Axiom Management Group, LLC WC Digital Fi LLC, which are entities affiliated with our founders and certain service providers (“Initial Supporters”). These entities have indicated to WLF their intent to deploy the majority of the fees received on the WLF Protocol once launched. In essence, protocol revenue primarily flows to corporate entities behind WLFI (though they have committed to allocating most funds to support the protocol). Crucially, WLFI tokens themselves have no direct linkage to business revenue. Valuation: What is WLFI Worth Long-Term? Since WLFI’s core business revolves around stablecoins, we can reference the valuation metrics of its major listed competitor, Circle, using its “Market Cap / Stablecoin Market Cap” ratio to roughly estimate WLFI’s fair valuation range. As of late June 2025, Circle’s USDC stablecoin maintained a circulating supply of approximately $61.7 billion. During the same period, Circle’s market capitalization stood at $41.1 billion, with a fully diluted valuation (including options and convertible instruments) reaching approximately $47.1 billion. This establishes Circle’s “Market Cap to Stablecoin Supply” ratio within the range of 0.66 to 0.76 ($41.1B/$61.7B = 0.66; $47.1B/$61.7B = 0.76). “Applying this benchmark to WLFI, which currently supports $2.2 billion in stablecoin supply, yields a projected valuation range of $1.452 billion to $1.672 billion ($2.2B × 0.66 = $1.452B; $2.2B × 0.76 = $1.672B), implies a theoretical token price range of $0.0145 to $0.0167 ($1.452B ÷ 100B = $0.0145; $1.672B ÷ 100B = $0.0167).” Clearly, this is a figure that WLFI investors find difficult to accept. For first-round public offering investors, it’s barely above the break-even point. Expectations for WLFI are high, and possible reasons include: Early WLFI had incomplete unlocking: Its circulating market cap is significantly lower than its FDV, allowing WLFI to command a higher premium.WLFI is in its early stages: Its potential growth rate is far higher than Circle’s.WLFI possesses strong political resources: It should carry a “Trump premium,” attracting numerous projects eager to partner with WLFI.Sentiment and speculation in the crypto market are more aggressive than in the stock market: WLFI will enjoy a higher premium than Circle.WLFI may time its token issuance closely with the passage of the US GENIUS Act stablecoin bill: This would allow it to capitalize on high market sentiment and enthusiasm. …… However, we can also present corresponding counter-arguments, such as: The stablecoin business has extremely strong network effects: The leader should have a stronger competitive advantage and command a higher valuation premium than a new entrant (consider the profit-generating power of the sector leader Tether compared to the second-place Circle).WLFI project revenue is unrelated to the WLFI token: The WLFI token lacks value capture and should be heavily discounted in valuation.93% of WFLI’s current stablecoin market cap is held by Binance for support. This indicates very low organic adoption, and the business volume is heavily inflated.WLFI might be just one of many Trump family “white-label licensing projects”: They could be as ruthless in dumping and operations as they were with the Trump token and various Trump NFTs, likely incapable of long-term commitment.Liquidity in the crypto market, especially for altcoins, has long dried up: Secondary market players hardly believe any story not backed by solid business data, and most newly listed tokens go into free fall. …… As an investor, which side of the argument you lean towards is a matter of perspective. In the author’s view, the decisive factor for WLFI token’s short-term price movement after listing will depend, on one hand, on the final content and timing of the Genius Act’s passage. More importantly, however, it hinges on whether the Trump family, in its various backroom deals and transactions, is willing to position WLFI as a relatively central medium of exchange for mutual benefits. This would manifest as “influential individuals/business entities/sovereign nations” actively embedding USD1 (even symbolically) into their business processes to gain political and commercial advantages – such as using USD1 as an investment currency (equity investments) or a settlement currency (cross-border trade). If there is a lack of such concentrated business news following the listing, WLFI likely holds a precarious position within the Trump family’s business empire. They undoubtedly have more lucrative channels. Let’s wait and see how WLFI develops after its listing. So, when specifically will the WLFI token become transferable? I speculate it will be after the US “Genius Act” is formally enacted (it has currently passed the Senate). That will be the optimal time for the project team to act freely, and it’s not far off.
Sifting for Gold: Identifying Long-Term Investment Targets Through Market Cycles (2025 Part2)
By Alex Xu, Mint Ventures' research partner & Lawrence Lee, Mint Ventures' researcher
In our previously published “Sifting for Gold: Identifying Long-Term Investment Targets Through Market Cycles (2025 Edition – Part I)“, we analyzed lending sector projects, including Aave, Morpho, Kamino, and MakerDAO, as well as staking sector projects Lido and Jito. Part II will continue exploring fundamentally strong projects with long-term potential. PS: This article reflects the authors’ perspectives as of publication date, which may evolve over time. The views expressed are highly subjective and may contain factual, data, or logical errors. None of the content constitutes investment advice. We welcome critiques and further discussions from industry peers and readers. 3. Trading Sector:Cow Protocol、Uniswap、Jupiter 3.1 Cow Protocol Current Business Status Product and Mechanism Cow Protocol is a decentralized trading aggregation protocol. Its core product is the decentralized trading aggregator, CoW Swap. The “CoW” in the name stands for Coincidence of Wants, referring to the matching mechanism that directly aligns the needs of buyers and sellers. CoW Swap uses batch auctions as a price discovery mechanism, consolidating users’ trading intentions (order demands) and settling them collectively in each block.
This mechanism allows users’ orders to be directly matched without needing traditional market makers or liquidity pools. When two parties want to exchange assets that meet each other’s needs, the transaction can be completed directly, avoiding intermediate fees. For orders that cannot be directly matched, CoW Swap routes the remaining orders to decentralized exchanges (DEXs) or other aggregators to obtain liquidity. This design minimizes slippage and fees, while batch matching ensures that all transactions executed in the same batch share the same settlement price, eliminating price unfairness due to transaction order. Additionally, CoW Swap introduces a Solver bidding mechanism: multiple third-party solvers compete to provide users with the best execution strategy, where the winner gains the right to execute the batch and also covers the on-chain gas fees. Users only need to sign their order intentions offline, without having to pay on-chain fees themselves, and incur no transaction costs if unfilled. This “intention matching + solver bidding” model enhances user experience (no need to worry about gas losses from failed transactions) and provides a degree of MEV (Maximal Extractable Value) protection—since order matching occurs off-chain, solvers must bid to return MEV to the user, making front-running and other MEV attacks less effective. CoW Swap currently operates on Ethereum, Arbitrum, Gnosis, and Base. Beyond Cow Swap, another product of Cow Protocol is MEV Blocker, developed in collaboration with CoW DAO, Beaver Build, and Agnostic Relay. By switching the wallet’s RPC to MEV Blocker, users’ transactions are routed through a private searcher network (instead of entering Ethereum’s public mempool visible to all searchers, which leads to MEV attacks), preventing sandwich and front-running attacks from the start. *The process of regular transactions on the Ethereum network being packaged into blocks: Users initiate transactions, which first enter the public mempool; searchers monitor the mempool for MEV opportunities and package transactions into bundles; builders receive bundles from searchers and construct blocks; validators receive blocks from builders, verify them, and add them to the blockchain. Revenue Model Cow Protocol’s revenue sources are broadly divided into two categories: Surplus from CoW Swap Transactions: This refers to the extra savings CoW Swap provides to users through its bidding network, compared to the initial quote. CoW Swap currently charges a fee of 50% on surpluses across most networks, but this fee does not exceed 1% of the transaction volume. Additionally, for external protocols (partners) integrated with Cow Protocol, Cow Protocol takes 15% of the transaction fees generated by these partners as a service fee, with the percentage defined by the partner but not exceeding 1% of the transaction volume. Lastly, Cow Protocol charges a fee on the total network transaction volume for certain networks like Gnosis and Arbitrum, currently set at 0.1% of the transaction volume (excluding special trades like stablecoins).Revenue from MEV Blocker: A rate of about 10% is deducted from the revenue validators earn through MEV Blocker. In the income structure of the protocol, the majority of revenue is contributed by the surplus from CoW Swap transactions, so our focus will primarily be on CoW Swap’s business data. Business Data We will focus on two key business metrics: the transaction volume of Cow Protocol and its protocol revenue. Transaction Volume
Data Source:Dune As an emerging intent matching protocol, CoW Swap has experienced rapid development over the past three years. In 2021, the protocol was still in its early stages, with small transaction volumes. Entering 2022-2023, the CoW Protocol saw its business data improve as demand for MEV protection and efficient aggregated trading grew in the DeFi space. By 2024, transaction volume increased significantly: monthly volumes hit a record high at the end of 2024, with nearly 7.8 billion in December alone and around 6.9 billion in February 2025, far exceeding previous years. Notably, CoW Swap is increasingly favored by DAOs and professional institutions for providing large, low-slippage trading solutions. In 2023, about one-third of the DAO on-chain transaction volume was completed through CoW Swap, and by February this year, this proportion had risen to 79.5%.
Data Source:Dune Protocol Revenue
Data Source:Dune After entering 2024, the Cow Protocol began actively exploring revenue generation, conducting multiple rounds of revenue testing. This resulted in a steady month-by-month increase in income. January 2025 marked the highest revenue month, with 641 ETH earned. Calculated at an average ETH price of 3,328 per month, this amounts to approximately 2.13 million. In February, revenue was 586 ETH, with an average ETH price of 2,668, bringing in 1.56 million. Protocol Incentives
Data Source: Tokenterminal Currently, Cow Protocol’s main expenses are token incentives given to network solvers. These solvers receive COW tokens as rewards based on the quality of the trading solutions they provide, specifically the surplus they generate for traders. According to Token Terminal statistics, over the past year, spending on COW token rewards was approximately 7.4 million. In January and February 2025, protocol token incentives were 858,000 and 961,000, respectively, both below the protocol′s revenues of 2.13 million and $1.56 million for the corresponding months. According to Cow Protocol’s official disclosure of the 2024 project budget in January, excluding development costs, the token rewards given to solvers amounted to about 5.2 million, while the annual protocol revenue was approximately 6 million, meaning revenue has already surpassed the token incentive expenditure. Competitive Landscape The main battlefield for Cow Protocol is the decentralized exchange aggregator sector. Initially dominated by 1inch, the landscape has diversified over the past two years. According to The Block’s latest data from March 2025 (excluding UniswapX), 1inch has lost its leading position (following a March 5th attack on its Fusion function, resulting in losses of over $5 million and increasing user concerns about its security), now ranking second with a 22.8% market share. Meanwhile, CoW Swap has taken the lead with 33.85%, marking its first time at the top in monthly data.
Data Source: The Block In addition to 1inch and CoW, the other top five aggregators include ParaSwap, 0xAPI/Matcha (an aggregation interface provided by the 0x protocol), KyberSwap, and Bebop. These competitors each hold a market share of around 10% or less. ParaSwap and 0x have a longer history and stable user base, while KyberSwap (transitioning from Kyber Network to aggregation) and Wintermute’s Bebop have recently gained incremental users. Overall, competition in the DEX aggregator space remains fierce, with new players continually emerging. Although CoW Protocol has become the new leader, its position is not yet secure. Beyond traditional aggregation products, two other noteworthy competitors are Uniswap’s UniswapX and Particle Network’s cross-chain trading platform, UniversalX. Uniswap UniswapX is a cross-platform aggregation trading feature launched by the Uniswap team in the second half of 2023. Essentially, UniswapX provides users with a similar mechanism of intent orders and fillers. Users submit offline signed orders on the Uniswap front end, and third-party “fillers” in the network can fill these orders and trade on-chain for the users. The process involves fillers providing a quote and enjoying exclusive matching rights for a short period. If the transaction isn’t completed within this time, it enters a Dutch auction phase, allowing more fillers to bid. This model is quite similar to CoW Swap’s solver bidding, both being off-chain matching and on-chain settlement solutions. Leveraging Uniswap’s brand and extensive user base, UniswapX quickly integrated into its front-end interface and went live on the Ethereum network. It’s noteworthy that there were industry accusations of UniswapX “copying” CoW Swap’s intent matching model. Critics, including Curve’s official channels, pointed out that CoW Swap had already pioneered the solver model, suggesting UniswapX was not an original innovation. Despite the controversy, UniswapX swiftly captured substantial trading volume within the Uniswap ecosystem. In early 2024, its share in the EVM aggregation trading market briefly exceeded 10% (compared to CoW Swap’s 14% at that time). However, its market share gradually declined, and according to data disclosed by Cow Protocol in March, UniswapX’s market share in aggregated trading is now around 5.5%. UniversalX UniversalX is another highly anticipated new project focusing on cross-chain aggregated trading. Launched by Particle Network, it went live on the mainnet at the end of 2024. The aim is to enable trading of assets across any chain without the need for cross-chain bridges. Its core concept is “chain abstraction,” allowing users to deposit assets from multiple chains into a unified on-chain account. Through the UniversalX platform, users can trade tokens from any chain using a unified balance, with the platform automatically handling cross-chain exchanges and settlements in the background. As a new entrant in the aggregator space, UniversalX targets the cross-chain trading niche, setting itself apart from projects like CoW Protocol, which primarily focus on single-chain aggregation. However, as the multi-chain ecosystem evolves, UniversalX could potentially become a competitor to CoW Protocol. If CoW Protocol expands to more chains or offers cross-chain capabilities, it would enter the competitive domain of UniversalX. Cow Protocol’s Competitive Advantages In the face of intense competition, Cow Protocol has been able to rise and grow steadily, and its competitive advantages can be analyzed from two aspects: product and brand. Product: Technical and Mechanism Advantages of Trading Products: Cow Swap is the first protocol to apply batch auction matching and solver competition to DEX aggregation, giving it a first-mover advantage. Its unique Coincidence of Wants matching mechanism allows direct trades without relying on traditional liquidity pools, reducing slippage and fees. The unified clearing price mechanism prevents price manipulation due to trade order, enabling heavy traders, particularly institutions, to execute at fair prices. In comparison, later approaches like UniswapX and 1inch Fusion have similar ideas but differ in implementation. For instance, CoW Swap uses sealed bidding every block, where all solutions are submitted simultaneously and executed optimally, minimizing MEV opportunities. This is considered more effective at preventing unfair practices like front-running than UniswapX’s time-limited exclusive fills and Dutch auctions.MEV Protection and Security: The combination of Cow Protocol’s trading services and MEV Blocker further enhances protection against MEV, removing user trades from Ethereum’s public mempool and allowing trusted solvers to batch them before publishing on Ethereum. This effectively reduces the risk of MEV attacks such as front-running and sandwich attacks. The protocol also imposes strict limits on the slippage and execution results of solver quotes, compressing the space for miners and searchers to extract MEV. These measures make Cow Swap one of the most user-protective trading platforms currently available, especially appealing for large trades and DAO treasury managers due to its strong MEV protection. Brand Cow Protocol, as the first to introduce batch auction matching and solver competition mechanisms, combined with its MEV-resistant features, has established a strong value proposition of safety and cost savings for traders. It has become the top choice in the minds of large traders, a preference that is unlikely to change easily. This user habit stems from the brand and reputation built on the product’s strengths, which is also the source of the protocol’s eventual profitability.
1inch’s monthly active users over the past year, Data Source:Tokenterminal
Cow Protocol’s monthly active users over the past year, Data Source:Tokenterminal Main challenges and risks Intense Competitive Environment In the fiercely competitive landscape of aggregated trading platforms, established projects like 1inch, Kyber, and DoDo are leading the charge, while new players such as Bebop, backed by Wintermute, join the fray. Additionally, products like CEX and wallets that have closer user proximity, and possess strong entry points and frontend advantages, along with chain-abstract concepts like UniversalX, are continuously exploring trading product innovations and striving for greater user penetration. Over the long term, their relationship with Cow Protocol is more competitive than collaborative. Therefore, even though Cow Protocol has currently surpassed 1inch to become the leader in market share, maintaining this position in such a high-pressure environment is challenging. It directly affects the protocol’s bargaining power with users and suppliers (solvers), creating a clear conflict between the goals of “market share” and “protocol profit.” Market Cycles A downturn in the overall market cycle will lead to a contraction in total trading volume, impacting CoW Swap’s transaction volumes significantly, which is self-explanatory. Other trading products are similarly affected, so this point will not be elaborated further. Ties to the EVMEcosystem Currently, Cow Protocol only operates within the Ethereum ecosystem. If the Ethereum ecosystem underperforms compared to other blockchains, it will naturally limit Cow Protocol’s potential for development. Uniswap, discussed later, faces a similar risk, so I won’t repeat this point. Valuation benchmark COW Token Cow has a total supply of 1 billion tokens. According to Coingecko, the current circulation rate is about 41.5%, with a projected token inflation rate of 19.61% over the next year. Currently, the primary use case for Cow tokens is governance. As protocol revenue increases, there may be token buybacks. Previously, there were attempts to reduce fees through Cow staking. Valuation Looking at Cow’s valuation over time, its FDV hit a new high in this cycle as business metrics continue to rise. Excluding the initial month’s anomalies due to extremely low token circulation, the peak market cap reached 990 million at the end of December last year but then experienced a sharp decline, now standing at approximately 280 million. We compare Cow’s Price-to-Sales (PS) ratio by analyzing the FDV in relation to protocol revenue.
The chart shows that despite Cow’s FDV maintaining an upward trajectory over the past year or so, its PS ratio has exhibited a notable decline alongside rising business revenue, making it more valuation-attractive compared to previous levels. From a horizontal comparison perspective among competitors, within comparable projects in the aggregation protocol sector, 1inch serves as the most direct counterpart. Given that 1INCH currently lacks a direct token value capture mechanism and the protocol does not generate stable, publicly disclosed protocol revenue, we primarily conduct the comparative analysis through the FDV-to-trading volume ratio between the two protocols.
From the chart, we can see that as Cow’s price decreased and business data improved, its market cap to trading volume ratio fell below that of 1inch for the first time since February 2025, offering better relative value. 3.2 Uniswap Current Business Status Core Products Uniswap is the largest decentralized exchange (DEX) on Ethereum. Its main products currently include the DEX protocol (now deployed on the Ethereum mainnet and several scaling chains) and the newly launched Unichain, a dedicated Layer 2 network. The fee switch for the Uniswap protocol hasn’t been activated yet, so the protocol itself hasn’t generated direct revenue in the past. However, Uniswap Labs does charge a 0.15% interface fee on token trades via its official front end. With the launch of Unichain in November 2024, there will be a new way to distribute value directly to UNI holders by staking UNI to share in transaction sequencer fees without needing to activate the fee switch. Business Data For Uniswap, the key business metrics are trading volume and fees. As for Unichain, we focus on the number of active addresses on the chain, the main ecosystem, and the amount of capital on the chain. DEX Trading Volume and Fees
Uniswap’s Trading Volume and Fees, Source:tokenterminal Uniswap’s trading volume has generally continued to grow with the market, hitting all-time monthly highs in March and December of the past year. However, with the market cooling recently, trading volume has noticeably declined. It’s worth noting that in this cycle, Uniswap’s fee metrics have not surpassed the peak and secondary peak of the previous cycle, indicating that the fee rates are decreasing over time, leading to more intense competition among liquidity providers (LPs). Multi-Chain Data Thanks to multi-chain deployment (currently covering 11 EVM chains), especially with Coinbase’s launch of Base, Uniswap’s active users reached a record high of 19 million last October. This growth rate in active users far outpaces the growth in trading volume, highlighting Layer 2’s ability to attract new users.
Multi-Chain Distribution of Uniswap’s Monthly Active Addresses, Source:tokenterminal Among them, Base is the main contributor to active users, accounting for 82% of Uniswap’s active users across all chains.
Source:tokenterminal However, in terms of trading volume, Ethereum remains Uniswap’s main battleground, accounting for about 62% of the volume, followed by Arbitrum with 23%, and then Base with 8.4%.
Source:tokenterminal Unichain’s Business Data Since its official launch in early February this year, Unichain has grown rapidly. By early March, the number of weekly active addresses reached nearly 120,000, ranking 7th among all L2 projects, ahead of well-known L2s like zkSync, Manta, and Scroll.
Source:tokenterminal However, the value of assets bridged on Unichain remains low, currently only around $14 million.
Source:tokenterminal In terms of the ecosystem, Unichain’s official list includes over 80 projects, but most have not yet launched. For example, in DeFi, aside from Uniswap itself, the only notable app currently live is Venus, with total deposits of $5.67 million. Competitive Landscape Over the past year, Uniswap has remained a leader in the DEX market within the EVM ecosystem, holding the top market share. However, its overall market share has been declining. The chart below shows the market share trends of all DEXs in the EVM ecosystem (including all EVM L1 and L2).
Source:Dune The second place is Pancakeswap, and the third is Aerodrome, which are the leading DEXs on Bnbchain and Base, respectively (even though Uniswap has also been deployed on these two chains).
Source:Dune ETH, Bnbchain, and Base are the three largest chains by transaction volume in the EVM ecosystem, which aligns with the market share rankings of Uniswap, Pancakeswap, and Aerodrome. As for Unichain, since it’s relatively new, its ecosystem is still quite underdeveloped and is in the early stages of application and funding. Apart from a good growth in active users, its other metrics lag significantly behind mainstream L2s. Uniswap’s Competitive Advantages Uniswap’s competitive advantages can be summarized as follows: Network Effects and Liquidity Depth The largest liquidity pools attract the most traders and vice versa. More traders and transaction volume draw more tokens to deploy liquidity here, creating a self-reinforcing cycle.Brand and User Habit Stickiness As the first project to popularize the AMM model in the DeFi space, Uniswap has unparalleled brand recognition and credibility. It holds a strong position in the minds of traders and liquidity providers. Even with a plethora of DEXs and aggregators available, many users habitually conduct transactions on Uniswap’s front-end, despite it charging an additional transaction fee. Uniswap’s brand has been instrumental in building its L2 platform, attracting many quality projects for testing and joining right from the start, with rapid user growth.Ecosystem Positioning Through Multi-Chain Deployment Uniswap has deployed its products on most major EVM chains, consistently ranking in the top three by transaction volume. This strategy has helped Uniswap maintain its foundational ground in the multi-chain era and laid the groundwork for subsequent multi-chain aggregation features, facilitating easier liquidity interchange across chains. Main challenges and risks Intense Competitive Landscape and the Impact of New Models Despite Uniswap’s relative advantage in market share, it faces significant challenges. On one hand, its traditional Ethereum competitors like Curve are holding their ground. On the other hand, Uniswap’s expansion on other EVM L1 and L2 chains is proving difficult, with strong local competitors on each chain (such as Pancake on BNB Chain, Aerodrome on Base, and Camelot on Arbitrum). Emerging trading models also pose a significant challenge: RFQ (Request-For-Quote) protocols and batch auction matching are on the rise. Projects like CoW Swap allow market makers (solvers) to quote prices directly, improving efficiency for large trades and reducing AMM slippage and MEV. This is particularly favored by professional traders and large holders, significantly diverting trading volume from Uniswap. Although Uniswap introduced a similar mechanism with UniswapX, it hasn’t slowed the growth of projects like CoW Swap. Additionally, products with strong front-end advantages, such as wallets and CEXs, are aggressively entering the trading scene, attempting to influence user behavior upstream. This potential shift relegates Uniswap to a more passive “price taker” role in a fiercely competitive pricing environment. Community Governance Inefficiency and Lack of Value Pegging for Tokens Investors who have been following the Uniswap governance forum for a long time will find that, compared to other DeFi projects with higher governance efficiency and better reputations (like Aave), Uniswap’s governance efficiency is quite low. This is specifically manifested in slow decision-making, resource wastage, and insufficient focus on strategic metrics. For example: 1. The community’s most concerned issue, the fee switch, has been discussed repeatedly for nearly three years with no result; 2. Various donations and budgets are provided for research and organizations unrelated to Uniswap’s North Star metric (trading volume), but the outcomes have been of little benefit to the project. The low level of community governance and the neglect and tardiness regarding the value pegging of Uni tokens clearly have a long-term negative impact on the tokens’ price. Valuation benchmark Since Uniswap has yet to achieve formal protocol revenue and Unichain’s fees are negligible compared to its market value, we use the ratio of Uniswap’s market value to its fees (PF) for both vertical and horizontal valuation comparisons.
Source:tokenterminal From a vertical comparison, Uniswap’s PF in February this year was 6.77, at an absolute historical low. Since the issuance of Uniswap’s token, only three months have had a lower PF: May and June of 2022 (due to the Three Arrows Capital crisis) and April 2024 (due to a major altcoin pullback and Uniswap receiving a Wells Notice from the SEC). In March, this indicator rose slightly to 7.26. From this indicator, it is evident that the market is extremely pessimistic about the prospects of the Uni token.
Source:tokenterminal For horizontal comparison, I chose Pancake and Aerodrome, both of which are DEX projects with market shares second only to Uniswap. I did not choose Curve because it has lending as a main business in addition to being a DEX, which makes it less comparable to the other three. From the PF indicators of these three, Uniswap’s valuation appears significantly higher than Pancake and Aerodrome. However, we need to consider two additional factors: Uniswap hasn’t provided any token subsidies, whereas Pancake and Aerodrome are still engaging in large-scale token subsidies. Especially Aerodrome, whose token incentives were as high as $27 million in February (See the chart below)
Uniswap also has Unichain as a second growth curve.Uniswap’s multi-chain ecosystem is better developed. Although Pancake has deployed on multiple chains, its operational performance has a significant gap compared to Uniswap, while Aerodrome is a single-chain DEX. Overall, even considering the business similarities between Uniswap, Pancake, and Aerodrome, the horizontal valuation comparison (Price-to-Fundamental) of Uniswap is less informative than the vertical comparison. 3.3 Jupiter Current Business Status Jupiter started with trade aggregation and has expanded through product development and acquisitions, creating a comprehensive ecosystem around Solana’s on-chain transactions. It is also expanding horizontally to other chains and ecosystems. The main products within the Jupiter system include: Main site self-operated trading products: These include aggregated trades (Instant), market orders (Trigger), and conditional orders (Recurring). These were Jupiter’s earliest products and remain the most widely used, with a record 57 million trades in a single day on January 20th.
Source: Dune The main site’s Trenches product, formerly known as Ape.pro, was initially a specialized tool for memes, similar to products like Phonton/GMGN. However, after being integrated into Trenches in late February, its product format became much like Jupiter’s aggregated trading offerings.The main site’s Perps product operates similarly to GMX, providing leveraged long and short positions, as well as yield farming for BTC, ETH, and SOL. The TVL for this segment peaked at over 2 billion, making it a major component of Jupiter′s TVL. During peak times, the average daily trading volume was close to 1 billion, serving as Jupiter’s primary cash flow business in its early stages.
Jupiter Derivatives Exchange’s TVL (left axis) and Trading Volume (right axis) Source: DeFillama These can be considered Jupiter’s main products at present. In addition, the Jupiter ecosystem also includes the following products: The meme trading platform Moonshot. In January 2025, Jupiter announced the acquisition of a majority stake in Moonshot, a rapidly emerging meme trading platform in the past six months. Moonshot has attracted numerous users with its seamless fiat deposit system and smooth trading process, creating a “Moonshot effect,” especially during the launch of TRUMP, which was particularly popular.
Trading Volume of Moonshot (Left Axis) and Fees (Right Axis) Source:Dune The liquidity platform Meteora. Founded by one of Jupiter’s early co-founders, Ben Chow, Meteora is considered an important part of the Jupiter ecosystem, despite not having a clear control relationship with Jupiter. Meteora plans to issue its own token, and while it belongs to the Jupiter ecosystem, its connection with the JUP token is relatively indirect.The LST product jupSOL quickly captured a significant market share after its launch in 2024. Currently, jupSOL ranks fourth after jitoSOL, bnSOL, and mSOL.
Solana LST Market Share (Top Gray Block Represents jupSOL) Source: Dune Launchpad LFG: Besides the JUP token itself, LFG launched several projects in 2024, including the governance token ZEUS for the cross-chain communication protocol Zeus, the governance token CLOUD for the LST protocol Sanctum, and the governance token DBR for the cross-chain protocol Debridge, along with other meme projects. Although there are fewer projects launched, the quality is relatively high.Investment Portfolio Management Platform Jupiter Portfolio: In January, Jupiter announced the acquisition of the on-chain portfolio tracker Sonarwatch and officially launched Jupiter Portfolio on January 30th.Mobile Wallet Jupiter Mobile: After acquiring Solana’s mobile wallet Ultimate Wallet, Jupiter introduced its mobile wallet.Cross-Chain Network Jupnet: Launched at the end of January this year, Jupnet aims to allow access to all chains, currencies, and assets with one account. However, it does not yet have a user-friendly version for end consumers.Trading Terminal Coinhall: Acquired by Jupiter in September 2024, Coinhall primarily facilitates the trading of Cosmos ecosystem tokens. Through this acquisition, Jupiter gained the capability to build its own trading terminal, which is utilized in its Trenches product. Currently, on-chain trading of Cosmos ecosystem tokens is not very frequent, with daily trading volumes below $10 million.
Source: Coinhall Official Website In addition to the consumer-facing products mentioned, Jupiter has also been active in other areas, such as acquiring Solana’s browser, SolanaFM. They are developing a variety of products, including the cross-chain network Jupnet. From a product layout perspective, Jupiter, as the largest consumer gateway on Solana, covers nearly all business directions except for lending. Even in Solana’s diversified business environment, Jupiter’s reach is extensive. Beyond their own operations, they aggressively expand their business boundaries through acquisitions. Revenue Model Currently, Jupiter’s revenue-generating services include: Aggregated trading services (including Trenches) with fees ranging from 0.05% to 0.1%; spot orders and DCA orders have a fee of 0.1%.Derivatives services are based on GMX’s mechanism. The main fees come from a 0.06% charge when opening and closing positions, as well as borrowing fees, price impact fees, etc. However, not all the derivatives fees go to JupiterDAO; 75% of the fees are allocated to liquidity providers (JLP), and the remaining 25% is taken by JupiterDAO. Other services are offered without fees. Token Incentives Jupiter does not have a regular token incentive program. Its main incentives come from two rounds of retrospective airdrops. Competitive Landscape Trading is the core service offered by Jupiter. Other services like LST, Launchpad, and wallet can be seen as ways to leverage traffic brought in by trading. Therefore, we’ll focus on analyzing Jupiter’s competitive situation in aggregated and derivative trading. Aggregated Trading In the competitive landscape of Solana trading entry points, Jupiter quickly surpassed Orca and Raydium in the first half of 2024, thanks to its multi-liquidity pool routing capabilities and excellent user experience. By Q2 2024, Jupiter held a dominant position, accounting for 51% of Solana’s trading volume (source: Messari)。 However, with the rise of meme tokens and platforms like Pump.fun, specialized meme trading tools such as Photon, Trojan, Bullx, and GMGN rapidly encroached on Jupiter’s market share. These platforms offered faster trading speeds and comprehensive meme trading support, becoming the preferred “meme trading gateways.” In response, Jupiter launched a similar tool, ape.pro, in October last year, but it failed to gain traction and was eventually integrated into the main site’s Trenches product. As a result, Jupiter’s share of Solana’s trading volume dropped to 38% by Q5 2024 (source: Messari) During the meme frenzy, meme trading accounted for 90% of Solana’s network volume. The loss of market share in meme trading gateways is Jupiter’s biggest challenge in the realm of aggregated trading. Derivatives Trading Jupiter’s derivatives exchange is currently the second-largest on-chain derivatives platform, with trading volume second only to Hyperliquid, which we’ll discuss in the next section. Specifically on the Solana chain, Jupiter has a clear advantage over its main competitor, Drift, with its trading volume being roughly 5 to 10 times that of Drift recently.
Ranking of 7-Day Derivatives Exchange Trading Volume Source:DeFillama Looking at DAU, the gap between the two over the past month is also roughly an order of magnitude.
Data Source: Dune In the derivatives trading field, Jupiter’s position on the Solana network is difficult to shake in the short term. Main challenges and risks Despite launching Jupnet to expand cross-chain operations, Jupiter’s core business currently remains on Solana. The biggest uncertainty for Jupiter is whether the Solana network can maintain its prosperity and active on-chain trading. In addition to the aforementioned challenges related to the Meme trading entry competition, other challenges and risks Jupiter faces include: Overly Aggressive Expansion, Effectiveness in Doubt Jupiter’s expansion strategy is much more aggressive than most Web3 projects, with ambitious business ideas that have led to frequent acquisitions over the past year to broaden its scope. However, many of these acquisitions have not achieved the expected results, such as the acquisitions of Moonshot and Coinhall. At its peak, Moonshot had a daily trading volume of 660 million and generated revenues of tens of millions of dollars. Currently, the daily trading volume has dropped to less than 5 million, with revenue not exceeding $10,000. Although Jupiter has not disclosed the acquisition costs or payment details, it’s clear that acquiring Moonshot today would be less expensive for JUP token holders.
Trading Volume of Moonshot (left axis) and Fees (right axis) Source:Dune The acquisition of Coinhall helped Jupiter build its meme trading product, Trenches. However, in terms of both trading volume and market presence, Trenches still lags significantly behind leading meme trading products like Photon, Bullx, Trojan, and GMGN. No Proprietary Liquidity Pool Jupiter does not have its own liquidity pool. Its supported platform, Metrora, has started a rewards program and plans to launch an independent token issuance. This means that JupiterDAO, or the JUP token, cannot capture trading fees from the “token trading in liquidity pools” step, fees that have contributed to Raydium’s revenue of over $22 million this past January. Untested by Bear Market In a bear market, many assumptions taken for granted during a bull run might be challenged. For example, users trading memes on the Solana chain currently seem willing to pay Jupiter’s 0.05% fee, as competitor meme tools charge between 0.5% to 1%. However, if trading enthusiasm declines during a bear market, users might become more sensitive to transaction fees, putting Jupiter in a conflict between “market share” and “net profit” objectives. Moreover, Jupiter’s product lineup includes a wallet, the cross-chain network Jupnet, and the portfolio management tool Jupiter Portfolio—all of which are unlikely to generate significant short-term revenue. Maintaining such an extensive product line during a bear market raises significant questions. Valuation benchmark JUP has a total supply of 10 billion, with 3 billion tokens burned following a vote at the end of January, leaving a maximum of 7 billion tokens in circulation. Currently, 2.63 billion are circulating, representing a 38.5% circulation rate. Among the non-circulating tokens, 810 million team tokens will begin vesting over the next 21 months. Additionally, 700 million tokens will be released in a Jupiter airdrop in January next year. With an inflation rate exceeding 40% over the next year, JUP remains a low-circulation, high-inflation token.
Current distribution of JUP tokens, Source:Jupiter Governance Forum At the end of January, Jupiter announced that 50% of its protocol revenue will be used to buy back JUP, with purchased JUP being locked for three years. The chart below, sourced from DeFiLlama, shows Jupiter’s protocol revenue since last October. Note that unusual values for Jupiter’s aggregator revenue on February 10th and March 10th may contain errors; however, I couldn’t find alternative data sources for Jupiter’s revenue. It’s evident that Jupiter’s main income currently comes from derivatives trading (blue bars), which is partly due to the significant decline in meme trading enthusiasm since the introduction of fees by the Jupiter aggregator.
Source:DeFillama Since Jupiter just completed a significant economic model update at the end of January, introducing a transaction fee of 0.05%-0.1%, the P/S data for February and March are more relevant. According to data collected by DeFiLlama, Jupiter’s revenue for February was 31.7 million, with an annualized revenue of 380 million. This corresponds to a P/S (circulating) of 3.65 and a P/S (fully diluted) of 9.5. As of March 18th, the revenue was 12.25 million, translating to an annualized revenue of 253 million, with a P/S (circulating) of 5.45 and a P/S (fully diluted) of 14.15.
Source:DeFillama Whether comparing horizontally with CoW Swap or vertically with Jupiter itself, the current valuation of JUP seems relatively low. Of course, these figures are based on the recent popularity of Solana. As Solana’s hype potentially decreases in a bear market, maintaining such high revenue will be challenging. We’ve already observed this trend when comparing data from March to February.
Mint Venturesの研究者、Lawrence Leeによる 2回の連続資金調達ラウンドを確保した後、Polychainが主導する1200万ドルの投資やBinance Labsからの資金調達を受けて、SolanaチェーンのリステーキングプロジェクトであるSolayerは最近DeFiの空間で数少ないハイライトの1つとなっています。そのTVLは着実に増加しており、現在Orcaを超えてSolanaチェーンで12位にランクインしています。
Mint Ventures のリサーチ パートナー Alex Xu 氏と Mint Ventures の研究者 Lawrence Lee 氏による記事 導入 仮想通貨業界で最も成熟したセクターの1つであるにもかかわらず、DeFiプロジェクトは今回の強気相場で期待外れのパフォーマンスを見せている。過去1年間で、DeFiセクターは41.3%の緩やかな増加を記録しており、市場平均の91%の成長やイーサリアムの75.8%の上昇に大きく遅れをとっている。