May 29, 2025

Tokens, Currencies, Coins, Assets… What the Heck Are We Talking About Anyway?

The Owl
By and The Owl
shutterstock 2160328403

“Stablecoins are a type of cryptocurrency that act as a form of cash but sit outside the banking system. They are used to pay for other crypto assets…” Financial Times, 2 April 2025

There are a lot of names in the crypto space. People often use them interchangeably. Different countries, different companies, and different regulators all have their preferred names for what they’re talking about. But it matters that we all know what we’re talking about when we use these words and - as much as possible - use them in the same way. This is particularly true when it comes to regulation because without solid definitions, compliance is difficult. 

In this Owl Explains note we’re going to tackle lexicography for commonly used terms for what we prefer to call tokens. And explain why we think ‘tokens’ is the best word to use when talking in a general sense. By the end of the article you should be able to see how the Financial Times quote at the top uses these different terms - and decide whether you think it gets them right.

Crypto: Let’s start with the fundamental word: ‘crypto’. The ‘crypto’ in cryptoasset or cryptocurrency comes from ‘cryptography’. That is, the use of codes or ‘encryption’ to provide secrecy. Cryptography is an ancient practice going back many thousands of years, at least to the ancient Egyptians. Modern cryptography has been greatly enhanced by the use of computers and new techniques. Together these allow people to create the public and private keys necessary for blockchain. The use of ‘crypto’ essentially just means that some information has been ‘encrypted’ using these modern cryptographic techniques. And in practice it is used to refer to something on a blockchain - or the whole blockchain-based sector itself.

Cryptocurrency: A cryptocurrency is, naturally enough, a type of currency utilizing  ‘crypto’. But what is a currency? A currency is a type of money widely used in a particular area. It is a form of ‘money’. So by calling something a ‘cryptocurrency’, its founders are implying that it has the characteristics of money: the dollars, pounds, euros or yen that you use every day. The three fundamental characteristics of money are:

  1. That it is a store of value. That is, that what you hold today will be worth the same amount tomorrow.

  2. That it is a means of exchange. That is, that other people will be happy to take it in exchange for goods or services they provide.

  3. That it is a unit of account. That is, that you can price a good or service in it. 

While ‘cryptocurrency’ was one of the first ways of describing these blockchain-based units, it is now largely out of favor since many (or even most) don’t fulfil these three characteristics. When was the last time you heard someone price something in Dogecoin?

Cryptoasset: More popular nowadays is the term ‘cryptoasset’ (and note that there are different ways of spelling this: all one word, with a hyphen, or as two separate words). But what’s an asset? An asset is something that has (financial) value. So a cryptoasset is something on the blockchain that holds (or represents) value. This makes sense as a term, given that many people buy or sell ‘cryptoassets’ as speculation (to make money) or because it offers them access to something else that has value (like a blockchain protocol or a good or service in the real world). But while this is a useful term that is in wide use, it does also have one issue with it: it implies the crypto ’asset’ does have some sort of value. Which they don’t always. For example, a tokenized digital record, such as a diploma, might not ever have (or be intended to have) a value. So calling them ‘cryptoassets’ would imply a use - and therefore a form of regulatory treatment - that doesn’t make sense.  This is one of the reasons we stress token classification, including in our submission to the SEC Crypto Task Force. This terminology matters when it comes to thinking about the correct regulatory treatment for things on the blockchain. Nowadays when a regulator or government official says ‘crypto’ they’re referring to a cryptoasset - and probably including the idea of a ‘cryptocurrency’ within it.

Stablecoin: Stablecoins are a unique type of ‘cryptoasset’ that attempt to maintain a stable value against a reference asset. Usually today this reference asset will be a so-called ‘fiat currency’: in other words, the normal currency of any given country (dollars, pesos, etc.). In this sense they are a ‘crypto’ or on-chain representation of normal money that already exists, and they fulfil the three functions of currency by ‘piggybacking’ on the underlying existing fiat currency. Previously (around 2018-2019) the term was used more loosely to mean something that tried to reduce volatility in the value of a cryptoasset - either through its backing asset or via an algorithm. Now, largely driven by regulation, ‘stablecoin’ tends to only refer to a token that is pegged one for one to a single fiat currency, or perhaps sometimes to a group (a ‘basket’) of different fiat currencies. So depending who you’re talking to, ‘stablecoin’ could be referring to the whole universe of ‘stablecoins’ that attempt to minimise volatility or just to those, more common now, that maintain a stable value against the reference asset or fiat currency.

Central Bank Digital Currency (CBDC): A CBDC is very similar to a stablecoin, in that it is the ‘digital’ version of a fiat currency, except that it is created by a government’s Central Bank or other monetary authority. That is, a CBDC is issued by a country’s public sector and is a direct liability of that authority. There is therefore no private sector company responsible for it, or which could go bankrupt or fail to provide it. That makes it very safe, in an economic sense, for people who hold it. Many countries are still exploring developing a CBDC, and there are significant ongoing political discussions around questions like privacy rights and the ability of governments (or Central Banks) to control how a CBDC might be used by citizens and businesses.

Digital [currency/asset/cash]: As you’ll have seen in the term CBDC, this is not called ‘crypto’ but ‘digital’. That’s because ‘crypto’ implies something on a blockchain, as we’ve seen, and through its meaning about the wider sector still sometimes has a negative connotation. Central Banks don’t want to be associated with that - and anyway may not issue on a blockchain. So they used ‘digital’. That makes sense as far as it goes, but has one major problem: the overwhelming majority of ‘traditional’ money is also digital because it exists as commercial bank deposits (and indeed as Central Bank reserve deposits). These deposits are purely digital in that the value solely exists as information inside bank computers. Calling something blockchain-based as ‘digital’ does not really help distinguish it.  In other words, digital is a much broader category that includes crypto.

Virtual [currency/asset/cash]: Some people use the term ‘virtual’ in an attempt to get around this confusion, though it’s now a little less used than it used to be. ‘Virtual’ covers basically the same ground as ‘digital’ but without the confusion about existing bank deposits. In this sense it’s really used as a synonym for ‘on-chain’: that is, something based on a blockchain.  Virtual has more traditionally been used to mean anything on the internet, such as people referring to a “virtual meeting” when they do a video call.  For these reasons, by and large the term ‘crypto’ is winning out as the main usage for something on-chain.

All these terms are in use, but all have problems. So what does Owl Explains use? 

Well, we prefer the term ‘Token’. This word refers to something that is used to represent an asset, item, bundle of rights or thing. It does not necessarily imply financial value (like ‘asset’) or money (like ‘currency’). It is technology neutral, so does not imply something has to be blockchain-based (like ‘crypto’) or not (like a CBDC) - and indeed it even applies to non-digital/virtual representations like those that are based on paper (like old time stock certificates or tickets to an event) or metal (like subway tokens). A ‘token’ can refer to all these things without implying any characteristic, and therefore without prejudging any regulatory treatment. And the word ‘token’ allows anything to be ‘tokenized’ or ‘represented by a token’, which is  a major growth area for the blockchain sector at the moment.

In an upcoming post, we’ll explain how tokens themselves can be classified from a regulatory and market point of view.

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IMG 7527
2026-03-04

London Calling Part 2: The UK’s Journey from Roadmap to Reality

London Calling Part 2: The UK’s Journey from Roadmap to Reality Eight months ago, we wrote about the UK’s crypto journey being still largely about direction of travel. The legislative perimeter had been sketched out, regulators had published their roadmap, and the ambition to become a global hub for digital assets was firmly back in the political vocabulary. The framework was coming, but for firms on the ground, it still felt a step removed from current reality. That is no longer the case. Since then, the UK has moved from strategy to execution at a pace that is difficult to ignore. The government has now laidthe statutory instrument that brings cryptoasset activities formally into the financial services regime, creating new regulated activities from trading platforms to stablecoin issuance and giving the FCA the legal foundations for a full rulebook. At the same time, the FCA has finalised a core package of consultations covering market structure, admissions and disclosures, market abuse, and a dedicated prudential regime - the operating manual for the future UK crypto market. Add to that the Bank of England’s systemic stablecoin proposals, a new stablecoin-focused regulatory sandbox and sprint, the confirmation of the authorisations gateway timeline, and even primary legislation clarifying that digital assets can attract property rights, the picture becomes clear: the UK is no longer designing a regime in theory. It is building one in real time. Authorisations Approaching The new regime will take effect on October 25, 2027. From 30 September 2026, firms will be able to apply for licences, with a five-month window in which early applicants gain the significant advantage of being able to continue operating while their applications are assessed (even after commencement). But there will be no automatic transition. Every firm, regardless of its current status, will need to pass through the gateway if it wishes to conduct regulated business in the UK. The shift from the MLR framework to FSMA authorisation changes the evidential threshold at the gateway. Applications will need to set out not only what the firm intends to do, but how its governance, risk management, capital planning and operational arrangements will meet the relevant Handbook standards by go-live. Early engagement through the FCA’s specialist crypto authorisations teams and the pre-application support service should help firms interpret those expectations, but authorisation will depend on the credibility and completeness of the proposed operating model not just the timing of the application. For the market, this is the moment when regulatory policy becomes a commercial timetable. From Speed to Calibration For years, the standard critique of the UK was that it was moving too slowly. But that argument no longer passes muster. Few major jurisdictions have attempted to deliver, in parallel, a full conduct regime, a market-structure framework, a prudential rulebook, a systemic stablecoin model, an authorisation gateway and a legislative perimeter, all on a clearly sequenced and short timeline. The UK is now doing exactly that. The question has therefore changed. It is no longer whether the UK can move fast enough. It is whether the regime, once complete, will be calibrated well enough to compete. At Avalanche Policy Coalition, we hope that the calibration will properly take into account a workable token classification system that differentiates financial instruments from other types of assets so that the regulatory perimeter is correctly scoped, as well as preserve the distinction between infrastructure and intermediation. Developers, validators, node operators, and open-source contributors, among others, who do not custody assets or exercise unilateral discretion should not be treated as financial intermediaries. Protecting infrastructure neutrality will support innovation without weakening consumer protection. The Coherence and Competitiveness Challenge The UK’s great structural advantage has always been its integrated regulatory architecture. With HM Treasury setting the perimeter and the FCA and Bank of England dividing responsibilities along clear conduct and financial-stability lines, the system is far less fragmented than in jurisdictions where multiple federal and state authorities overlap. That should make it easier to deliver a single, coherent framework. But coherence is not automatic. It has to be designed. Firms are now looking at how the layers fit together in practice: how the FCA’s stablecoin rules interact with the Bank’s systemic regime, particularly as firms consider the transition from an FCA-only framework to dual supervision once systemic thresholds are reached; how prudential requirements align with conduct expectations; and how market-abuse, disclosure and trading-platform rules operate as a unified whole rather than as separate compliance exercises. This is not an academic question. Global firms do not build to individual consultations; they build to the overall regime. That determines where they locate trading infrastructure, where they base senior management, where they deploy capital and where new products are launched first. If the cumulative effect is predictable and proportionate, capital and talent will follow, and the UK will continue to be a competitive force around the world. Birdseye View The UK has reached the point where it can no longer be described as a jurisdiction “planning” its crypto regime. It is implementing it, on a defined timeline, with a full licensing process in sight. That is a significant achievement and one that only a small number of global financial centres have matched. The question is no longer one of speed or first mover advantage. It is about identifying the right risks and calibrating them appropriately, allowing firms to operationalise with confidence. The UK is at a crossroads. If the final framework is as coherent and proportionate, the UK has a genuine opportunity to translate regulatory progress into market leadership. Coherence requires not only institutional alignment, but clarity that different asset types and activities are appropriately regulated (or not). That is what will attract firms who are not simply looking for certainty, but for a regime within which they can scale. Otherwise, the UK will struggle to convert historical and structural advantage into long-term competitive advantage.

The Owl
By and The Owl
shutterstock 2533565017
2026-02-19

Bridging the Atlantic, Part II: What’s New in UK Stablecoin Policy?

In August we compared the upcoming stablecoin regimes in the US and UK. Since that post, the UK has moved forward in shaping how these digital assets should be regulated as part of the financial system, especially if they become widely used for everyday payments. This post provides an update to describe the significant changes in direction in the latest UK proposals from the Bank of England and HM Treasury. The Bank of England has the mandate to create rules for ‘systemic’ stablecoins given their potential impact on financial stability, while HM Treasury (part of the UK government) is creating the detailed law that will give UK regulators the powers they need (and set the overall guidelines) to develop regulation. The big change in the UK is the focus on “systemic” stablecoins, and how they and their issuers are to be regulated.  The concept of systemic stablecoin regulation does not appear directly in US law under the GENIUS Act, although provisions of GENIUS require regulators to evaluate stablecoins and their issuers for potential threats to financial system stability. Below, we focus on the UK proposal. Why the UK is Focusing on Stablecoins Now Stablecoins (digital tokens designed to maintain a stable value against a fiat currency) remain the fastest-growing form of money in the digital economy. They are a key pillar of our token classification system, which you can read more about here. The UK government and regulators have been clear: if stablecoins are going to function like money in daily life and not just in crypto trading, then they must be subject to a regulatory framework that protects consumers and safeguards financial stability. The goal is to integrate stablecoins responsibly into the UK’s financial architecture, while also supporting the innovation they represent. This will go hand-in-hand with proposals for comprehensive crypto regulation that were originally introduced in 2023 through proposed changes to the Financial Services and Markets Act. The UK government (HM Treasury) ‘laid’ secondary legislation in December 2025 that would put much of the 2023 updates into effect, including defining stablecoins as regulated financial instruments and regulating their issuance.   The Core Focus: “Systemic” Stablecoins In coordination with HM Treasury and the FCA, the latest Bank of England consultation paper was published in November 2025. Its focus is on pound sterling-denominated “systemic” stablecoins. These are stablecoins that become so widely used in everyday retail payments that, if something went wrong, they might affect not only consumers and businesses at scale, but the wider financial system as well. What makes a stablecoin systemic? While the full details will be clarified in the final regulation, it’s essentially based on how many people and businesses use it (and for what kinds of payments) and the extent of its interconnections with the financial system. HM Treasury has the power to designate stablecoins as systemic and once it has done so, the stablecoin would fall under a joint regulatory regime, with the Bank of England looking after financial stability and prudential requirements, and the Financial Conduct Authority (FCA) overseeing consumer protection and conduct under its own upcoming stablecoin regime.  Non-systemic stablecoins will be regulated solely by the FCA under existing and upcoming cryptoasset rules. A non-systemic stablecoin, for example, is one used for a day-to-day payment or as an on-/off-ramp to the crypto ecosystem that does not have a critical mass of users in the UK.  Note that even with this consultation paper, much of the regulation of stablecoins, their issuers and their usage remains subject to additional rulemaking.  Those looking for certainty need to remain patient, notwithstanding that the government has been considering these issues since at least 2023. New Backing Asset Rules: A Balancing Act One of the biggest changes in the new proposals is how issuers of stablecoins designated systemic would be required to back the coins they issue; that is, what assets they must hold to ensure that coins remain redeemable at a fixed value in pounds sterling. Under the draft proposals: At least 40% of backing assets must be held as unremunerated (non-interest-bearing) deposits at the Bank of England - effectively very liquid central bank money. Up to 60% can be held in short-term UK government debt (gilts), which can earn a return and help make issuer business models viable. This is a shift from earlier proposals that would have required almost all backing assets to be held at the central bank with no interest.  The Bank of England is also considering offering liquidity lines to issuers, and proposes allowing them to repo out backing assets as a means of accessing additional liquidity. The idea is to strike the right balance: making sure issuers can always meet redemption requests even in a crisis, while also not squeezing them out of business by forcing ultra-conservative backing rules.These requirements will make systemic stablecoin issuers look a lot like so-called narrow banks and the stablecoin itself a lot like a central bank digital currency. “Step-Up” and Transitional Rules There are also transitional measures to support issuers that are systemic from the start. Such firms could temporarily hold up to 95% of their backing assets in short-term government debt during their early growth phase, before scaling into the full 60/40 structure. This “step-up” regime is designed to give new market entrants space to grow while still ensuring they eventually meet stringent safeguards. It is designed to limit worries of a ‘cliff-edge’ from transitioning from the FCA to the BoE’s systemic regime. Consumer Safeguards and Limits Controversially, to reduce the risk that stablecoins could pull deposits out of the banking system too quickly (which could affect credit and financial stability) the proposals include temporary holding limits per systemic stablecoin: £20,000 per individual £10 million per business (with exemptions possible for some business uses) These limits are framed as transitional, with regulators monitoring whether they can be adjusted as the market matures. It is not clear how these limits would be enforced from a practical perspective. Other Noteworthy Requirements in the Consultation A few other important parts of the consultation include: Direct payment system access: Systemic stablecoins should be able to settle with traditional money systems, making redemptions and transfers smoother. Safeguarding backing assets: Reserves must be ring-fenced and held in the UK, with clear legal claims for coin-holders. Subsidiary requirements: Foreign stablecoin issuers targeting the UK market would need UK-based and regulated subsidiaries. Birdseye View  While the UK continues to develop and adapt its framework for stablecoins, it seems to be still mired in basics and with overlap between the FCA and BoE’s roles. The BoE’s updated stablecoin policy proposals reflect a pragmatic approach: significant safeguards to protect users and financial stability, flexibility to support issuer viability, and a clear path toward integrating stablecoins into the payments system, which will allow them to be part of commerce in the UK. But some basic concepts still need to be clarified. And the UK is running out of time. Whether this proposed framework will help the UK compete with the US’s crypto-friendly stance and the EU’s MiCA regime remains a live debate.  It’s important to note that these are draft proposals open for comment, and we expect there will be robust discussion between the Bank of England and industry on the details. They are not set in stone and may be subject to change. We will continue to watch with interest for new developments and await the final rules.

The Owl
By and The Owl
advisory-council-main
2026-02-03

Announcing Avalanche Policy Coalition Initial Advisory Council & 2026 Policy Priorities

We are pleased to announce the initial members of our newly-formed Advisory Council. We warmly welcome Bart Smith and Laine Litman, CEO and COO, respectively, of Avalanche Treasury Co., Jolie Kahn, CEO of Avax One Technology, and Lord Chris Holmes, a director for the Avalanche Foundation and member of the UK House of Lords.  Each brings rich and diverse experience together with a commitment to the Avalanche ecosystem that makes them uniquely qualified for the role.  Lee Schneider, the Ava Labs General Counsel, will chair the Advisory Council.  APC will serve as the policy hub for the Avalanche community, with the Advisory Council charting the course on the themes and priorities for our educational and advocacy efforts.  2026 promises to be a busy year on the policy front with the US and major other jurisdictions (including Australia, Korea, and the UK) moving ahead with comprehensive crypto asset regulation or making significant adjustments to existing regulation.  APC seeks to be the premier resource on foundational blockchain policy and regulatory issues.  Our guiding principles for policymakers and regulators on how to approach blockchain and crypto set the stage for thoughtful, targeted laws and rules that are easy to understand and apply.  The Advisory Council’s goals include providing expertise and insight on key issues and helping to expand our reach to a broader audience. The Advisory Council has set three policy priorities for 2026.  These are the key themes that will guide our advocacy, thought leadership, and other activities during the year.  They are designed to cover matters that impact the Avalanche community directly, and blockchain/crypto policy and regulation in general.  They are also geared towards what we believe are foundational points to undergird all thinking on these topics. First, APC will focus on token classification, refining it for an era of tokenized real world assets (RWA).  The nature of the asset matters for utilization, valuation and legal/regulatory classification, among other things.  If policy makers and regulators get token classification right, it will result in rules that are easy to understand, apply and follow.  Get it wrong, and it will sow confusion, over-regulation, and inhibit growth.  We have seen token classification in action as countries have adopted rules for stablecoins as distinct from other tokens.  Similarly, tokenized stocks and bonds are different from tokenized concert tickets and should not be regulated the same, nor should protocol (network) tokens.   Second, we will focus on the difference between infrastructure and intermediary functions to buttress the dividing line between which activities should be regulated and which should not.  The nature of the activity matters for allocating responsibility and liability from a commercial, financial, legal and regulatory standpoint.  There are efforts in many jurisdictions to push regulatory requirements to the infrastructure layer like never before.  We will keep fighting against these proposals, because it is the specific businesses that should be regulated, not the infrastructure layer providing common rails for all.  Validator nodes, software developers, and hardware providers are prime examples of infrastructure.  On the other hand, banks, brokerages and exchanges are properly regulated as intermediaries. Finally, we will advocate for an open, uncensored internet to keep blockchains functioning.  Access to infrastructure matters as we navigate an increasingly online world for commerce, finance, communications, education and recreation.  We should not tolerate direct or indirect government restrictions on the internet, such as those imposed by the regime in Iran during this turbulent time.  At best it results in censorship of core freedoms; at worst it results in the death of innocents.  Because blockchains depend on the internet, everyone in the community should demand open, uncensored internet access. Here at APC, we have a number of exciting initiatives in the works.  Follow us on X, LinkedIn and Instagram, subscribe for our biweekly update, listen to our podcast, and find us at events around the world.  There is a lot to do in 2026...

The Owl
By and The Owl