The new collateral framework developed by Anchorage Digital, Kamino and Solana Company enables borrowing against staked SOL while the underlying assets remain in qualified custody at a federally regulated crypto bank. This architecture provides a test case for how regulated entities can access decentralized credit markets without surrendering control of assets to smart contracts. It arrives as U.S. policymakers continue to debate the scope of DeFi oversight under the still‑unresolved CLARITY Act, and as other jurisdictions, including the UK and Brazil, refine definitions of control, custody and reporting duties. The structure therefore offers insights into how onchain credit markets may adapt to institutional governance, risk and regulatory constraints.
Context and Background
The integration links Anchorage’s Atlas collateral management system with Kamino’s Solana‑based lending markets, allowing institutions to borrow against natively staked SOL while earning staking rewards. The assets remain under segregated, qualified custody at Anchorage Digital Bank, which manages margin requirements and potential liquidations.
This operational design is emerging while regulatory discussions remain unsettled. U.S. lawmakers are negotiating the CLARITY Act, which seeks to clarify jurisdiction over digital assets and DeFi arrangements. Meanwhile, the UK FCA is finalizing its own digital asset regime. Industry groups have urged the FCA to limit regulatory obligations to cases involving unilateral control, noting that extending trading platform, prudential and money‑laundering rules to automated protocols would be structurally incompatible with non‑custodial systems.
Brazil, in parallel, has implemented a comprehensive SPSAV regime with mandatory segregation of client assets, monthly disclosures and biennial independent audits, signaling a global trend toward more formalized governance and reporting for digital asset activity.
Market Impact Assessment
The Anchorage–Kamino structure addresses a long‑standing barrier for regulated entities: transferring collateral out of custody into smart contracts. By retaining custody while enabling onchain credit creation, this model reduces operational friction and aligns with internal asset‑control policies common to banks, asset managers and corporates.
Its timing coincides with significant increases in onchain transactional throughput. Infrastructure improvements, including Solana‑related optimizations that have delivered 5x faster processing, combined with custody and operational tooling that has secured more than $10 trillion in transactions across over 120 blockchains, signal that institutional workflows are increasingly scalable. Stablecoin settlement activity, which grew 300% year‑over‑year with over $200 billion processed monthly in 2025, further demonstrates demand for high‑frequency, credit‑linked liquidity operations.
While Solana Company’s 2.3 million SOL treasury is a meaningful early mover, broader institutional uptake will depend on credit pricing, margin stability and the perceived resilience of the collateral‑management interface during stress periods.
Regulatory and Compliance View
Anchoring collateral in regulated custody directly addresses supervisory expectations around asset control, auditability and liquidation governance. For U.S. entities, keeping assets with a federally chartered bank simplifies compliance reporting and avoids triggering interpretive questions that may arise if assets were placed directly into smart contracts with no intermediary oversight.
The regulatory significance of this model extends to jurisdictions evaluating whether DeFi protocols constitute intermediaries. The FCA’s evolving framework could impose trading platform, prudential and anti‑money‑laundering obligations on non‑custodial mechanisms. Industry responses have emphasized that regulatory duties should apply when a party has unilateral authority over user assets or transactions. The Anchorage–Kamino model creates a clear control point, making compliance classification more straightforward.
Brazil’s SPSAV rules illustrate how digital‑asset reporting is converging globally toward segregation, periodic audits and transparent disclosures. Monthly public reporting and two‑year audit cycles mandate consistent data‑quality and reconciliation standards, which similar structures may need to emulate for cross‑border interoperability.
Product and Structuring Implications
The design enables a hybrid credit product: fully custodial collateral with decentralized execution for borrowing. Key structuring implications include:
- Collateral remains in segregated custody, meeting common institutional mandates.
- Staking rewards continue to accrue, allowing borrowers to maintain baseline yield.
- Loan‑to‑value calibration relies on real‑time monitoring within the custodian’s risk engine.
- Distribution is likely limited to entities with established custody relationships and risk‑management infrastructure capable of integrating onchain execution flows.
Investor suitability frameworks will need to consider whether borrowers understand liquidation mechanics that occur at the protocol level while control of assets remains with a custodian.
Risk Considerations
Market and Liquidity Risk: Volatility in SOL prices and liquidity conditions on Kamino may lead to rapid shifts in collateralization. Clear thresholds and pre‑agreed liquidation protocols reduce uncertainty but do not eliminate execution risk.
Counterparty and Credit Risk: The custodian’s role as collateral manager concentrates operational responsibility. If the execution bridge between Anchorage and Kamino experiences delays, mismatches between expected and actual liquidation timing may occur.
Operational and Cybersecurity Risk: Elevated digital‑asset security concerns remain material. Hackers stole over $3.4 billion in 2025, with total theft exceeding $17 billion since 2020. DPRK‑linked actors accounted for more than $2 billion last year, with the Lazarus Group responsible for three‑quarters of attacks on crypto platforms. Ensuring robust defense‑in‑depth controls and continuous monitoring across API touchpoints between custody and protocol components is essential.
Legal and Regulatory Risk: Pending U.S. legislation introduces interpretive uncertainty. Should the CLARITY Act adopt an expansive view of protocol‑level responsibility, hybrid custodial‑onchain models may be treated differently depending on which functions are deemed intermediated.
Implementation and Operating Model Notes
Integration with Anchorage’s Atlas system means institutions must align internal collateral‑management processes with the custodian’s monitoring and liquidation logic. Key considerations include:
- Real‑time data synchronization between custody records and onchain lending positions.
- Maintenance of audit‑ready transaction logs in line with emerging reporting requirements such as those under MiCA and the GENIUS Act, both of which require accurate reconciliation and tax‑compliant disclosures.
- Embedding crypto‑accounting and reconciliation tooling, a capability strengthened by industry adoption of specialized platforms supporting hundreds of clients.
- Stress‑testing workflows using scenarios that reflect infrastructure surges similar to those seen in February and October 2025.
Forward View
The Anchorage–Kamino model is likely to influence how custodians, credit protocols and treasuries design interoperable frameworks that respect regulatory expectations while enabling capital efficiency. Its relevance will increase if policymakers adopt control‑based regulatory tests, distinguishing between custody, governance and automated infrastructure.
Future market development will depend on whether similar structures are extended to other staked assets and whether margin‑management interoperability becomes standardized across chains. As reporting and audit requirements proliferate, the operational burden will favor institutions with integrated data, accounting and risk‑management systems capable of supporting hybrid onchain‑offchain credit exposures.
