A Year of Change Across Financial Regulation – and What Comes Next, December 2025 – SEC Staff Issues No-Action Relief for DTC Tokenization Pilot

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On December 11, 2025, the staff of the SEC’s Division of Trading and Markets issued a no-action letter (the “DTCC No-Action Letter”) stating that it would not recommend enforcement action against The Depository Trust Company (“DTC”) in connection with the launch of a pilot version of its DTCC Tokenization Services. The relief permits DTC to operate a preliminary tokenization program that records participants’ security entitlements using distributed ledger technology, rather than exclusively…
By: Cadwalader, Wickersham & Taft LLP
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