Weekly · Tokenization, personnel changes, and regulatory shifts · September 20–26, 2026

Key points

Tokenized finance infrastructure

On September 21, the ECB announced plans to invest part of its own funds in tokenized securities with settlement through the Pontes platform. On the same day, the Eurosystem stated that it would bring central bank money into the tokenized financial environment. These steps made the issue of tokenization infrastructure more concrete for issuers and market infrastructure providers.

In parallel, regulatory changes in the US are also aimed at developing this segment. On September 22, the US Securities and Exchange Commission (SEC) issued an order granting temporary conditional relief from the definitions of "exchange" and "dealer" for certain trading venues on distributed ledgers (DLT) and liquidity providers for tokenized NMS stocks. On September 23, Coinbase Derivatives LLC filed a proposal with the SEC to amend rules for cash-settled futures on individual stocks and ETFs, including perpetual futures on individual stocks, which received immediate effectiveness. On September 24, the company filed another proposal regarding margin requirements for clients in securities futures.

In Europe, oversight of this process is also being strengthened. On September 23, ESMA announced a new EU strategic supervisory priority for 2027 dedicated to digital innovation, with an initial focus on the use of artificial intelligence and tokenization by supervised entities. This means that the implementation of tokenized instruments will occur under the close scrutiny of national competent authorities and ESMA.

Personnel and monetary decisions

On September 24, ECB Executive Board member Isabel Schnabel announced her intention to leave her position at the ECB to move to a leadership role at the IMF. This event changes the composition of the Executive Board and links a senior ECB representative with the IMF, which may affect the bank's institutional trajectory and communication.

On the same day, the Swiss National Bank (SNB) kept its key rate unchanged at 0%, maintaining a 0.25 percentage point discount for demand deposits above the threshold. The SNB confirmed its readiness to act in the currency market as needed, despite further inflation growth since June, driven primarily by energy prices. The decision confirmed that the bank is not tightening policy, keeping currency interventions as a tool.

ECB communication activity was also high. Executive Board member Philip Lane gave an interview to the Swiss newspaper Le Temps on September 22, and delivered two speeches on the outlook for the eurozone economy on September 23 and 24. These speeches followed Schnabel's departure announcement and, together with the SNB decision, form a picture of monetary expectations in Europe.

Corporate governance and sanctions

On September 21, the US SEC proposed repealing Rule 14a-8 under the Securities Exchange Act of 1934 and amending Rule 14a-4, expanding companies' discretionary powers regarding voting on shareholder proposals not included in proxy materials. The proposal shifts the focus in determining the fate of shareholder proposals toward state law and corporate documents, providing shareholders with the right to waive discretionary voting on individual stocks.

In the sanctions sphere, OFAC published several updates. On September 23, two general licenses related to Iran (GL Y and Z) and General License GL 2 for sanctions against the Democratic Republic of Congo were published. On September 25, OFAC amended the Sanctions Regulations on State Sponsors of Terrorism, removing and reserving a specific general license for Syria after its removal from the list of state sponsors of terrorism. On the same day, new penalty rules were added, consolidating information on fines from various OFAC sanctions programs.

What this means

This week's events indicate an acceleration in the institutionalization of tokenized finance. If you participate in securities or payment infrastructure markets, the ECB's and SEC's transition to practical steps (investments, rule exemptions) signals that tokenization is moving from the experimentation stage to regulated operational activity. ESMA's oversight from 2027 adds a layer of requirements for AI and tokenization risk management, which will require a review of product architecture and compliance processes.

Personnel changes at the ECB and the stability of the SNB rate create a mixed backdrop for currency and interest rate risks. If you have exposure to the euro or the Swiss franc, Schnabel's departure may change the tone of ECB communication, while the SNB maintains the status quo, relying on the currency market. Watch for announcements regarding the ECB successor appointment and subsequent inflation statements: if ECB rhetoric becomes more hawkish and the SNB continues to ignore inflation signals, monetary policy divergence may increase volatility in currency pairs.

In corporate governance, the SEC's proposal on Rule 14a-8 implies a potential weakening of federal regulation of shareholder rights in favor of corporate documents. If you manage portfolios with US stocks, expect changes in engagement and voting mechanisms with companies. The repeal or adoption of this proposal will change the balance of power between management and shareholders.

In the sanctions sphere, the consolidation of OFAC penalty rules and changes regarding Syria simplify navigation of the regulatory framework but require updating internal lists and screening procedures. If your business interacts with regions affected by sanctions, review assumptions about the applicability of general licenses, especially in the context of Iran and the Democratic Republic of Congo.

Under the radar

Despite major news, it is worth noting technical OFAC updates that may go unnoticed but have operational significance. The publication of general licenses for Iran and the Democratic Republic of Congo, which were previously available only on the website, and the removal of the license for Syria formalize the current status of sanctions regimes. Consolidating penalty rules into a single document simplifies risk analysis but requires verifying that internal penalty recording systems correctly interpret new references. These changes do not add new prohibitions but clarify legal certainty for existing operations.

Our read

The period is characterized by increased institutional support for tokenized finance, shifting the balance toward the development of new market infrastructures while simultaneously increasing supervisory attention. On the axis of tightening versus easing obligations, a mixed picture is observed: the SEC proposes to ease certain aspects of corporate governance (repeal of Rule 14a-8), but at the same time creates temporary frameworks for new DLT venues, and ESMA announces new supervisory priorities for 2027. On the axis of convergence versus fragmentation, ECB and SEC actions proceed in parallel toward legitimizing tokenization, indicating global convergence regarding the technology, although regulatory mechanisms differ. The intensity of oversight is growing: the transition from pilot projects to ECB own-fund investments and ESMA plans signals a shift to a phase of active control. A counterargument is the temporary nature of SEC exemptions and the absence of immediate sanctions, which leaves room for adaptation. An observable indicator of a turnaround will be the publication of detailed ESMA guidelines on AI and tokenization or the final adoption by the SEC of rules regarding Rule 14a-8. The overall signal is mixed: infrastructure is developing, but regulatory uncertainty persists until specific technical standards and decisions on ECB personnel appointments are released.

This digest was produced automatically by a large-language-model system from the regulator publications and official sources listed below; it is AI-generated content and may contain inaccuracies. It is not legal advice — verify wording and deadlines against the original documents.

Sources