Key Highlights
- SEC Crypto Task Force staff met with Clique and C Guidry Law on September 1 to discuss token-listing due diligence.
- Clique presented a framework for using public blockchain data alongside issuer disclosures and other review materials.
- The discussion covered token concentration, wallet relationships, distribution patterns and participant activity.
The U.S. Securities and Exchange Commission’s (SEC) Crypto Task Force met with representatives of digital asset infrastructure company Clique and C Guidry Law, PLLC on September 1 to discuss how crypto platforms evaluate tokens before listing them.
According to an SEC meeting memorandum, the discussion covered information used in token due diligence, including issuer disclosures and data recorded on public blockchains.
Clique Founder and CEO Charles-Nicolas Gaubert-Amy participated in the meeting. The company provided SEC staff with a document titled “Token Listing Due Diligence and Onchain Evidence,” outlining how blockchain data could be incorporated into existing token review processes.
The memorandum does not indicate that the SEC adopted or endorsed the framework.
The Crypto Times reached out to C Guidry Law for comment on the meeting and the issues discussed but did not receive a response at the time of publication.
SEC discusses onchain evidence in token reviews
The meeting focused on information trading platforms may consider when assessing a digital asset.
Token due diligence can include legal, compliance, technical, commercial and tokenomic reviews, alongside information supplied by the issuer.
Clique’s framework looks at several types of public blockchain data, including token ownership concentration, wallet relationships, distribution patterns, participant activity, and other onchain behavior.
The proposal treats blockchain data as part of a broader review rather than a replacement for issuer disclosures or other due diligence.
Clique argued that existing diligence processes can have limited visibility into how tokens are actually distributed, making blockchain records another potential source of evidence rather than a replacement for conventional checks.
Blockchain data can be compared with issuer disclosures
The discussion also considered how issuer-provided information can be compared with activity recorded onchain.
An issuer may disclose token allocations, investors or planned distributions. Once tokens begin moving, blockchain records can show how those allocations are transferred.
This can provide exchanges with another way to examine ownership and distribution patterns. However, wallet concentration or links between addresses do not by themselves indicate wrongdoing.
Addresses may be connected for legitimate reasons, including exchange operations, custody arrangements and transfers between related entities.
Wallet attribution remains a challenge
Public blockchains do not generally reveal who controls a particular address, so analysts may rely on transaction patterns and other information when linking wallets to specific entities.
Clique’s framework accounts for this uncertainty through confidence levels and false-positive considerations, with findings assessed based on the strength of the available evidence rather than treated as definitive conclusions.
The September 1 meeting did not introduce any new SEC requirements for token listings.
The memorandum also does not indicate that the agency has adopted Clique’s framework or plans to include it in future rules or guidance. Any changes to listing requirements would require separate regulatory action.
Recent task force meetings cover other crypto issues
The Clique meeting follows other discussions between the SEC Crypto Task Force and companies across the digital asset sector.
In August, the Task Force met with WisdomTree to discuss tokenized funds and the regulatory treatment of blockchain-based investment products. It also met with Offchain Labs, the developer of Ethereum Layer 2 network Arbitrum, on topics including sequencers, institutional adoption and Layer 2 infrastructure.
Earlier in July, the Task Force met with representatives from Hyperliquid to discuss regulatory issues involving the platform and its ecosystem.
The meetings have covered different areas of the market, including tokenization, Layer 2 infrastructure, trading platforms and onchain markets.
Onchain data enters the token-listing debate
The September discussion highlights a regulatory question around how much weight crypto platforms should give to public blockchain data when reviewing assets.
Onchain records can provide information about token movements and wallet activity, but interpreting that information can be difficult when address ownership or relationships cannot be established with certainty.
For now, the SEC memorandum documents a discussion between agency staff and industry participants. It does not establish a new listing standard or indicate that the SEC has endorsed Clique’s approach.
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