Revisiting Different DAT Strategies in the Context of Tightened Nasdaq Regulation

Author: @BlazingKevin_ , the Researcher at Movemaker

The Nasdaq announced new regulatory measures for digital asset companies last Thursday. Specifically, if such companies wish to fund their cryptocurrency purchases by issuing new shares, the plan must first be submitted for a shareholder vote to ensure investors' right to be informed.

This undoubtedly poured cold water on the crypto market, as the “DAT strategy” is seen by many as the latest wealth code. From an external perspective, it appears to be a simple and brutal financial tool: companies raise funds through listing, use the money to buy coins, and then rely on market rises to achieve positive feedback for their stock prices. In a short period, this model quickly ignited public opinion, even being packaged as a “financial gimmick” conspired between Wall Street and the crypto circle. From the market performance, BTC-related DAT has encountered a brief cold wave, the ETH narrative seems to have completed its first round of rollercoaster, while SOL's treasury model appears to be on the verge of takeoff. What kind of logic and risk is hidden behind the glamour?

The development model of DAT enterprises

The core idea of DAT (Digital Asset Treasury) is not complicated: publicly listed companies raise funds by issuing new shares, and then directly use the raised cash to buy cryptocurrencies in the market, filling their balance sheets with mainstream tokens like BTC, ETH, and SOL. In an ideal cycle, companies can repeatedly perform the spiral operation of “financing - buying coins - coin price rising - stock price following - refinancing,” as if it were a capital accelerator that can infinitely compound.

To make this narrative coherent, there are usually three paths for treasury operations:

Business Rebranding: Companies on the brink of bankruptcy transform into “crypto financial service providers,” for example, binding themselves to new narratives through staking or yield strategies.

Merger and acquisition by reverse takeover: inserting a private company focused on cryptocurrency business into a publicly listed shell company to obtain a compliant status at a low cost.

SPAC Model: Entering the capital market as a “shortcut” through a Special Purpose Acquisition Company.

The first two methods are not new, but what has been brought back into the spotlight is the SPAC tool that was once used by Circle. Its appeal lies in the fact that even without customers, products, or a mature business logic, as long as the balance sheet is filled with Bitcoin, it can quickly get a stock code listed on the exchange, directly packaging and selling Bitcoin dividends to public investors.

This approach is vastly different from the strategy of Strategy back in the day. The latter at least made an effort to emphasize the “store of value” property of BTC, while the new players almost buy up mainstream tokens first and then temporarily concoct a business story. These companies resemble hedge funds dressed in the guise of publicly listed companies, yet they are still able to attract waves of capital chasing crypto assets.

The true value of SPACs is not just that they allow companies to bypass the lengthy IPO process and go public quickly. The key point is that companies can sell investors highly imaginative plans—even in the absence of actual business—such as “BTC holdings soaring to $1 billion by the end of the year.” In this process, the founding team can even bring in giants like Galaxy to participate in PIPE (private investment in public equity) ahead of time, locking in astonishing valuations before the merger. The SEC's regulations appear to be followed on the surface, but in essence, they circumvent the sensitive status of “investment funds.”

More importantly, SPACs provide companies with the opportunity to leverage very early on: first hoarding tokens, then doubling down through equity or debt financing, using crypto assets as the underlying asset to continuously amplify their power. This mechanism allows founders to completely bypass the traditional path of “build the product first, then prove its value,” and instead drive growth directly through narrative and financial instruments. Compared to an IPO, SPACs give them greater imaginative space and operational freedom.

The combination of PIPE and convertible bonds is an important supplement to the entire script:

First, identify a suitable shell company or SPAC.

Collaborate with it to tailor a strategy for cryptocurrency asset reserves.

Cooperate with investment banks to issue PIPEs and convertible bonds, directly selling shares to institutions.

PIPEs are often sold at a discount on stocks, leaving room for arbitrage for institutions.

Convertible bonds protect investors from downside risks while providing some upside returns, making them the preferred choice for stable capital.

Unlike the initial narrative of “anti-inflation reserves” with Strategy, today's PIPE players are more aggressive. They not only buy coins but also leverage staking, lending, and other operations to accelerate the release of on-paper profits. The response from the secondary market is also extremely direct: whenever such transactions are disclosed, the company's stock price often skyrockets several times in an instant. For Wall Street, this is a skilled financial packaging technique—translating “buying coins” into a complex financial structure and then extracting expensive premiums from investors through information asymmetry.

Of course, not all companies are focused on major coins like BTC, ETH, and SOL. For smaller enterprises, those mid-cap tokens ranked in the top 50 are often more enticing targets. They are highly volatile, with astonishing potential returns, attracting a wave of small treasury companies to gamble, but more often than not, they are just fleeting and eventually washed out by the market.

What are the differences between DAT like ETH and SOL compared to BTC?

The background of enterprises holding cryptocurrencies is becoming increasingly diverse and is no longer limited to the crypto-native industry. For example, among BTC holders, there are traditional business companies like Strategy (business intelligence) and Metaplanet (hotel real estate) that use Bitcoin as a strategic reserve for value storage; there are also companies closely related to the industry, such as Mara (intellectual property/mining) and Bullish (digital asset trading).

BTC DAT is facing a cold wave, but mNAV is the most stable.

In August of this year, the stock price of Strategy fell by a cumulative 16.8%, nearly erasing the valuation premium the company had enjoyed for years due to its Bitcoin holdings. This is not just a simple stock price adjustment, but more like a prelude to the gradual loss of luster of the Bitcoin corporate treasury story.

In fact, as emerging DAT strategies like Ethereum gradually take root, the industry position of Strategy as a “pioneer” is being diluted. Even more critically, there has been a turning point in the financing method. The company originally planned to raise funds by issuing preferred shares to purchase Bitcoin, but only managed to raise 47 million dollars, far below external expectations. The funding gap forced it to restart the issuance of common shares, which undoubtedly breaks the previously promised principle of “controlling dilution.” In the context of the capital market, this means a loss of credibility.

This kind of turnaround is not an isolated case. By observing the capital flows of BTC, ETH, and SOL, it is not hard to find that the market is moving towards diversification, and Bitcoin treasury firms are the first to feel the pressure of capital diversion. As the earliest groups to attempt this model, they are also the first to enter a period of adjustment and pain. Currently, about one-third of publicly traded companies holding Bitcoin have stock prices that are even lower than the book value of their Bitcoin. This is particularly fatal for small enterprises: tight liquidity makes every equity financing exceptionally difficult, while heavy convertible bond interest and approaching repayment deadlines further compress the space for survival.

Companies that can truly succeed often share two common traits: one is that their community consensus is strong enough, and the other is that they can continuously increase the “Bitcoin holdings per share” and build financial engineering around it. Conversely, companies that lack sustained strategic support are mostly eliminated by the market. For example, SOS Limited, after transitioning from crypto mining to commodity trading, not only faced difficulties in its main business, but also struggled to maintain its Bitcoin strategy, ultimately lagging far behind its peers. This shows that the model of “heavily investing in Bitcoin” is more favored by the market than “symbolic allocation.”

Of course, such companies still face the impact of extreme volatility. When a company's net assets exceed its market value, it may create a reversal opportunity; however, for financially precarious companies, simply retaining a small amount of Bitcoin on the books is clearly insufficient to change the fate of bankruptcy. Moreover, when a company's strategy extends to tail tokens, the risks are doubled. These assets lack the hard asset properties of Bitcoin and also lack stable buying support, making them prone to collapsing first during market adjustments.

ETH DAT offers diversified returns, but mNAV is at a significant discount.

According to the latest Strategic ETH Reserve data, over 70 companies, listed firms, or institutions globally have incorporated ETH into their strategic reserves (with individual holdings exceeding 100 coins). The total holding has surpassed 4.7 million coins, valued at approximately 2 billion USD, accounting for 3.89% of the total Ethereum supply. Among them, about 14 companies have explicitly disclosed their “Ethereum treasury strategy,” with a total holding close to 3 million ETH, valued at approximately 12.86 billion USD.

Unlike the “single holding” strategy mainly adopted by Bitcoin treasury companies, those entering the ETH treasury track exhibit significant differentiation in asset utilization models. Their strategies can be broadly classified into four categories: one is the “delegated type” that relies on third-party staking services to obtain stable returns; another is the “self-operated type” that directly embeds into the network through self-operated nodes and liquid staking; a more aggressive category combines operations such as lending, liquidity provision, and MEV optimization to maximize capital efficiency; and another group is exploring advanced leverage strategies like circular lending in an attempt to amplify asset returns.

The trends of the top five companies among the current holdings are particularly representative:

BitMine became the largest corporate holder just two months after launching its ETH treasury strategy, with holdings soaring to over 1.52 million coins, targeting 5% of the total ETH supply. Notably, Peter Thiel has acquired a 9.1% stake in it. If staking is initiated subsequently, the profit potential is extremely promising.

SharpLink Gaming was originally a sports betting company, and in June it officially positioned ETH as its core reserve asset, appointing Ethereum co-founder Joseph Lubin as chairman of the board. Its holdings are now nearly fully staked, creating a stable source of passive income.

The Ether Machine is formed through a SPAC merger, planning to hold over $1.5 billion in ETH. The management has publicly stated that they will focus on staking, re-staking, and DeFi operations, and even mentioned attempting circular lending on Aave.

Bit Digital has completed its transformation from a traditional mining company to an Ethereum asset management and staking platform, with a clear strategic positioning.

ETHZilla has shifted from biotechnology to the entertainment and gaming industry, while also developing accumulation tools related to ETH, with the presence of Peter Thiel's investment team behind it.

Overall, the logic of the ETH treasury is different from that of Bitcoin. The core value of Bitcoin is more reflected in its positioning as a “reserve asset,” while the advantage of ETH lies in its native revenue channels. The current nominal yield rate for Ethereum staking is about 2.95%, with an inflation-adjusted real yield rate of 2.15%. If 30% of the existing corporate holdings are staked and the ETH price remains at the level of $4000, the corresponding annualized revenue scale is about $79 million. This figure reflects that ETH treasury enterprises can obtain relatively stable cash flow beyond price fluctuations.

On the operational level, enterprises mainly have two paths to choose from: one is to directly run verification nodes; the other is to leverage liquidity staking protocols (such as Lido, Coinbase, RocketPool). The U.S. SEC has clarified that such protocols are not recognized as securities, which has cleared compliance obstacles for institutional participation and allowed them to additionally obtain liquidity tokens as derivative assets.

These derivative assets (such as Lido's stETH) have a high degree of composability in the DeFi market and can further be used as lending or liquidity mining tools. Taking Aave v3 as an example, its ETH and stETH liquidity pool has exceeded 1.1 million ETH. With more treasury funds from enterprises flowing in, the size of this liquidity pool is expected to continue expanding, thereby significantly enhancing market liquidity while improving yields.

The core competitiveness of ETH DAT lies in the hierarchical and scalable structure of its收益. This gives it a stronger latecomer advantage when compared to Bitcoin DAT.

SOL DAT aims to rise above others, but its scale is still small.

More and more listed companies are starting to hold SOL on their balance sheets. Currently, Solana's total market value is about $107 billion, and data shows that listed companies hold more than 4 million SOL, worth over $800 million. However, the stock prices of these companies are not performing well, which may be because the reserve market for Solana has not yet seen a true leading strategy and also because the SOL ETF has not yet been approved.

However, a new wave of capital is rushing in. Currently, the SOL held by listed companies only accounts for 0.69% of the circulating supply, while recently Pantera Capital committed to invest $1.25 billion, and the three firms Galaxy, Multicoin, and Jump jointly committed to invest $1 billion, which collectively amounts to 3.5 times the current holdings of listed companies.

More specifically, Galaxy, Multicoin, and Jump intend to acquire a publicly listed company to create a digital asset financial firm focused on Solana. Meanwhile, Pantera, led by former Tiger Management executive Dan Morehead, also plans to raise $1.25 billion to acquire a Nasdaq-listed company and transform it into an investment firm focused on SOL, tentatively named “Solana Co.” It's worth noting that Pantera and Galaxy previously bought a significant amount of SOL at a low price from the bankrupt FTX, making a substantial profit. In simple terms, their new moves can be understood as—having made enough money, they are ready to increase their stakes.

The rise of the DAT company model represents a brand new and advanced value capture method for these institutions. Through DAT, they can not only hold SOL while waiting for price increases but also earn stable profits through various DeFi protocols, achieving multiple asset appreciation.

The trend of Bitcoin over the past two years shows that when institutions begin to systematically accumulate a certain cryptocurrency, that asset often enters a relatively stable upward channel. The example of Ethereum has already illustrated this point. The differences between Solana and Ethereum DAT enterprises are also very clear: a significant part of the reason institutions choose ETH is its decentralization, while Solana is favored for its public chain characteristics and potential for user-facing applications.

From the perspective of the absorption efficiency of trading supply volume from DAT, the $2.5 billion SOL DAT plan brought by Galaxy and Pantera is equivalent in power to the financing scale of $30 billion for ETH or $91 billion for BTC. The efficiency of SOL DAT can be higher than that of ETH for two reasons: first, the circulating supply does not equal the tradable volume; currently, 63.1% of Solana's tokens are staked, meaning very few are actually tradable in the market; whereas the staking rate for ETH is only 29.6%, allowing for a larger tradable volume, making it harder for the price to be pushed. Second, in terms of relative capital impact, SOL's market value is much lower than that of ETH and BTC, so from a relative valuation perspective, investing $1 in SOL DAT has a far greater effect than the same investment in ETH and BTC.

Moreover, with the SOL ETF expected to pass by the end of this year, the impact of this wave of buying behavior on the price may become more pronounced.

The DAT expectations for BNB and a host of tail assets.

BNB DAT

CEA Industries: Aiming for 1% of BNB's total supply

CEA Industries (stock code: BNC) recently announced that it has increased its holdings of BNB to 388,888 coins, with a market value of approximately $330 million. The company plans to reach a holding of 1% of the total supply of BNB, or about 10 million BNB, by the end of 2025. This move highlights its strategy of making digital assets a core part of its business, similar to MicroStrategy's strategy in the Bitcoin space. Additionally, CEA Industries is partnering with 10X Capital to accept a $500 million private placement investment from YZi Labs, which includes $400 million in cash and $100 million in crypto assets, to further expand its BNB reserves.

Nano Labs: Steadily Increasing BNB Reserves

Nano Labs (NASDAQ: NA) currently holds approximately 128,000 BNB, with an average acquisition cost of $713 per coin, totaling a market value of about $108 million. The company has increased its holdings by 8,000 BNB through OTC, demonstrating its commitment to BNB as a long-term store of value. This strategy may lay the groundwork for its further expansion in the digital asset space.

Liminatus Pharma: Established a subsidiary “US BNB Strategy”

Liminatus Pharma (Nasdaq: LIMN) plans to raise up to $500 million in phases over the next few years through its newly established subsidiary “American BNB Strategy” to strategically invest in BNB. This initiative marks a traditional biopharmaceutical company's active embrace of digital assets, exploring the possibility of incorporating BNB into its asset allocation.

Windtree Therapeutics: Uses $520 million in financing for BNB strategy

Windtree Therapeutics (NASDAQ: WINT) announced plans to raise up to $520 million, with 99% of the funds allocated for the purchase of BNB to enhance its digital asset treasury. The company has partnered with Kraken as its custodian service provider for its BNB holdings. This move demonstrates the proactive transformation of traditional biotechnology companies in the digital asset space.

Huaxing Capital: The first listed company in Hong Kong to directly hold BNB.

Huaxing Capital signed a memorandum with YZi Labs in August 2025, planning to invest 100 million USD to purchase BNB, becoming the first Hong Kong listed company to directly hold BNB. In addition, Huaxing Capital also plans to launch compliant BNB fund products and establish a stablecoin based on BNB and RWA for on-chain applications.

B Strategy: Plans to raise $1 billion to establish the BNB Treasury Company

The B Strategy plans to go public in the United States and establish a treasury company focused on BNB investments, aiming to raise $1 billion. The company has received strategic support from YZi Labs.

Amber International and Hash Global: Launch of the BNB Fund

Amber International (NASDAQ: AMBR) has partnered with Hash Global to launch the BNB Fund, which aims to use its $100 million cryptocurrency asset reserve for BNB investments. This fund serves as a blockchain-native income product designed to provide institutional investors with a stable source of income.

Ethena and SUI's DAT layout

Ethena (ENA): Strategic investment between StablecoinX and Mega Matrix

Ethena's native token ENA is attracting the attention of institutional investors. StablecoinX plans to raise $895 million through a SPAC merger to reserve ENA tokens. In addition, Mega Matrix has submitted a $2 billion structured registration statement to the U.S. Securities and Exchange Commission (SEC) to reserve USDe and ENA.

SUI: The strategic layout of Sui Group Holdings

Sui Group Holdings is the only publicly listed company supported by the Sui Foundation, holding approximately 102 million SUI tokens, with a market value of about $345 million. The company plans to continue raising capital to purchase more discounted locked SUI tokens to increase the amount of SUI held per share, thereby creating value for shareholders.

Can non-mainstream DAT generate enough influence to even continuously create a positive flywheel? The most important thing is not whether mNAV remains greater than 1 and in a premium state: mNAV may drop below 1, leading to a discount, but for these companies, selling crypto assets in a discounted state is an act that accelerates their demise.

The core focus of evaluating non-mainstream DAT should be its financing ability and buying capability:

The former represents the optimism and confidence in the cryptocurrency asset. Whether the company has good financing channels to buy in when there is a discount or when the cryptocurrency enters a downward cycle is the best endorsement for DAT enterprises. The positive effects generated by the financing scale can, to a certain extent, promote mNAV. Observing the DAT processes of the three cryptocurrency assets mentioned above, both BNB and Ethena's DAT enterprises have very strong and extensive financing capabilities, making it more likely to promote the positive development of coin-stock prices in the long term.

Secondly, the ability to continually buy is also key. Continuously and disciplinedly executing its investment strategy to demonstrate its research and timing abilities to the market is the foundation for building a brand and winning a premium. When discounts occur, having enough ammunition to continue buying is the best confidence injection to prove to the market.

BNB, Ethena, and Sui have not yet experienced this stage, but after the FOMO of mainstream DAT subsides, whether tail-end asset DAT enterprises can survive, aside from the two factors mentioned above, may hinge on whether they can offer more asset gameplay for crypto protocols: Wall Street has only brought incremental capital, the key is how to leverage that capital within the market. How to maximize asset efficiency, innovate programmable liquidity, and capture value in multiple dimensions. Precise financial engineering and tangible returns will allow the best performers among tail-end DATs to stand out.

Rationally view the DAT flywheel

DAT is not a sophisticated financial innovation; it is essentially more like a regulatory arbitrage tool: in the context where the regulation of existing crypto assets is not yet fully clarified, Wall Street or certain listed companies achieve rapid allocation of crypto assets through the DAT framework. This wave of DAT enthusiasm superficially appears to imitate the strategic layout of MicroStrategy, but the core driving force comes more from the market FOMO sentiment during a period when official regulatory channels are still lenient. In other words, the prosperity of DAT has a clear speculative color in the short term, and its sustainability depends on the dual influence of market sentiment and regulatory policies.

Under the flywheel mechanism, DAT can amplify returns during a bull market: asset market value rises, mNAV premium increases, and liquidity enhances, creating a positive feedback loop. However, once the market reverses, this mechanism can also amplify risks. When mNAV discounts or premiums disappear, some DAT companies may be forced to liquidate assets, triggering a chain selling pressure, thus magnifying short-term price fluctuations. The structure of DAT is complex, attracting institutional funds while exacerbating information asymmetry, making it difficult for retail investors to fully understand risk exposure and the true value of assets.

From a valuation logic perspective, DAT may bring the market back to a “story-driven” phase: prices in the short term rely more on market expectations, concept popularity, and institutional participation. The influx of hot money may drive prices up, but this rise lacks underlying value support. While the rise of Ethereum DAT is expected to boost on-chain staking, DeFi activity, and ecological participation, its long-term impact on corporate profitability and the overall health of the ecosystem remains highly uncertain.

Overall, the DAT flywheel can generate short-term gains and market attention during prosperous market conditions, but investors need to rationally recognize its limitations: high leverage amplifies upside gains but also amplifies downside risks, while regulatory pressure, liquidity tightening, and mNAV discounts are key factors that could potentially disrupt this inflated structure at any time.

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Disclaimer:

This article/blog is for reference only and represents the author's personal views, and does not represent the position of Movemaker. This article does not intend to provide: (i) investment advice or recommendations; (ii) offers or solicitations to buy, sell, or hold digital assets; or (iii) financial, accounting, legal, or tax advice. Holding digital assets, including stablecoins and NFTs, involves high risks, with significant price volatility, and they may even become worthless. You should carefully consider whether trading or holding digital assets is suitable for you based on your financial situation. If you have specific questions, please consult your legal, tax, or investment advisor. The information provided in this article (including market data and statistics, if any) is for general reference only. Reasonable care has been taken in compiling this data and charts, but no responsibility is accepted for any factual errors or omissions expressed therein.