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TLDR

  • Institutions have historically sacrificed the openness and liquidity of public networks in favor of the greater trust and predictability of more closed models. Past precedents include permissioned counterparties, private clearing networks, and dark pools.
  • Most public blockchains fail the key tests that institutional compliance requires. However, the evolution of Avalanche’s sovereign L1s and Avalanche Interchain Messaging creates a model that meets the institutional compliance standards that have been established over the past few decades.
  • What’s more, Avalanche creates a unique value proposition by giving institutions the security of private networks without completely sacrificing access to more public markets. With compliance standards now met, Avalanche is seeing an influx of institutional interest and capital.

For years, institutional allocators have understood the significant opportunities created by public blockchain networks. However, compliance officers have been hesitant. In order to feel comfortable moving forward with adoption, institutions have needed blockchain structures that fit within the previously established and familiar frameworks.

In order to pass institutional muster, networks must typically pass three tests: 

  1. Can the institution feel confident that they know who they are transacting with?
  2. Does the institution have isolated infrastructure with significant controls in place?
  3. Are there defined transaction rules that can’t change arbitrarily? 

Public blockchains have historically failed these three tests due to their open access, undefined counterparties, and shared congestion.

In this piece, we explore the historical precedents behind these tests, and how the specific architecture of Avalanche’s sovereign L1s now allow institutional compliance teams to move forward with greater confidence, using the same logic that cleared institutional committees decades ago.

THE TRADEOFFS THAT INSTITUTIONS ARE WILLING TO MAKE

The three previously mentioned tests were born from a historic precedent, in which institutions have consistently chosen to give up the greater openness and accessibility of more public markets in exchange for the greater trust and predictability of more closed networks.

  • Permissioned Counterparty Networks: International wire instructions used to travel by telex, which offered weak authentication and little standardization across banks, creating significant fraud and operational risks.¹ In 1973, 239 banks across 15 countries agreed to form a permissioned counterparty network: the SWIFT network. With stronger authentication and standardized message formats that enabled end-to-end automation, the result was greater speed and trust, addressing major counterparty identity challenges in the process.
  • Private Clearing Networks: The rapid growth of over-the-counter derivatives in the 1990s created a different problem: bilateral credit exposure. Every derivatives contract represented direct exposure between two counterparties, with no buffer between them if one defaulted. The scale of that unnetted exposure became visible during the 2008 financial crisis, when Lehman Brothers’ default created cascading settlement failures across the market. Dodd-Frank codified what institutions had already begun building: central counterparty clearinghouses that interposed a capitalized entity between both sides of every trade, netting exposures and defining the risk.² The tradeoff was accepted membership requirements and mandatory margin posting, in exchange for bounded, legible counterparty exposure and isolated settlement infrastructure.
  • Dark Pools: Large institutional orders on public exchanges created an information leakage problem. A sizable sell order on a public exchange telegraphs intent to the market before the trade can fill, moving price against the institution while it’s still executing. In response, major banks had built private trading venues where orders weren’t visible until after execution. Participation was restricted to approved institutional counterparties. The tradeoff was giving up the price transparency and open access of public markets in exchange for executing large orders without broadcasting intent. Despite ongoing regulatory scrutiny, dark pools became a standard feature of institutional trading infrastructure by the early 2000s.³

In each case, compliance approval (and, accordingly, institutional adoption) rested on the same logic: a specific risk, a permissioned structure that bounded it, and a legible tradeoff in which the institution gave up some openness for greater controls.

PUBLIC BLOCKCHAINS HISTORICALLY FAILED THESE TESTS

On public blockchains, counterparty identities were undefined by design, with anonymous addresses offering no clear KYC/KBC compliance path. Shared infrastructure meant that a surge in activity from an unrelated application could spike fees or delay settlement for everyone on the network, leading to uncertainty around execution and performance. 

Meanwhile, governance of these public blockchains was external: a protocol upgrade passed by a distributed validator set could alter the rules for everybody on the network, including the institutions who had built infrastructure on it, without their consent. 

Public blockchains may have been a technological evolution. But for compliance officers who had spent decades approving permissioned structures precisely because they solved these problems, they represented a significant regression when it came to risk management.

Public blockchains may have been a technological evolution. But for compliance officers who had spent decades approving permissioned structures precisely because they solved these problems, they represented a significant regression when it came to risk management.

AVALANCHE INTRODUCED A SIGNIFICANT COMPLIANCE BREAKTHROUGH

In April 2023, Ava Labs launched the Evergreen initiative, a suite of institutional blockchain deployments and tooling designed specifically for financial services requirements: permissioned validator sets, KYC/KYB controls, and jurisdictional geofencing built into the network layer.⁴ 

The framework was directionally right, but it had a structural gap. Under the original subnet architecture, validators on any Evergreen deployment were still required to participate in the public Primary Network. That dependency was disqualifying for institutions requiring complete operational isolation to meet regulatory requirements.

The Avalanche9000 upgrade, which went live on December 16, 2024, closed that gap. The key change, introduced through ACP-77, allowed L1 validators to operate independently of the Primary Network entirely.⁵,⁶

Institutions could now launch fully isolated networks with their own dedicated validator sets, walled off from public network activity, while retaining the ability to interoperate with the broader Avalanche ecosystem through Interchain Messaging when they chose to. The compliance objection that had previously been unanswerable was resolved at the protocol level.

Together, the Evergreen initiative and Avalanche9000 upgrade addressed the three failure points that historically blocked public blockchains from clearing institutional compliance review.

  1. Institutions know who they are dealing with: Evergreen L1s support KYC/KYB validator requirements, meaning institutions can restrict network participation to credentialed counterparties. Jurisdictional geofencing adds a further layer of control, allowing institutions to limit participation to approved jurisdictions.⁷ The identity problem that structurally blocked public blockchain adoption from institutional compliance review is now configurable at the network layer.
  2. Institutions have isolated infrastructure they control: Each Evergreen L1 runs its own dedicated validator set and its own execution environment, walled off from public network activity. A congestion event on the broader Avalanche network does not propagate into an institution’s L1. Blockspace is not shared. The execution uncertainty that made public blockchains unsuitable for institutional settlement is eliminated by design.
  3. Institutions control and define their own rules: Each L1 sets and controls its own fee structures, transaction rules, and upgrade path. A governance vote on the public Avalanche network cannot rewrite the rules of a sovereign L1. Rule changes require the institution’s own consent through its own defined process. What this eliminates is the specific risk compliance teams historically flagged: external, unilateral modification by a network the institution does not control.

Taken together, these adaptations allow Avalanche’s architecture to no longer be treated as a novel structure for compliance officers. Now, institutional teams can use the same parameters that cleared SWIFT, CCPs, and dark pools across four decades of institutional infrastructure development.

A BETTER TRADE-OFF: PRIVATE CONTROLS, PUBLIC ECOSYSTEM

The three compliance tests Avalanche now passes are necessary conditions for institutional adoption, but they aren’t sufficient by themselves. Even if a blockchain passes a compliance review, institutions still have to ask: is the architecture actually worth deploying on?

It’s worth remembering that institutions achieved their past compliance goals by accepting a significant cost: isolation. A permissioned network is, by definition, cut off from outside participants, which reduces reach and liquidity. 

However, the introduction of Avalanche Interchain Messaging in December 2022 helped reduce that isolation cost, allowing institutions to keep the security of permissioned networks while maintaining some access to the more public markets available on Avalanche.

Interchain Messaging makes it so Evergreen L1s can communicate with and transfer assets across the broader Avalanche ecosystem while maintaining their permissioned controls internally. An institution operating a sovereign L1 retains full KYC/KYB restrictions on its own validator set and counterparty access, while selectively interacting with public Avalanche infrastructure, liquidity, and developer tooling. 

To be clear, Interchain Messaging reduces the historical tradeoff between control and connectivity, but doesn’t entirely eliminate compliance risk when operating with the public network. Institutions will need to define what cross-chain interoperability they permit and what they restrict, based on their own risk models.

However, it does provide, for the first time, an optionality that prior private network models had structurally foreclosed. This gives institutions something demonstrably new: the trusted controls of a private network while maintaining optional access to a public liquidity and developer ecosystem.

GROWING INSTITUTIONAL ADOPTION ON AVALANCHE

As compliance officers recognize both the historical precedence for Avalanche L1s and the significant opportunities they create, traditionally cautious institutions are increasingly onboarding with confidence that Avalanche’s structure fits the frameworks they’ve already deemed acceptable. 

  • Wyoming’s state legal team cleared Avalanche as a deployment environment for FRNT, the first U.S. state-issued stablecoin in the country’s history, in January 2026.⁸,⁹
  • VanEck’s legal team cleared VAVX, the first U.S.-listed ETF combining AVAX price exposure with staking rewards, for listing on Nasdaq in January 2026.¹⁰
  • Franklin Templeton expanded its Franklin OnChain U.S. Government Money Fund, making it the first U.S.-registered mutual fund deployed on Avalanche, in August 2024.¹¹

Compliance is the prerequisite condition for broader adoption, and growing awareness and familiarity is a significant reason why Avalanche is seeing increased adoption and interest from major institutional partners, with Ava Labs now reporting dozens of institutional partners across the ecosystem.¹²

REFERENCES

  1. Scott, S.V. and Zachariadis, M. “Origins and Development of SWIFT, 1973-2009.” Business History, Vol. 54, No. 3, 2012. Available via LSE eprints: https://eprints.lse.ac.uk/46490/1/Origins%20and%20Development%20of.pdf
  2. U.S. Commodity Futures Trading Commission. “Central Counterparty Clearing.” CFTC Background. https://www.cftc.gov/PressRoom/PressReleases/pr6395-12
  3. U.S. Securities and Exchange Commission. “Regulation of Non-Public Trading Interest.” SEC Concept Release, 2010. https://www.sec.gov/rules/concept/2010/34-61358.pdf
  4. Ava Labs. “Evergreen: Institutional Blockchain Deployments on Avalanche.” evergreen.avax.network. https://evergreen.avax.network/
  5. Ava Labs. “Avalanche9000: The Etna Upgrade and ACP-77.” Avalanche Developer Documentation. https://build.avax.network/academy/avalanche-l1/avalanche-fundamentals/03-multi-chain-architecture-intro/03a-etna-upgrade
  6. The Block Research. “Unlocking Avalanche Layer 1s with ACP-77.” The Block, 2024. https://www.theblock.co/post/312121/research-unlock-unlocking-avalanche-layer-1s-with-acp-77
  7. Ava Labs. “Avalanche L1s: Developer Documentation.” build.avax.network. https://build.avax.network/docs/avalanche-l1s
  8. Ava Labs. “FRNT Goes Live: The First U.S. State-Issued Stablecoin You Can Actually Use.” avax.network, January 2026. https://www.avax.network/about/blog/frnt-goes-live-the-first-u-s-state-issued-stablecoin-you-can-actually-use
  9. The Defiant. “Wyoming Launches First U.S. State-Issued Stablecoin.” January 2026. https://thedefiant.io/news/defi/wyoming-launches-first-u-s-state-issued-stablecoin
  10. BusinessWire. “VanEck Introduces Another First with Launch of the VanEck Avalanche ETF (VAVX).” January 26, 2026. https://www.businesswire.com/news/home/20260126788202/en/VanEck-Introduces-Another-First-with-Launch-of-the-VanEck-Avalanche-ETF-VAVX
  11. CoinDesk. “Avalanche Becomes Latest Blockchain to Support Franklin Templeton’s Tokenized Money Market Fund.” August 22, 2024. https://www.coindesk.com/business/2024/08/22/avalanche-becomes-latest-blockchain-to-support-franklin-templetons-tokenized-money-market-fund
  12. Avalanche. @avax, X (formerly Twitter), 2026. https://x.com/avax/status/2016541493628993604

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