Lisa B. Saacks is President, Trillium Surveyor.

What were the key theme(s) for your business in 2024?
The key theme for our business in 2024 was navigating the complexities of evolving market conditions to ensure traders operated in a fair, transparent, and efficient environment.
The expansion of overnight trading presented unique challenges, particularly around managing risks associated with low liquidity and potential market disruptions. For traders, this underscored the importance of maintaining dynamic and adaptable surveillance thresholds to keep pace with the rapidly shifting market landscape.
Another critical focus was addressing the risks posed by low-price, low-volume securities, which drew heightened regulatory scrutiny due to their vulnerability to manipulative schemes like pump-and-dump tactics. With a notable increase in enforcement actions against firms failing to monitor trading in these securities, the need for robust, proactive trade surveillance became a top priority for ensuring compliance and maintaining market integrity.
More broadly, the regulatory environment has evolved across asset classes, and we received more questions than ever on how our trade surveillance and reporting solutions can elevate the capabilities of internal compliance teams. With comprehensive detection filters, full depth-of-book market data, and new self-service features, the Surveyor platform offers a robust set of tools for effective risk mitigation. In addition to ensuring their compliance, these capabilities enabled our clients to adopt new asset classes and strategies with minimal disruption to existing compliance workflows.
What was the highlight of 2024?
The SEC’s adoption of amendments to Rule 605 of Regulation NMS in March was an important regulatory action this year. This update was aimed at enhancing transparency in order execution for NMS stocks, effective as of June 14, 2024, and with a compliance deadline of December 14, 2025.
The amendments brought significant updates, including the expansion of reporting requirements to include broker-dealers managing 100,000 or more customer accounts. This broadens the scope of entities responsible for disclosing execution quality. Additionally, the definition of “covered orders” was revised to encompass orders submitted outside regular trading hours, those with stop prices, and non-exempt short sale orders, ensuring more comprehensive reporting.
The amendments also introduced order categorization based on notional dollar value and order type — fractional shares, odd lots, or round lots — enhancing the accuracy of order size representation. Moreover, new execution quality metrics, such as average effective over quoted spread and size improvement statistics, were introduced to provide deeper insights into execution quality.
Finally, the new requirement for firms to provide publicly accessible summary reports on execution quality is another move toward greater transparency, empowering investors to make informed comparisons.
What are your expectations for 2025?
We anticipate that heading into 2025, the crypto market is poised to be a high-volume, high-volatility environment. To enable traders to operate effectively in this dynamic space, robust trade surveillance is essential. We’ve recently partnered with Kaiko, which provides high-quality crypto market data. Additionally, the expansion of our coverage in Europe reflects our dedication to providing comprehensive tools that address the unique needs of both traders and investors.
Similarly, we’ve observed a growing regulatory focus on non-equity asset classes, particularly fixed income, prompting us to prioritize enhancements to our surveillance capabilities in these markets. Other areas of focus include expanding our best execution offerings and providing targeted support for RIAs and buyside firms—two groups that are navigating heightened regulatory scrutiny and an increasingly complex trading environment.
Within the wider regulatory landscape, we foresee changes poised to deeply influence market participants, with a particular emphasis on enhancing oversight and addressing the challenges of dynamic and evolving work environments. Additionally, FINRA’s proposed fee increases for broker-dealers, scheduled to phase in over five years starting in 2025 through 2029. While most changes will take effect in 2026, the initiative underscores FINRA’s commitment to enhancing its regulatory and oversight capabilities by securing additional financial resources.
Crypto is Poised to Improve Regulated Markets, Not Disrupt Them
By Aaron Kaplan, co-CEO, Prometheum Inc.
The crypto industry has surged in the wake of post-election optimism, fueled by expectations of a crypto-friendly administration. Nearly all prices are up—led by Bitcoin’s crescendo to $100,000—buoyed by the expectation of easing regulatory burdens and an administration that seems to favor crypto. This feels like the long-awaited moment when crypto finally upends traditional finance.
However, the reality is far more nuanced.
Over the past several years, the crypto ecosystem has become deeply intertwined with traditional finance. Financial institutions are no longer bystanders in the digital asset space; they are key players. Giant firms like BlackRock, Fidelity, and Franklin Templeton have launched products that merge crypto innovations with conventional investment frameworks, adding legitimacy and scale to a once-nascent industry.
This entanglement reflects a broader trend. Rather than replacing traditional financial infrastructure, cryptographic assets are becoming an extension of it. This transformation is being driven by the integration of digital asset securities (DAS) and their underlying distributed ledger technologies (DLT) into traditional markets—a critical yet misunderstood innovation.
From Digital Asset Securities to Digital Markets
Digital asset securities–any securities issued and transferred on a blockchain–combine the regulatory oversight of conventional finance with the speed and efficiency of distributed ledger technology. The term is widely misunderstood. DAS encompasses a wide range of potential assets beyond cryptocurrencies, including equities, debt, structured products, treasuries, ETFs, mutual funds, and money market funds.
The benefits of issuing securities on a blockchain are significant: faster settlement, fewer trade fails, more transparency, and efficient product issuance and distribution. For example, firms like BlackRock have experimented with tokenized money market funds that allow 24/7 asset transfers, real-time dividend accrual, and on-chain distributions.
Financial institutions and market participants recognize the benefits of DAS and are looking to introduce these products into regulated markets. To accommodate this, securities market infrastructure will need to transition from its current ‘electronic’ state to a digital one based on DLT and cryptographic representation of assets. This unlocks greater efficiencies, which enables product issuers to innovate new products.
A similar transition occurred in the 1980s when markets moved from paper based asset representation to electronic, creating the foundation for faster trading and the introduction of new ways to access investments, such as ETFs, that took advantage of the new electronic markets infrastructural efficiencies to offer investors better products.
Shifting from electronic to digital offers the same opportunities, of which we see glimpses of in DeFi markets.
Integrating DeFi’s Innovations into Regulated Markets
When traditional markets are able to incorporate digital asset securities, the innovations developed and refined in the roughly $20 billion decentralized finance (DeFi) market can be applied to the larger financial markets. Instead of disrupting the financial ecosystem, the real opportunity lies in applying these innovations within the $255 trillion global securities market (global equities and fixed income markets as of 2023).
Examples of this are already underway. The aforementioned tokenized money market fund from BlackRock, BUIDL, is effectively a yield-bearing stablecoin – a product born out of DeFi with immense potential. Tokenized stocks, too, are attracting interest as DLNews reported in November that investment in tokenized stocks – led by shares of Coinbase, BlackRock’s iShares Core S&P 500 ET, and Nvidia – moved up 35% to an all-time high of $10 million allocated.
While that figure is small, the trend should not be ignored; investors will gravitate towards more efficient products. Consider an index fund or ETF issued on a blockchain that is able to be offered for 50 basis points less than its traditional counterpart. For Wall Street, it’s easier to bring innovation to traditional markets—where customers are already active—than to force traditional finance participants to navigate the complexities of DeFi.
Regulation BI and the Digital Market Flywheel
Regulation Best Interest (Reg BI) is poised to be a powerful catalyst in this transformation. Reg BI requires broker-dealers to recommend products that serve their clients’ best interests. If two products are identical in structure and exposure—one issued electronically and the other as a digital asset security— and the DAS version has lower costs and greater efficiency, the DAS version should be the default choice.
This creates a flywheel effect. As more digital asset securities enter the market, their cost advantages will drive adoption among advisors and institutions, further incentivizing issuers to adopt blockchain technology. The result is a self-generating cycle that accelerates the transition to digital markets.
The Crypto Boom’s Legacy
As the crypto industry may benefit in the next several years under a friendlier business environment, the most impactful innovations will occur within traditional financial markets. Major sell side institutions are looking to issue existing products digitally in order to take advantage of the cost savings and operational efficiencies of cryptographic tokens. Cryptographic-based, commercially driven efforts by major institutions will drive the integration of digital asset securities into regulated frameworks. This process is quietly transforming market infrastructure–not through disruption, but by making the movement of assets in the bowels of Wall Street faster and more efficient.
Major institutions recognize that digitizing securities markets is simply better business, offering new efficiencies, operational advantages, and above all profit. While the focus is on the price of bitcoin, the legacy of a crypto-friendly administration will be on the modernization of traditional finance– the next chapter of global markets.
Aaron Kaplan is the co-CEO of Prometheum Inc. Its affiliates Prometheum ATS and Prometheum Capital offer an end-to-end, blockchain-enabled ecosystem for the trading (Prometheum ATS) and clearance, settlement, and custody of digital asset securities (Prometheum Capital).