TL;DR: On-Chain Treasuries in 5 Points
- Three products dominate: BlackRock BUIDL ($2.5B, $5M minimum, institutions), Ondo USDY ($620M, $500 minimum, non-U.S.), Franklin BENJI ($780M, no minimum, widest access)
- The value prop: Mid-single-digit Treasury yields + 24/7 trading + instant settlement + DeFi composability. Not higher returns—better infrastructure.
- Real adoption: Binance/Crypto.com accept BUIDL as collateral. MakerDAO allocating $1B. Market grew 539% in 2024 to $5.5B.
- The catch: Even "risk-free" Treasuries become risky when wrapped in smart contracts, novel legal structures, and thin secondary markets. You're stacking new risks on top of the base asset.
- Bottom line: This is infrastructure maturing, not speculation. If you're holding idle stablecoins or managing protocol treasuries, tokenized Ts are now table-stakes for yield optimization.
Who this is for: DAO treasury managers, institutional allocators exploring on-chain, DeFi protocols needing stable collateral, and crypto investors with $500-$5M+ seeking regulated yield.
Next step: See The Rise of Tokenized Real-World Assets for the broader tokenization landscape, or jump to the comparison table below to evaluate which product fits your needs.
The New On-Chain Safe Haven
Traditional finance has long relied on U.S. Treasury securities as the "risk-free rate"—the foundational benchmark against which all other investments are measured. Yet until recently, crypto markets operated in a parallel universe where no such benchmark existed. Investors seeking stable yield faced a choice: exit to fiat banking systems or accept zero-interest stablecoins with credit risk.
That changed in 2024. The tokenized U.S. Treasury market surged to $5.5 billion—a 539% increase from $769 million twelve months prior. This isn't speculation; it's systematic integration of the safest traditional asset into blockchain infrastructure, creating an on-chain risk-free rate accessible to institutions and retail investors alike.
What are tokenized Treasuries? Digital tokens representing fractional ownership in funds holding short-term U.S. government debt—typically T-Bills under one year, overnight repos, and cash equivalents. Each token equals a fund share, enabling holders to transfer and utilize these instruments with blockchain's programmability and instant settlement.
The value proposition: Instant settlement (vs. T+2 traditional), 24/7 global trading, fractional ownership eliminating large minimums, and DeFi integration as yield-bearing collateral. You're not getting better yields than direct Treasury ownership—you're getting better infrastructure for accessing those yields on-chain.
Three products dominate: BlackRock's $2.5B BUIDL (March 2024 launch), Ondo Finance's $620M USDY (February 2024), and Franklin Templeton's $780M BENJI (operational since 2021). They collectively control 75%+ of the market but serve radically different investor segments with distinct regulatory frameworks and access requirements.
Deep Dive: Major Players Compared
The three market leaders differ fundamentally in structure, creating clear segmentation by investor type. The comprehensive table below captures these distinctions—subsequent sections drill into specific dimensions without re-describing entire products.
| Product | Issuer/Structure | Underlying Assets | Yield Mechanism | Target Audience | Minimum Investment | Liquidity & Settlement |
|---|---|---|---|---|---|---|
| BlackRock BUIDL | BlackRock + Securitize BVI-domiciled fund BNY Mellon custody | 100% cash, U.S. Treasury Bills, overnight repos | Monthly dividend airdrop to investor wallets. ~4% annual yield as of late 2024. | U.S. Qualified Purchasers, institutional investors, protocol treasuries | $5,000,000 | 24/7 instant USDC redemption via Circle for approved users. Secondary peer-to-peer transfers enabled. T+1 primary redemption. |
| Ondo USDY | Ondo Finance Bankruptcy-remote SPV Ankura Trust custody | Short-term U.S. Treasuries and bank demand deposits | Continuous value accrual (USDY price increases) or rebasing (rUSDY token count increases at $1.00). ~4.25% APY as of late 2024. | Non-U.S. individual and institutional investors (Reg S exemption) | $500 | 40-50 day minting delay after deposit. Interest accrues immediately. Redemption via wire to non-U.S. banks. Secondary DEX trading available. |
| Franklin BENJI | Franklin Templeton SEC-registered fund (1940 Act) Independent transfer agent | U.S. government securities, cash, repurchase agreements | Daily dividend reinvestment increasing NAV per token. ~5.25% annual yield as of mid-2024. | Institutional and retail (via Benji Investments app), multiple jurisdictions | No stated minimum (app accessible) | Peer-to-peer transfers enabled since April 2024. USDC conversion via app. Fund redemption follows standard procedures. 24/7 on-chain trading. |
Yield Structures and Current Returns
As shown in the table above, all three products derive yield from short-term U.S. government debt yielding mid-single digits (4-5% range as of late 2024). The distribution mechanics differ significantly:
BUIDL (Monthly Dividend Airdrop):
- Last business day of each month, fund airdrops proportional BUIDL tokens to wallets
- $7M cumulative dividends since March 2024 launch
- Current yield ~4% annually net of 0.2-0.5% management fees (varies by blockchain)
- Dividends arrive as additional BUIDL maintaining $1.00 per token value
USDY (Continuous Value Accrual):
- Token price increases daily reflecting accumulated interest (~4.25% APY)
- No explicit management fee—Ondo monetizes via 40-50 day minting delay
- Alternative: rUSDY maintains $1.00 with token count increasing (rebasing)
- 1,000 USDY at $1.00 → $1,042.50 value after one year | 1,000 rUSDY → 1,042.5 tokens
BENJI (Daily Reinvestment):
- Daily dividends automatically reinvest, increasing NAV per token
- Current yield ~5.25% annually net of ~15 bps fund expenses
- Higher relative yield likely reflects Franklin's $1.6T+ scale advantages
- SEC 1940 Act registration provides institutional reporting transparency
For DAO treasuries: Monthly dividends (BUIDL) simplify accounting. Continuous accrual (USDY) compounds automatically without transactions.
For DeFi protocols: Rebasing (rUSDY) maintains $1.00 pricing for oracle integration. Standard tokens require price feed infrastructure.
For retail: You're not getting higher yields than direct T-Bills—you're paying 0.15-0.5% in fees for 24/7 accessibility and blockchain infrastructure.
Critical Disclaimer: Yield figures reflect late 2024 Fed policy and will fluctuate with short-term Treasury rates. Management fees, blockchain transaction costs, and tax treatment vary by product and investor circumstances. Historical yields do not predict future returns. Tax note: In many jurisdictions, tokenized Treasury distributions are taxed similarly to money market fund interest income, but treatment may differ from direct T-Bill ownership. Consult a tax professional regarding your specific situation. Nothing here constitutes investment advice—consult a financial professional before allocating capital.
Liquidity Structures: Primary vs. Secondary Markets
The distinction between primary market redemption (directly with the fund issuer) and secondary market trading (peer-to-peer transfers or DEX swaps) determines practical liquidity for tokenized Treasury holders. Unlike traditional money market funds offering same-day NAV-based redemption, tokenized products introduce blockchain-specific settlement mechanisms creating both opportunities and constraints.
BUIDL pioneered instant liquidity integration through partnership with Circle, enabling approved investors to swap BUIDL tokens for USDC at $1.00 per token 24/7 with near-instant settlement. This "liquidity backstop" removes the multi-day settlement delays traditional funds impose, providing money market-like accessibility while maintaining on-chain custody. Additionally, BUIDL supports peer-to-peer transfers between whitelisted wallets on all supported blockchains (Ethereum, Arbitrum, Optimism, Polygon, Avalanche, Aptos, BNB Chain), enabling secondary market development. However, primary redemptions to fiat currency still require T+1 settlement through standard fund procedures following investor requests.
USDY faces the most restrictive primary market access due to U.S. securities regulations governing offshore offerings to non-U.S. persons. Investors deposit USDC (or USD via wire for $100K+ amounts) and receive temporary certificates entitling them to USDY tokens deliverable 40-50 days later—the delay ensures compliance with Securities Act registration requirements. Interest accrual begins immediately upon fund receipt of capital, partially compensating for the illiquidity period. Redemptions require wire transfer to non-U.S. bank accounts with similar processing delays. However, USDY's secondary market trading provides more liquidity than primary redemptions, with tokens tradable on decentralized exchanges across Ethereum, Arbitrum, Solana, and other supported chains. Trading volumes remain modest ($200-300K daily as of late 2024) limiting price efficiency for large transactions.
BENJI enabled peer-to-peer transfers in April 2024 after operating as a transfer-restricted fund for three years. This upgrade allows token holders to send BENJI to other whitelisted investors' wallets across nine blockchains (Stellar, Ethereum, Polygon, Arbitrum, Avalanche, Base, Solana, Aptos, VeChain), creating secondary market functionality. Franklin Templeton additionally provides USDC conversion capability within the Benji Investments mobile app, enabling users to fund purchases via stablecoin rather than bank wire. Primary redemptions follow traditional mutual fund procedures—investors submit redemption requests, the fund processes at next NAV calculation, and proceeds distribute via wire transfer within standard settlement windows.
Regulatory Frameworks and Compliance Structures
The legal and regulatory architecture underpinning each product determines eligible investor populations, custodial requirements, reporting obligations, and investor protections—factors that often prove more important than yield differences when institutions evaluate deployment options.
BUIDL operates under U.S. Securities Act Regulation D, Rule 506(c), restricting participation to "qualified purchasers"—individuals with $5 million+ in investable assets or entities with $25 million+ in investments. This exemption permits capital raises without SEC registration but imposes stringent investor verification requirements. Securitize, the registered transfer agent and tokenization platform, manages KYC/AML processes, maintains the official shareholder registry, and ensures compliance with securities regulations. The fund entity itself is domiciled in the British Virgin Islands, a common offshore structure for international funds, with assets held by Bank of New York Mellon providing institutional-grade custody. This structure appeals to large investors requiring SEC-adjacent compliance without full 1940 Act registration complexity.
USDY utilizes Securities Act Regulation S exemption, permitting offers to non-U.S. persons without registration. The critical restriction: no sales to U.S. individuals or entities, making USDY explicitly designed for international investor access to U.S. Treasury exposure. The issuer entity, Ondo USDY LLC, is structured as a bankruptcy-remote special purpose vehicle—meaning even if Ondo Finance encounters financial distress, USDY assets remain segregated and protected for token holders. This structure includes an independent director, limitations on activities (exclusively holding Treasuries and bank deposits), and minimal operational overhead reducing corporate bankruptcy risk. Assets are held by Ankura Trust, a third-party custodian, with clear waterfall provisions for redemptions. This architecture addresses stablecoin critics concerned about unsecured liabilities of operating companies like Circle or Tether.
BENJI represents the most traditional regulatory structure, registered with the SEC under the Investment Company Act of 1940—the same framework governing conventional mutual funds. This registration subjects Franklin Templeton to comprehensive oversight including: daily NAV calculations, annual audited financial statements, custody requirements, board of directors with independent members, and quarterly/annual reporting filed publicly. While this creates significant compliance burden, it provides investor protections and transparency institutional allocators often mandate. The 1940 Act registration also enables broader distribution compared to private placements—Franklin can market BENJI more publicly and serve both institutional and retail investors across more jurisdictions. The trade-off: more regulatory constraints on fund operations and distribution methods.
Integration: How Tokenized Treasuries Plug Into Crypto
Key Metric Snapshot (Late 2024):
- •Tokenized Treasuries: $5.5B
- •Growth YoY: 539%
- •Stablecoin Market: $210B+
- •Fed Short-Term Rate: 4-5%
- •Daily Traditional T-Bill Volume: $900B
- •Opportunity Cost (idle stablecoins): $8-10B/year
The strategic value of tokenized Treasuries extends beyond simple yield generation to their utility as foundational infrastructure for decentralized finance protocols, centralized exchange treasury management, and institutional on-ramps bridging traditional and crypto-native capital pools. This composability—the ability to integrate programmatically with other blockchain applications—distinguishes tokenized products from conventional money market funds despite sharing underlying assets.
DeFi Protocol Integration: Collateral and Yield Optimization
Decentralized finance protocols require high-quality, non-volatile collateral to backstop lending operations, stabilize algorithmic stablecoins, and provide margin for derivatives trading. Historically, these protocols relied on overcollateralization using volatile crypto assets (ETH, BTC) or centralized stablecoins (USDC, USDT) paying zero yield. Tokenized Treasuries introduce a third category: yield-bearing, regulated, stable-value instruments enabling protocols to earn returns on treasury capital while maintaining liquidity and collateral utility.
MakerDAO (now Sky Protocol) exemplifies institutional DeFi appetite for tokenized Treasuries. In July 2024, Maker announced the "Spark Tokenization Grand Prix"—an open competition to allocate $1 billion of protocol reserves to tokenized U.S. Treasury products. Applications from BlackRock BUIDL, Ondo Finance, Superstate, OpenEden, and others demonstrate the competitive intensity as providers seek this massive capital deployment. MakerDAO's motivation: diversify backing for the $5 billion DAI stablecoin away from pure crypto collateral toward stable, yield-generating instruments maintaining DAI's peg while generating protocol revenue. The integration would allow DAI holders to indirectly capture Treasury yields through protocol fee distributions while maintaining stablecoin utility.
Aave, the $10 billion+ DeFi lending protocol, is exploring tokenized Treasury integration through its GHO Stability Module. A governance proposal suggests enabling USDC-to-BUIDL swaps within GHO's collateral framework, allowing users to gain Treasury exposure while supporting GHO stablecoin backing. The proposal remains in "temperature check" phase but signals blue-chip DeFi protocol interest in regulated yield-bearing collateral. However, implementation faces technical hurdles: most lending protocols require real-time price oracles, yet tokenized Treasuries lack deep secondary markets providing reliable price feeds. This oracle challenge currently limits adoption—protocols cannot safely lend against collateral without robust price discovery mechanisms determining loan-to-value ratios.
Arbitrum DAO represents a concrete implementation example. The STEP Committee recommended diversifying 35 million ARB tokens ($24.5 million) from Arbitrum's treasury into six tokenized products including Ondo USDY, BlackRock BUIDL, Superstate USTB, Mountain USDM, OpenEden TBILL, and Backed Finance bIB01. This treasury diversification captures 4-5% yields on idle protocol reserves versus holding purely crypto assets or zero-yield stablecoins. The allocation demonstrates how protocol DAOs increasingly view tokenized Treasuries as essential treasury management tools—earning safe yield on operational reserves without exiting on-chain entirely.
The composability extends beyond simple collateral to yield-farming strategies. Sophisticated DeFi users can deposit tokenized Treasuries into lending pools (Aave, Morpho), use them as margin for perpetual futures (dYdX), or provide liquidity on decentralized exchanges earning trading fees plus underlying Treasury yield. For example: deposit USDY into a lending protocol earning 2% lending APY plus the 4.25% underlying Treasury yield, generating 6.25% combined returns. These stacked yields create compelling risk-adjusted returns unavailable in traditional finance where Treasury holders cannot simultaneously lend their securities in multiple venues.
Centralized Exchange Adoption: Collateral and Institutional On-Ramps
Major centralized exchanges face a strategic dilemma: large institutional clients demand secure, yield-bearing assets to collateralize derivatives trading and maintain margin, yet exchanges traditionally offered only crypto or zero-yield stablecoins. Tokenized Treasuries solve this problem by providing regulated, interest-bearing collateral enabling institutions to stay "on-exchange" while earning Treasury rates on posted margin.
Binance's BUIDL Integration represents the first major CEX adoption. In November 2024, Binance announced acceptance of BUIDL as "off-exchange collateral"—meaning institutional traders can post BUIDL tokens with custody partners (like Ceffu, Binance's institutional custody provider) as margin for trading on Binance platforms. This structure keeps assets in client custody rather than direct exchange deposits, addressing institutional concerns about exchange risk while enabling trading activity. Catherine Chen, Binance's Head of VIP & Institutional, noted: "Our institutional clients have asked for more interest-bearing stable assets they can hold as collateral while actively trading." The integration also includes launching a BUIDL share class on BNB Chain, bringing the product natively to Binance's blockchain ecosystem valued at $7.4 billion in total value locked.
Crypto.com and Deribit similarly accepted BUIDL as collateral for institutional accounts, making it the first tokenized U.S. Treasury fund achieving this milestone. The collateral haircuts applied (typically 5-10%, meaning $1 million BUIDL provides $900-950K in margin capacity) reflect exchanges treating these instruments as near-cash equivalents. This adoption creates network effects: as more venues accept tokenized Treasuries, liquidity deepens, reducing haircuts and increasing utility, driving further adoption.
The broader implication: tokenized Treasuries function as "compliant stablecoin alternatives" for institutional actors uncomfortable holding USDC or USDT due to regulatory uncertainty or lack of yield. A hedge fund maintaining $100 million on Crypto.com can now hold BUIDL generating $4 million annually in Treasury yields while retaining full trading capacity. This yield arbitrage versus zero-interest stablecoins drove BUIDL's explosive $2.5 billion growth within eight months—institutions previously leaving hundreds of millions idle in non-yielding cash now capture risk-free returns without operational friction.
Building Blocks for Next-Generation Infrastructure
Beyond direct usage in lending and trading, tokenized Treasuries provide foundational liquidity for emerging blockchain financial primitives. Ondo Finance's business model exemplifies this architecture: USDY serves as collateral backing Ondo's various investment products, enabling the protocol to offer instant liquidity for other tokenized Treasury funds including BlackRock BUIDL. Investors seeking immediate BUIDL exposure can swap through Ondo's platform receiving instant settlement, with Ondo assuming the primary market settlement lag. This liquidity provision function mirrors traditional finance market makers but operates on-chain with blockchain transparency.
Ethena Labs' USDe stablecoin represents another architectural use case. While primarily backed by staked ETH with delta-hedged futures, Ethena has explored integrating tokenized Treasuries into backing composition to reduce reliance on perpetual funding rates. The addition would make USDe partially backed by "real-world yield" rather than purely crypto-native mechanisms—potentially improving stability and regulatory positioning while diversifying revenue sources.
The Anemoy Liquidity Network launched in November 2024 addresses persistent liquidity challenges through market-maker partnerships. Anemoy guarantees $125 million in instant redemptions plus $100 million same-day liquidity for tokenized Treasury products via specialized market makers like Keyrock. This infrastructure layer provides institutional-grade liquidity provision eliminating the thin order books plaguing secondary markets—enabling large transactions without severe price impact. As this infrastructure matures, tokenized Treasuries increasingly function as "money-market equivalents" with instant liquidity approaching traditional fund accessibility.
The Future: Institutional Adoption and Market Projections
The $5.5 billion tokenized Treasury market as of late 2024 represents early-stage adoption—a rounding error compared to the $26 trillion traditional Treasury market or the $6+ trillion money market fund industry. Yet growth trajectories and institutional validation signals suggest this represents the foundation for substantially larger deployment over coming years.
Market Size Projections and Growth Drivers
Industry projections for real-world asset tokenization broadly, and Treasuries specifically, vary dramatically based on assumptions about regulatory evolution, technical infrastructure maturation, and institutional adoption timelines. Conservative estimates from consulting firms like McKinsey project $2-4 trillion in tokenized assets by 2030. More aggressive projections from investment banks and blockchain advocates suggest $18-30 trillion, implying tokenization capturing 10-15% of addressable traditional asset markets. For context: the tokenized Treasury market grew 539% in 2024 alone, from $769 million to $5.5 billion, demonstrating exponential rather than linear growth patterns.
Several structural factors support continued expansion beyond speculative enthusiasm. First, the Federal Reserve maintaining elevated short-term rates (4-5% as of late 2024) makes Treasury yields attractive versus the zero-rate environment persisting 2020-2022. Crypto investors holding $210+ billion in stablecoins (USDT, USDC) face opportunity cost of 4-5% annually by not capturing available Treasury yields—creating $8-10 billion in foregone returns driving demand for yield-bearing alternatives. Second, regulatory clarity emerging through frameworks like the EU's MiCA regulation, proposed U.S. stablecoin legislation, and SEC guidance on digital asset securities reduces compliance uncertainty enabling institutional participation. BlackRock's entry itself—the world's $10+ trillion asset manager launching BUIDL—validates the opportunity for traditional finance giants previously skeptical of crypto-native infrastructure.
Third, technical infrastructure maturation solves early friction points. Cross-chain interoperability protocols enable BUIDL, USDY, and BENJI to deploy on 20+ blockchains combined, eliminating "stranded liquidity" where assets on one chain cannot interact with applications on others. Oracle providers like Chainlink developing specialized price feeds for tokenized securities address the data challenge limiting DeFi integration. Institutional custody solutions from firms like BitGo, Anchorage, and Fireblocks provide regulated storage meeting compliance requirements traditional finance demands. These infrastructure layers compound: as each component matures, adoption friction decreases, accelerating growth trajectories.
The RWA Narrative: Treasuries as Gateway Asset
Tokenized Treasuries serve as the "gateway drug" for broader real-world asset tokenization, establishing technical and regulatory templates applicable to more complex instruments. The success proves blockchain infrastructure can support regulated financial products meeting institutional custody, reporting, and compliance standards—validating the technology for subsequent asset classes with higher complexity and return potential.
Private credit represents the next frontier, with $14 billion already tokenized as of late 2024 commanding 58% of non-stablecoin RWA markets. Platforms like Figure (Provenance blockchain) have tokenized $12.5 billion in private credit instruments delivering 8-12% yields through direct lending to businesses. These products offer substantially higher returns than Treasuries while maintaining tangible asset backing and contractual cash flows. However, they introduce credit risk, longer lock-up periods, and more complex legal structures—making Treasuries the logical entry point for institutions new to tokenized assets.
Real estate tokenization remains nascent despite significant hype, with operational challenges around custody (who holds property titles?), rent distribution mechanics, and illiquidity management hampering adoption. However, successful Treasury tokenization demonstrates blockchain can handle regulated securities with transparent custody and regular distributions—providing technical blueprints for real estate funds once legal frameworks solidify.
Corporate bonds and structured products represent massive addressable markets ($10+ trillion in U.S. corporate bonds alone) where tokenization could dramatically improve settlement efficiency, secondary market liquidity, and fractional access. Goldman Sachs announced plans for three tokenized debt products in 2024, JPMorgan operates the Onyx blockchain platform for institutional trades, and UBS tokenized money market fund shares. These initiatives from systematically important financial institutions signal the technology transitioning from experimental to production-grade infrastructure.
Regulatory Evolution and Compliance Frameworks
The regulatory environment for tokenized securities remains fragmented globally, creating both opportunities and constraints. The U.S. SEC treats most tokenized assets as securities requiring registration or exemption compliance, while European MiCA regulation provides clearer frameworks for crypto asset service providers. Singapore's MAS and Hong Kong's SFC have established regulatory sandboxes enabling controlled tokenization experiments with institutional oversight.
Proposed U.S. legislation like the Genius Act aims to streamline settlement and reduce costs for tokenized securities by clarifying legal treatment and providing regulatory safe harbors. If enacted, such frameworks could dramatically accelerate adoption by reducing compliance uncertainty that currently forces products into complex offshore structures (BUIDL's BVI domicile) or restrictive exemptions (USDY's non-U.S. only access). The presence of SEC-registered BENJI demonstrates that full compliance with existing regulations remains viable—Franklin Templeton proved tokenization compatible with 1940 Act requirements, establishing precedent for other fund managers.
The critical challenge: balancing innovation with investor protection. Regulators face pressure to enable technological advancement improving market efficiency while preventing fraud, ensuring adequate disclosures, and maintaining market integrity. Tokenized Treasuries' backing by U.S. government debt—the safest and most liquid asset class globally—provides regulators confidence that risks remain manageable even as distribution mechanisms modernize. This makes Treasuries the natural testing ground for regulatory frameworks that can extend to more complex tokenized instruments once proven effective.
Investment Considerations and Risk Analysis
Despite backing by U.S. government debt—the traditional "risk-free" asset—tokenized Treasury products introduce novel risks absent in conventional money market funds or direct Treasury ownership. Investors must evaluate these additional risk layers when determining allocation sizes and product selection.
Smart Contract and Technical Risks
All tokenized products rely on smart contract code to manage token issuance, redemptions, dividend distributions, and access controls. Software bugs, logic errors, or unforeseen edge cases in these contracts could enable theft, freeze funds, or cause incorrect distributions. While products undergo third-party audits (firms like Trail of Bits, OpenZeppelin, Quantstamp review major protocols), audits cannot guarantee code correctness—only reduce probability of critical vulnerabilities. Historical precedent from DeFi demonstrates even audited protocols suffer exploits: Poly Network ($600M+ theft), Wormhole ($320M bridge hack), and numerous smaller incidents prove smart contract risk remains non-theoretical.
Mitigation strategies vary by product: BUIDL limits smart contract complexity by maintaining relatively simple token mechanics with most business logic off-chain through Securitize's traditional software systems. BENJI similarly uses blockchain primarily for transfer recording while Franklin Templeton maintains fund operations through conventional infrastructure. USDY exposes more on-chain functionality, creating larger attack surface but enabling greater DeFi composability. Conservative investors should limit tokenized exposure to amounts acceptable to lose entirely in catastrophic smart contract failure—treating these as "venture" allocations rather than core Treasury holdings.
Regulatory and Legal Uncertainties
The legal treatment of tokenized securities remains partially unsettled, creating tail risks around investor rights in edge cases. If BUIDL's issuing entity faces bankruptcy, do token holders have the same creditor priority as traditional fund shareholders? If USDY's bankruptcy-remote structure is tested in actual insolvency, will courts respect the separateness or pierce corporate veils? If Franklin Templeton's blockchain-based shareholder registry conflicts with paper records, which governs? These questions lack definitive answers absent litigation establishing precedent.
Additionally, regulatory changes could impair product viability. The SEC could determine certain structures violate securities laws, forcing restructuring or discontinuation. Congress could pass legislation altering tax treatment of tokenized instruments. Foreign jurisdictions could ban their citizens from accessing U.S.-based tokenized products. USDY's restriction to non-U.S. persons demonstrates how regulatory boundaries constrain access—and those boundaries could shift unfavorably. Investors should monitor regulatory developments and maintain flexibility to exit positions if legal frameworks become hostile.
Liquidity and Market Structure Limitations
Despite 24/7 trading capabilities, tokenized Treasury secondary markets remain thin with limited depth. Daily trading volume across all tokenized Treasury products combined approximates $5-10 million—trivial compared to $900+ billion daily in traditional Treasury markets. This creates meaningful price slippage for large transactions: selling $10 million USDY might achieve only $0.98-0.99 per token versus $1.00 theoretical value, representing 1-2% implicit transaction cost. Primary market redemptions avoid this slippage but require multi-day settlement windows and KYC processes creating friction versus traditional money market funds offering same-day NAV-based redemptions.
The oracle problem exacerbates this challenge for DeFi integration. Lending protocols require reliable real-time pricing to determine collateral values and trigger liquidations. With thin secondary markets and no deep exchange order books, oracle providers struggle to deliver robust price feeds. Most oracles simply assume $1.00 per token regardless of actual trading—creating risk that market stress could cause tokenized Treasuries to trade at significant discounts while oracles still report par value, enabling collateral manipulation or preventing appropriate liquidations.
Concentration and Counterparty Risks
Product concentration in three issuers (BlackRock, Ondo, Franklin) creates correlated risk—regulatory action against one could trigger contagion affecting others. Technological dependencies introduce additional concentration: BUIDL's reliance on Circle for instant USDC redemptions means Circle operational issues impair BUIDL liquidity. Securitize's role as transfer agent for multiple products creates single point of failure in shareholder registry management. Blockchain network risks affect all products deployed on specific chains—Ethereum gas fee spikes, Solana network outages, or consensus failures would prevent transactions across all products on affected networks.
Custody concentration also matters: Bank of New York Mellon holds BUIDL assets, Ankura Trust for USDY, Franklin's designated custodian for BENJI. While these are reputable institutions, operational failures, cyber attacks, or insolvency could create temporary or permanent asset impairment. Unlike FDIC insurance protecting bank deposits or SIPC coverage for brokerage accounts, tokenized products rely on contractual relationships and fund structures for protection—legal remedies that may prove slower and less certain than regulatory insurance schemes.
Conclusion: The Maturation of On-Chain Fixed Income
Tokenized Treasuries represent far more than mere technological novelty—they constitute the foundational infrastructure enabling compliant, regulated fixed income to operate on blockchain rails with programmability and instant settlement characteristics impossible in traditional markets. The explosive 539% growth in 2024 from $769 million to $5.5 billion in assets demonstrates genuine institutional and DeFi protocol demand for yield-bearing, stable, blockchain-native instruments serving as crypto's equivalent of the risk-free rate.
The three dominant products—BlackRock BUIDL, Ondo USDY, and Franklin BENJI—serve complementary rather than competing market segments. BUIDL targets large U.S. institutional investors requiring maximum liquidity and regulatory comfort, offering $5M minimums with instant USDC redemption and major CEX collateral acceptance. USDY serves non-U.S. individuals and institutions seeking accessible Treasury exposure ($500 minimums) with DeFi composability despite 40-50 day minting delays. BENJI provides broadest accessibility with SEC registration, mobile app access, and widest blockchain distribution across nine chains. Understanding these differences proves essential for investors evaluating which product aligns with their jurisdiction, capital size, liquidity needs, and intended use case.
The integration into decentralized finance through MakerDAO's $1 billion allocation, Aave's collateral proposals, and Arbitrum's treasury diversification validates that blue-chip DeFi protocols view tokenized Treasuries as essential infrastructure rather than experimental products. Similarly, Binance, Crypto.com, and Deribit accepting BUIDL as collateral demonstrates centralized exchange recognition that institutional traders demand yield-bearing margin alternatives to zero-interest stablecoins. These integrations create network effects: as adoption increases, liquidity deepens, reducing haircuts and increasing utility, driving further adoption in virtuous cycles.
Looking forward, tokenized Treasuries serve as proof-of-concept for broader real-world asset tokenization. The technical and regulatory templates established through BUIDL, USDY, and BENJI provide blueprints for tokenizing private credit ($14B already on-chain), corporate bonds ($10+ trillion addressable market), real estate, and structured products. As infrastructure matures—cross-chain interoperability, institutional custody, robust oracle pricing, regulatory clarity—the friction differentiating tokenized from traditional securities diminishes. Within five years, tokenized Treasuries trading indistinguishably from money market funds in accessibility, liquidity, and pricing efficiency appears increasingly plausible.
For investors, tokenized Treasuries occupy a unique position offering U.S. government-backed stability, 4-5% risk-free yields, and 24/7 accessibility with blockchain programmability—characteristics unavailable through any single traditional product. The appropriate allocation depends on risk tolerance, jurisdiction, capital size, and intended use. Institutional investors meeting BUIDL's $5M minimum gain maximum liquidity and compliance comfort. International retail investors access global Treasury markets through USDY's $500 entry point. Those prioritizing regulatory transparency and mobile accessibility select BENJI's SEC-registered structure. Regardless of product selection, the emergence of on-chain risk-free rates represents one of 2024's most significant developments in bridging traditional and decentralized finance—creating foundational infrastructure likely to compound in importance as the tokenized asset market scales toward projected multi-trillion dollar size by decade's end.
The democratization of Treasury access, elimination of settlement delays, and integration into programmable financial applications marks not just evolution but revolution in how fixed income markets operate. As BlackRock CEO Larry Fink stated regarding tokenization: "The next generation for markets, the next generation for securities, will be tokenization of securities." With $5.5 billion already on-chain and growth trajectories pointing toward $50+ billion within years, that future arrives not gradually but suddenly—and tokenized Treasuries stand at the vanguard of transformation reshaping global capital markets.

