Deutsche Börse's Crypto Finance Launches AnchorNote, Signaling Maturity in Off-Exchange Infrastructure
On September 16th, 2025, Deutsche Börse Group's Crypto Finance launched AnchorNote from Zurich, a custody-native pledging solution that lets institutional clients trade across exchanges while assets remain in regulated custody. The announcement received limited fanfare outside crypto trade publications, yet it marked something significant. One of Europe's largest exchange operators, overseeing trillions in traditional market infrastructure, had deployed production infrastructure that decouples custody from execution. Deutsche Börse does not experiment with beta products. The move signals that custody-native settlement has crossed from crypto-native innovation to regulated financial plumbing.
Tokenized Treasuries Surge, Driving Demand for Collateralized Trading
The timing tracks with deeper market shifts. Tokenized US Treasuries hit $9.11B in November 2025, up from roughly $1B in January 2024. BlackRock's BUIDL fund alone holds $2.5B and expanded to eight blockchains in November, with Binance listing it as collateral alongside Crypto.com and Deribit. Institutions want these yield-bearing assets to work as margin for crypto trading without the operational friction of moving them between custodians and exchanges.
Three major providers built distinct approaches. The question for institutions is no longer whether to adopt custody-native settlement, but which architectural model fits their operational requirements.
The Pre-Funding Problem That Forced the Solution
Traditional finance separated custody, execution, and settlement decades ago. A hedge fund trades on the NYSE without depositing cash there. Prime brokers intermediate credit, central clearinghouses manage settlement, and assets stay with qualified custodians throughout.
Crypto evolved differently. Early platforms bundled everything. To trade on Binance or FTX, users deposited assets directly into exchange wallets. FTX's November 2022 collapse demonstrated why this model cannot scale to institutional capital.
The regulatory response pushed hard toward segregation. MiCA took full effect on December 30th, 2024, requiring crypto asset service providers to segregate customer holdings both on-chain and on internal ledgers. In the US, the SEC rescinded SAB 121 in January 2025, eliminating requirements that banks treat client crypto as balance-sheet liabilities. The OCC issued clarifying guidance confirming that national banks may provide crypto custody without prior supervisory approval.
Asset segregation solves the safety problem but creates a new one. If assets sit at a qualified custodian and the trading venue sits elsewhere, how does the venue know what the trader can access? The legacy solution is pre-funding. A market maker wanting to arbitrage Bitcoin across five exchanges deposits fully funded collateral at each venue. Industry analysis suggests this traps approximately 60-70% of working capital that could otherwise generate yield. For a firm managing $100M, that represents $60M to $70M earning zero return while sitting as security deposits.
In a rate environment where tokenized Treasuries yield 4-5%, the opportunity cost compounds. Off-exchange settlement infrastructure emerged to solve this: let assets stay in custody while their purchasing power projects across multiple venues simultaneously.
Three Models, Three Tradeoffs
The dominant providers took different paths to the same destination.
Copper ClearLoop pioneered the category and claims more than $50B/mo in notional volume. Assets remain in Copper's MPC custody, protected by an English Law Trust structure, while the ClearLoop network broadcasts collateral availability to connected exchanges. Allocation occurs in under 100 milliseconds. Exchange integrations include Coinbase International Exchange (July 2025), Deribit, OKX, Bybit, Bitfinex, Kraken MTF (June 2024), and BitMart. Flow Traders completed full integration in July 2024.
The Copper model offers a seamless user experience. Everything lives in one custody environment. The constraint is vendor lock-in. To use ClearLoop, the client must custody with Copper. The February 2025 partnership with BitGo changed this, allowing assets held in BitGo's qualified custody to settle through ClearLoop.
Fireblocks Off Exchange launched in November 2023 with Deribit as the initial partner. Rather than relying on custodial intermediaries, Fireblocks uses on-chain MPC shared wallets called Collateral Vault Accounts. Early institutional users, including QCP Capital and Zerocap, allocated more than $100M by September 2024. The Fireblocks Network now connects more than 1,800 liquidity partners and has facilitated over $200B in transactions. Exchange integrations include Bybit, HTX, Gate.io, WhiteBIT, and Bitget.
During the February 2025 Bybit hack, where the exchange lost approximately $1.4B from its hot wallet, funds held in Off-Exchange Collateral Vault Accounts remained protected.
BitGo Go Network differentiates through its status as a qualified custodian under US regulatory frameworks, with $250M in institutional insurance. The platform expanded in June 2025 to include HTX, KuCoin, and Gate.io. BitGo Singapore holds a Major Payment Institution license from MAS, and the company filed for an IPO following its $100M Series C.
For US institutions navigating SEC custody rules, BitGo's qualified custodian status simplifies compliance committees. The tradeoff is narrower exchange connectivity compared to Copper or Fireblocks, though the partnership with Copper helps bridge that gap.
The Neutral Middleware Thesis
Deutsche Börse's AnchorNote took a fourth path. Instead of building proprietary custody or relying on a single integrated provider, Crypto Finance chose neutral middleware. The technology provider is Bridgeport, which raised $3.2M in seed funding in July 2025, led by Further Ventures, with participation from Virtu Financial, XBTO, and Blockchain Founders Fund.
Bridgeport builds customized API adapters connecting custodians to exchanges without taking custody itself. Clients pledge assets to venue-specific accounts through AnchorNote, exchanges grant trading lines based on collateral value, trades execute without pre-funding, and net settlement occurs end-of-day through Crypto Finance's platform.
CEO Nirup Ramalingam, formerly of CME Group's EBS platform, described the architecture: "What we do is connect crypto execution venues to crypto custodians to allow trading firms to hold assets at a custodian escrow and pledge for trading."
Bridgeport has achieved SOC 2 Type 1 and Type 2 compliance and is pursuing ISO 27001 certification. In September 2025, the company partnered with Lynq settlement network, which counts B2C2, Crypto.com, Galaxy, and FalconX among its 18 institutional members.
The neutral middleware approach appeals to traditional banks entering crypto custody. Standard Chartered's Zodia Custody offers Interchange Connect for T+1 delivery-versus-payment settlement, with exchange integrations including Bybit (April 2025) and Deribit (fully automated DvP by November 2025). These banks have balance sheets, trust, and regulatory licenses but lack crypto-native connectivity infrastructure.
The constraint is coordination complexity. Middleware providers must maintain bespoke integrations with every custodian and exchange.
Tokenized Treasuries Create the Collateral Layer
The $9.11B tokenized Treasury market provides the assets institutions want to use as margin. BlackRock's BUIDL fund holds approximately $2.5B across eight blockchains, representing roughly 27% market share. Franklin Templeton's BENJI holds approximately $849M across Stellar, Ethereum, and five other chains. Ondo Finance's OUSG holds $777M, and Fidelity's quietly launched FDIT holds $204M.
Hashnote's USYC was acquired by Circle in January 2025 at $1.5B AUM. BlackRock's BUIDL becoming accepted collateral on Binance in November 2025 demonstrated that exchanges recognize the operational advantage of assets that never need to convert to cash.
The broader RWA market, including private credit, commodities, and real estate, reached $34B in October 2025. Industry projections from McKinsey suggest $2T to $4T by 2030, while Standard Chartered forecasts $30T by 2034.
Regulatory Clarity Accelerates Deployment
MiCA's December 2024 implementation created Europe's first comprehensive crypto regulatory framework. Article 75 requires crypto asset service providers to segregate customer holdings both on-chain and on internal ledgers. Custody services require €125k minimum capital plus business continuity and conflict-of-interest policies.
Crypto Finance Deutschland received its MiCAR license from BaFin on January 27, 2025, among the first providers in the EU. Circle became the first major stablecoin issuer to achieve compliance, receiving its Electronic Money Institution license from France's ACPR in July 2024. Tether remains non-compliant due to lacking an EU EMI license, leading to delisting from major EU exchanges by March 31, 2025.
In the US, the SEC rescinded SAB 121 in January 2025. The OCC issued Interpretive Letters 1183 and 1184 confirming national banks may provide crypto custody and execute client-directed trades without prior approval. On September 30, 2025, the SEC's Division of Investment Management issued no-action relief allowing state-chartered trust companies to serve as qualified custodians for crypto assets.
Traditional banks responded. Citi announced plans to launch crypto custody in 2026. Deutsche Bank applied for a German crypto custody license in 2024.
Consolidation Accelerates as Full-Stack Becomes Requirement
Recent acquisitions reflect a shift toward vertical integration.
In August 2025, Coinbase acquired Deribit for $2.9B, the largest crypto acquisition on record. Deribit processes $59B in open interest and over $1T in annual derivatives volume.
In October 2025, Ripple acquired Hidden Road for $1.25B. Hidden Road is a multi-asset prime broker clearing $3T annually across crypto, FX, and equities.
In February 2025, Kraken acquired NinjaTrader for $1.5B to gain US futures capability.
The institutional crypto custody market reached $3.2B in 2024 and is projected to grow to $27.8B by 2033 at a 26.7% CAGR. North America represented 41% of the 2024 market.
Banks invested an estimated more than $100B in blockchain settlement, custody, and tokenization infrastructure between 2020 and 2024. The EY-Parthenon 2025 survey found 83% of institutional investors have or plan crypto allocations, with 59% targeting more than 5% of AUM.
Infrastructure Becomes Invisible
When Deutsche Börse deployed AnchorNote in September 2025, the milestone received minimal attention outside trade publications. That obscurity is the point. Off-exchange settlement has graduated from crypto innovation to operational necessity.
The verified metrics confirm production scale. More than $9B in tokenized Treasuries, $50B/mo through ClearLoop, $200B+ in Fireblocks transactions, MiCA licenses activated across Europe, SAB 121 rescinded in the US. The AnchorNote launch under Deutsche Börse's umbrella signals that custody-native trading has crossed from crypto-native experimentation to a regulated market structure.
For financial institutions evaluating this infrastructure, the decision framework has shifted. The question is no longer whether to adopt off-exchange settlement but which architectural model fits operational requirements. Copper and Fireblocks offer integrated ecosystems with deep exchange connectivity at the cost of some vendor lock-in. BitGo provides qualified custodian status for US compliance. Neutral middleware approaches like Bridgeport's partnership with Deutsche Börse allow traditional banks to offer settlement services without rebuilding connectivity infrastructure.
The tradeoffs vary by institution. Market makers prioritizing millisecond latency and maximum venue access may prefer Copper's optimized network. Crypto-native funds already using Fireblocks wallets gain straightforward off-exchange access. Banks entering custody for the first time can white-label middleware solutions to compete without years of development.
Off-exchange settlement infrastructure connects these requirements. It is the plumbing that makes institutional crypto trading operationally feasible at scale. When Deutsche Börse deployed it in production, the message was clear: this infrastructure is ready, regulated, and required.