Written by: Charlie Little Sun

The last time I wrote about the future, every company should become a DAT company, a flood of questions came in: some asked for specific operational methods, while others inquired about risk assessments.

Recently, the SEC and FINRA have intensified their scrutiny of DAT companies, and the secondary market has voted with its feet, causing many DAT companies' mNAV to drop below 1.

The result is actually quite good—less hype, more real skills.

My basic judgment remains unchanged: DAT is still worth serious consideration by all companies.

Moreover, I now emphasize one point more strongly—DAT is not for speculators; it belongs to true operators.

Whoever can design the law and public opinion well, build a resilient balance sheet, and more importantly, allow digital assets to feed back into the business rather than amplify stock price fluctuations, deserves this capability.

Regulatory and Market Adjustments

What did the last cycle teach us?

Companies that treat "holding crypto assets" as a headline often enjoy a day of excitement, only to face the gravity of compliance processes, information disclosure rhythms, and trading controls.

Regulatory agencies are not afraid to peel back the layers and examine the linkage between announcements and trading. Meanwhile, the secondary market has become more pragmatic: the so-called mNAV premium has disappeared, and many companies heavily invested in digital assets have seen their market value drop to equal or below the value of the assets they hold.

This is a heavy blow to speculators, but it serves as a wake-up call for long-term builders. The drop of mNAV below the benchmark of 1 is not a denial of digital assets, but a judgment on strategy and capital structure: if what you bring to the table is only β, then the game has changed.

So, especially for publicly listed companies that need to submit reports to auditors, exchanges, and long-term institutions, what does it mean to "succeed" in DAT?

Step One: Compliance Disclosure

Compliance and law are not footnotes; they are core functions like products.

DAT should be treated as a significant corporate action: information disclosure must be rigorous, internal controls must cleanly separate "insider knowledge—trading," and all plans should be assumed to be price-sensitive information before disclosure.

Set a blackout period around inventory adjustments, and all external communications should go through legal; fully map the accounting impact of fair value into P&L and MD&A.

For cross-border operations, additional requirements from various jurisdictions and exchanges must be layered on.

A truly credible DAT may even appear a bit "boring" from the outside, because the goal of the system is to avoid dramatization—which is precisely a manifestation of professionalism.

Step Two: Capital Management

The balance sheet must be rigorously resilient.

In recent years, we have seen too many extreme market conditions; pretending that the next market shock won't come is irresponsible to shareholders.

Conduct stress tests based on at least 80% peak-to-trough drawdowns in crypto assets, strictly separate operating cash from asset allocation, and ensure that you are never forced to sell at a low point.

If using debt, the duration should be long, LTV should be conservative, and sufficient unencumbered buffer assets should be reserved.

If using equity financing, also be clear about the "feedback loop" of mNAV: when the market gives you asset premiums, moderate issuance is equivalent to exchanging "expensive stock" for "cheap cash/assets," which enhances per-share value.

When the market prices below the holdings, prioritize buybacks or other tools to reduce value transfer caused by discounts and encourage discount convergence.

The healthiest DAT resembles long-term capital allocation rather than momentum trading, with the capital structure designed from the outset to "weather the storm."

Step Three: Business Synergy

DAT that is only being done by finance will always be treated as macro allocation; only DAT that can reach products and operations will create the compounding value of synergy.

Companies with large cross-border settlement volumes can use stablecoin channels to reduce friction and working capital usage.

Companies that operate bilateral platforms can use on-chain incentives to engage core users, which may reduce CAC and stabilize retention more effectively than outsourcing a points system.

Companies involved in infrastructure, custody, or data analysis should hold and use the assets they serve—not for speculation, but as a true "hands-on involvement."

The test is actually quite simple: can an external person who understands the business clearly state that having DAT is definitely better than not having it?

If the answer is negative, then it’s time to rethink the strategy.

Underlying Logic of the Macro Environment

In the face of a global long-term inflation trend, DAT serves as a "hedge" against monetary distortion.

Global talent increasingly prefers to fluidly and permissionlessly share the value they create; DAT acts as a "magnet."

When geopolitical risks rise, DAT acts like a "circuit breaker," preventing capital from being passively locked out.

Every force reinforces one conclusion: putting a small portion of the company's net worth that can be tolerated on-chain, disclosed, hedged, and held long-term is rational.

Another macro variable worth noting is: AI and intelligent agents.

If the last era was about humans speculating around blockchain, the next era will be about machines directly using blockchain.

Intelligent agents will not fill out vendor forms, will not wait for net 30-day payment terms, and will not manually reconcile accounts; what they need is the "native language" of instant payments, programmable custody, and verifiable states.

On-chain assets, stable settlements, and composable liquidity will gradually become the native tracks for transactions between machines.

At the implementation level, three "pulls" will emerge.

Internal AI systems within enterprises can autonomously manage micro-payments, real-time settlement of computing costs, and collateral guarantees as long as there are suitable tools in the balance sheet; your customers, with their own intelligent agents, will also prefer tracks with "certain outcomes"; the developer ecosystem will treat custody, wallets, and token gating as primary interfaces, no longer just sandbox testing.

The benefits will be tangible: fewer intermediaries, lower reconciliation costs, and tighter cash cycles.

The biggest risk here is poor product design: if you first deploy AI intelligent agents and then think about DAT treasury, you will either trap value in silos or bear unlimited settlement risks.

The correct answer is to integrate DAT with AI in a unified design—policies, internal controls, asset combinations, and payment paths, implemented as a system simultaneously.

Action Checklist for Operators and Investors

For CFOs and boards of publicly listed companies, start with first principles: what specific problems will DAT solve for the company in the next three years?

Write it into a policy that is acceptable to auditors and can be priced by investors; choose assets and tracks that match the scenario, rather than those that match the hot topics.

Agree on a disclosure rhythm and risk dashboard from day one, so investors know how to read the signals.

The operating cash pool must have hard boundaries, and stress tests should ensure that even in the worst case, you do not sell at the lowest point.

Involve products and sales in the plan—can settlement, incentives, or data credibility change core KPIs?

Finally, communicate in advance with long-term cornerstone shareholders. Good shareholders will not require you to hold nothing; they will only ask you to hold assets that are reasoned and valuable.

For investors researching or allocating DAT targets, the filter is equally simple: see who prioritizes compliance disclosure and capital buffers; see who can withstand drawdowns while iterating products; see who uses on-chain assets in core business engines—payments, incentives, identity, computing power—rather than just stopping at press releases.

Conclusion

The tightening of regulation and the market is not the opposite of innovation, but rather the premise of sustainable innovation.

DAT has graduated from the "easy mode" and entered the "merit-based" era.

This is good for the market.

It is even better for true operators who adhere to first principles and long-termism.

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