Five Countries, Five Approaches
Brazil, Argentina, Colombia, Chile, and the United States are each taking different approaches to regulating digital financial infrastructure. Some lead with sandboxes. Others with pilot transactions. Others with legislation. No two countries have taken the same path. But patterns are emerging that offer lessons for any jurisdiction considering how to enable digital capital markets while protecting investors.
United States: Regulation by Institutional Action
In the United States, institutions moved first. Regulators followed.
JPMorgan launched Kinexys (formerly Onyx) and now processes over $2 billion daily without new legislation. BlackRock launched BUIDL, a tokenized US Treasury fund exceeding $2 billion, under existing securities exemptions. Circle operates USDC ($78.8 billion in circulation) under state-by-state money transmitter licenses across 46 states plus the District of Columbia and Puerto Rico, along with federal registration with the Financial Crimes Enforcement Network (FinCEN).
The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) published joint guidance on digital asset classification on March 17, 2026, classifying 16 assets as digital commodities. The GENIUS Act, stablecoin legislation, is advancing through Congress.
The lesson: institutional adoption created regulatory urgency, not the other way around.
European Union: The Legislative Framework First
The European Union took the opposite approach: comprehensive legislation before market development.
The Markets in Crypto-Assets Regulation (MiCA) has been fully in force since December 2024. Stablecoin provisions applied in June 2024 and authorization of Crypto-Asset Service Providers (CASPs) took effect in December 2024. Existing providers have a transitional period until July 1, 2026.
Separately, the Distributed Ledger Technology (DLT) Pilot Regime provides a framework for testing digital securities in regulated sandboxes.
Regulatory clarity attracted institutional participation. Circle achieved MiCA compliance immediately. European digital bond issuance reached EUR 3 billion in 2024, an increase of 260% year-over-year.
The lesson: regulatory clarity accelerates institutional participation. The tradeoff is that comprehensive regulation takes years to implement and can slow early innovation.
Brazil: Exchange-Led Institutional Infrastructure
In Brazil, the stock exchange leads and regulators support.
B3, the largest stock exchange in Latin America, announced plans to launch a digital securities platform and a stablecoin in 2026. The Central Bank of Brazil developed Drex, a Central Bank Digital Currency (CBDC), currently in pilot phase. The Comissão de Valores Mobiliários (CVM), the securities regulator, established a framework for digital securities.
The lesson: when the stock exchange leads, infrastructure is institutional from day one. There is no gap between innovation and compliance.
Argentina and Colombia: Sandboxes and Pilots
Argentina: regulatory sandbox
The Comisión Nacional de Valores (CNV), Argentina's securities regulator, launched a formal sandbox for digital securities in mid-2025. It covers equities, corporate bonds, and CEDEARs (Certificados de Depósito Argentinos, depositary receipts representing foreign securities). The central bank approved banks to provide digital asset services starting in 2026.
The lesson: sandboxes allow experimentation within regulatory guardrails. Lower risk for regulators, faster learning for the market.
Colombia: pilot transaction within the sandbox
The first digital bond in Latin America and the Caribbean was issued in Colombia in 2022: COP $110 million. Participants included Davivienda Bank, the Inter-American Development Bank (IDB) Group, and the Banco de la República, within the Financial Superintendence's innovation sandbox known as "la Arenera." The entire lifecycle was executed on institutional infrastructure: issuance, trading, settlement, and cancellation.
The lesson: a single successful pilot transaction generates more regulatory confidence than years of theoretical frameworks.
Common Patterns and Lessons
Five patterns emerge across all jurisdictions analyzed:
- Institutions move before regulation. In every case, institutional adoption preceded comprehensive regulation. Regulators responded to market reality, not the other way around.
- Existing frameworks accommodate more than expected. Most treasury and payment applications operate under existing regulatory frameworks. New legislation is needed primarily for public securities issuance, not for treasury optimization.
- Sandboxes accelerate learning. Countries with formal sandboxes (Argentina, Colombia, the EU DLT Pilot Regime) developed regulatory confidence faster than those without.
- The exchange matters. When the national stock exchange leads (Brazil), institutional credibility is embedded from the start.
- One pilot changes everything. Colombia's COP $110 million bond pilot created more momentum than years of discussion. Execution builds confidence faster than theory.
What This Means for Regulators and Companies
For regulators: the question is not whether to regulate digital financial infrastructure, but how. The approaches vary, but the direction is universal. Waiting does not reduce risk; it increases the gap with jurisdictions that moved earlier.
For companies: regulatory clarity is increasing across every major jurisdiction. Treasury and payment optimization operates within existing frameworks today. Capital markets applications require more regulatory coordination, but precedents exist in every region.
The infrastructure is institutional. The regulation is catching up. The gap between the two is closing.
Navigate the Regulatory Landscape
Greenwich Sound Capital advises companies and institutions on evaluating the regulatory landscape for digital financial infrastructure in Latin America.
Schedule a Consultation