Christopher Montagnano, Chief Legal Officer of Orca, delivered a speech on May 22 at a National Assembly seminar titled 'Global Digital Asset Institutionalization Trends and South Korea's Legislative Direction' held at the National Assembly Members' Hall in Yeouido, Seoul. Montagnano proposed a regulatory model where token issuers manage investor qualification requirements and enforcement occurs at the token level, eliminating the need for trading platforms to act as gatekeepers. The speech detailed Orca's year-long collaboration with US regulators and presented three live case studies of regulated assets trading on Solana blockchain. Montagnano advocated this approach as a framework applicable to any jurisdiction, including South Korea, stating that compliance should be implemented at the asset level while trading platforms maintain openness. The presentation occurred amid ongoing policy discussions in South Korea on digital asset regulation and followed Orca's submission of the 'Project Open' framework to the SEC in April and subsequent constructive dialogue with SEC leadership.
Orca Submits Project Open Framework to SEC and Engages in Regulatory Dialogue
Montagnano disclosed that Orca co-led an industry framework called 'Project Open' submitted to the SEC in April. The proposal requested permission to trade listed equities on public blockchain infrastructure with appropriate investor protections. The consortium included the Solana Policy Institute, tokenized securities issuers, and self-custody wallet providers, with Orca representing on-chain trading protocols providing liquidity in secondary markets.
Montagnano described the decision to engage directly with the SEC as deliberate, noting the agency's historically stringent enforcement stance toward DeFi companies in the US. He stated the team possessed sufficient confidence in their technology's soundness and chose to approach regulators directly rather than operate outside regulatory frameworks. The first meeting with SEC staff occurred on Montagnano's 40th birthday last year, which he described as "highly encouraging" with constructive dialogue and serious technical review by SEC personnel.
Two months prior to the seminar, the SEC published official working guidance opening an initial pathway for interfaces like Orca to support listed equity trading. Montagnano expressed gratitude to SEC Chair Paul Atkins for creating an environment where entrepreneurs and technology developers could comfortably engage in direct dialogue and freely communicate on-the-ground perspectives about technology's actual advantages and limitations. He stated that regulators and technology developers can collaborate productively when both parties engage sincerely and when technology is designed to support regulatory compliance rather than evade it.
Three Tokenized Assets Trade on Solana with Issuer-Managed Compliance
Montagnano presented three assets currently trading on Solana infrastructure, spanning a spectrum from fully open public access to fully permissioned structures requiring accredited investors. All three asset types trade on the same public non-custodial trading platform, with regulatory compliance requirements implemented at the individual asset and issuer level while the platform itself remains open.
The first case is PRIME, a token issued by Nasdaq-listed Figure Technologies, founded by SoFi's founder. PRIME provides institutional-grade private credit yields backed by home mortgages, historically accessible only to large banks. Montagnano stated that through PRIME, anyone worldwide can now access the same institutional-level returns anytime, anywhere, representing a traditional finance listed company choosing open public blockchain infrastructure to expand product accessibility.
The second case is SPCX, a token issued by Backpack, a Japan-regulated exchange, providing economic exposure to SpaceX stock. SPCX launched on Solana blockchain on the same day SpaceX listed on Nasdaq. Montagnano noted that while traditional stock exchanges like Nasdaq operate approximately 6.5 hours per day in a single time zone, this token trades 24 hours daily with equal accessibility worldwide, demonstrating global on-chain distribution enabling instant worldwide access from the moment an asset exists.
The third case is GLDY, a gold-backed security issued by Nasdaq-listed Streamex, classified as a restricted security under US securities law tradable only by verified accredited investors. Montagnano explained the compliance structure: Streamex independently conducts investor verification (KYC procedures) with Orca holding no personal investor information; Orca's technology continuously checks the issuer-managed approved wallet list and records wallet eligibility on Solana blockchain; audited on-chain programs function as gates, allowing only verified wallets to hold and trade the token while unverified parties can view markets but cannot participate in trading.
Orca Proposes Token-Level Compliance Model for Global Jurisdictions
Montagnano identified the GLDY structure as the core design principle: investor qualification requirements are managed by issuers, enforcement occurs at the token level, and trading platforms need not act as gatekeepers. In this structure, trading platforms collect no personal information and custody no one's assets, allowing investors to directly control their assets at all times. Montagnano stated that this model—implementing compliance at the asset level while maintaining platform openness—can support regulated assets in any country, including South Korea.
Montagnano described Orca's vision as expanding access to high-quality financial assets previously available only to privileged minorities in the wealthiest nations to general investors worldwide. Over the past five years, Orca processed over $500 billion in cumulative trading volume with zero security incidents and zero user asset losses. The platform uses blockchain analytics to screen high-risk wallets, preventing transactions from sanctioned wallets or sanctioned jurisdictions.
Montagnano concluded by congratulating South Korea on possessing world-class technology talent and achieving remarkable technological progress, noting that the large seminar attendance demonstrated the Korean policy community's active and in-depth ongoing discussions.
FAQ
What regulatory model did Christopher Montagnano propose at the South Korea seminar on May 22?
Montagnano proposed a model where token issuers manage investor qualification requirements and enforcement occurs at the token level, eliminating the need for trading platforms to act as gatekeepers. He stated that compliance should be implemented at the asset level while trading platforms maintain openness, describing this as a framework applicable to any jurisdiction including South Korea.
What is the GLDY token and how does it maintain compliance on an open blockchain?
GLDY is a gold-backed security issued by Nasdaq-listed Streamex, classified as a restricted security under US law tradable only by verified accredited investors. The compliance structure operates through three mechanisms: Streamex independently conducts investor verification with Orca holding no personal information; Orca's technology checks the issuer-managed approved wallet list and records eligibility on Solana blockchain; audited on-chain programs allow only verified wallets to hold and trade the token while unverified parties can view markets but cannot trade.
When did Orca submit the Project Open framework to the SEC and what was the outcome?
Orca co-led the Project Open framework submitted to the SEC in April, requesting permission to trade listed equities on public blockchain infrastructure with investor protections. Following submission and constructive dialogue with SEC leadership, the SEC published official working guidance two months prior to the May 22 seminar, opening an initial pathway for interfaces like Orca to support listed equity trading.
