a16z Crypto: A New Approach for Financial Institutions to Go On-Chain

Financial institutions are increasingly debating the suitability of permissionless versus permissioned blockchain networks for tokenized assets. While firms like Franklin Templeton, BlackRock, and Apollo have already deployed products on public chains like Solana and Ethereum, many institutions remain hesitant due to perceived compliance risks. A new industry paper argues that permissionless networks are compatible with existing financial regulations, including the Bank Secrecy Act and sanctions laws. Regulators like FinCEN and OFAC emphasize a risk-based approach rather than a zero-tolerance standard, focusing on systemic controls rather than isolated errors. The paper suggests that institutions should treat permissionless infrastructure similarly to the public internet or telephone networks. Furthermore, the OCC has provided legal clarity through Interpretive Letter 1186, confirming that banks can pay network fees and hold cryptocurrencies for operational purposes. This shift in perspective is critical for the RWA market, as it removes a major barrier to institutional adoption of public blockchain rails.