A financial integrity framework for permissionless networks

Many financial institutions are taking advantage of one of the most innovative advancements in blockchain technology — permissionless networks. 

Franklin Templeton has kept the official share register of its onchain U.S. government money fund on permissionless blockchains since 2021 and added the Solana network in February 2025. BlackRock has issued shares of its tokenized money market fund on Ethereum since March 2024. And in January 2025, Apollo made tokenized access to its Diversified Credit Fund available across six permissionless networks. Additional announcements touting traditional financial institutions’ deployment of products on permissionless networks continue on a near-weekly basis.

Yet, some TradFi institutions still treat permissionless networks as somehow unavailable. Instead, many banks, broker-dealers, and asset managers have been trending toward permissioned networks — systems in which a gatekeeper or consortium decides who may validate transactions, who may use or participate in the network, and for what purpose. These institutions are currently choosing permissioned networks because they believe — wrongly —  they must. The premise underlying that choice is that a known, verified set of actors is a precondition to compliance with financial integrity laws: the Bank Secrecy Act (BSA), with its anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements; and U.S. sanctions laws.