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Solana Policy Institute, Superstate, and Orca seek SEC approval for securities trading on public blockchains

April 30, 2025
in Regulations
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Solana Policy Institute, Superstate, and Orca seek SEC approval for securities trading on public blockchains
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A coalition led by the Solana Policy Institute, decentralized exchange Orca, and registered investment adviser Superstate has filed a request with the US Securities and Exchange Commission (SEC) to launch a pilot program for the issuance and secondary trading of securities on public blockchains. 

The April 30 filing proposes that the SEC grant exemptive relief to facilitate the project, named “Project Open,” under existing regulatory frameworks.

The initiative would allow US entities to issue securities on public blockchain networks and permit investors to trade those securities through compliant interfaces. Orca would serve as the venue for secondary transactions. 

Solana Policy Institute CEO Miller Whitehouse-Levine said: 

“Project Open is an embodiment of American progress in financial innovation. Our goal is to work constructively with the SEC and industry partners to create internet capital markets, and make all capital markets more efficient, accessible, and transparent.”

Superstate would issue the securities, while the Solana Policy Institute would coordinate technical and regulatory engagement.

The filing is structured as a time-limited pilot under SEC Rules 5b-3 and 15c3-3, requesting regulatory relief to design and operate a market structure compatible with existing investor protection rules while utilizing blockchain settlement layers. 

The sponsors aim to demonstrate that publicly accessible blockchains can support transparent and compliant markets for traditional securities.

Project Open

The proposal would allow the issuance of tokens to represent securities on a public blockchain, like Solana (SOL), allowing for programmable compliance features and settlement mechanisms. 

The securities would be available to eligible investors through interfaces governed by know-your-customer (KYC) and anti-money laundering (AML) requirements.

Orca would provide the liquidity venue and price discovery, while Superstate, already operating under an SEC-registered investment advisor (RIA) structure, would serve as the issuer. The pilot proposes a measured scope, targeting limited asset types and capped transaction volumes. 

It seeks to evaluate the feasibility of public blockchain infrastructure as an alternative to existing clearing and settlement systems such as DTCC, with a focus on regulatory auditability, transparency, and operational resilience.

The coalition seeks no-action relief or exemption orders from the SEC’s Divisions of Trading and Markets and Investment Management. 

The petition also outlines legal arguments asserting that the pilot would remain within the bounds of the Investment Company Act and Exchange Act, given its narrow structure and oversight features.

Regulatory engagement amid market evolution

The filing arrives at a time when the SEC is increasing its engagement with tokenization and blockchain-based infrastructure. 

Project Open explicitly calls for the use of public, decentralized blockchain infrastructure. The sponsors argue that public chains offer verifiable audit trails, open access to market data, and lower barriers to entry for issuers and intermediaries, aligning with the SEC’s long-term goals for transparency and investor protection.

The pilot would also provide empirical data on investor behavior, system performance, and compliance monitoring in a blockchain-native environment, which would inform future policymaking. 

The filing includes technical documentation detailing the cryptographic settlement model, token standards, and access controls to support supervisory visibility and enforce compliance.

The SEC has not issued a formal response, and there is no current timeline for a decision.

If approved, the Project Open pilot would represent one of the first SEC-sanctioned efforts to operationalize securities trading directly on a public blockchain with a registered asset manager and decentralized exchange as counterparties.

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