The Growing Gap For Investors Outside The U.S. To Access Crypto ETFs
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The U.S. crypto exchange-traded fund (ETF) market has experienced tremendous growth in 2024, fueled by
bitcoin and Ethereum ETFs. As of August 2024, the total market capitalization for Spot and Futures
Bitcoin ETFs exceeded $78 billion, and $7.81 billion for Ethereum ETFs according to Blockworks’ ETF
tracker.
The 11 Spot Bitcoin ETFs approved early this year reached $30 billion in trading volume in the last
month alone, highlighting the increasing demand for safe crypto exposure from retail investors.
Upstream ETF Tracker September 18, 2024.
trackinsight
While U.S. investors are benefiting from this surge, retail investors outside the U.S. face many
barriers to accessing crypto ETFs, which is limiting the global adoption of crypto through safer
regulated channels.
Following the launch of spot bitcoin and Ethereum ETFs, the U.S. captured 83.3 percent of the global
market, overtaking Canada, which previously held a 46.3 percent market share, according to data from
CoinGecko.
This shift points to the U.S. market’s growing influence in the cryptocurrency ETF space, as the SEC
approvals have fueled notable investor interest and driven adoption.
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Crypto ETFs Outside Of The U.S.
Spot bitcoin ETFs are currently available in Canada, Germany, Brazil, Australia, Switzerland, Hong Kong,
and several other jurisdictions, however many only cater to institutional clients and exclude retail
investors from participating.
European retail investors currently lack access to U.S. spot bitcoin and Ethereum ETFs due to
regulations. MiFiD prohibits firms to sell funds to European retail investors which do not provide
regulatory documents such as a Key Information Document (KID), which differ to the U.S. disclosure
regime.
Countries within Europe like Germany and France have slightly more advanced regulatory frameworks for
cryptoassts and offer access to crypto through Exchange Traded Notes (ETNs), unsecured debt securities
that track an underlying index of securities and trade on an exchange like a stock.
Europe's first bitcoin ETF from Jacobi was listed two years after its initial approval in in October
2021 on Euronext Amsterdam, trading under the ticker BCOIN and is structured as an Alternative
Investment Fund not available to retail investors.
U.K. retail investors are also barred from accessing European-listed crypto ETNs. In 2021 the FCA banned
the sale of ETNs containing unregulated transferable cryptoassets. The FCA has stipulated that these
products are exclusively available to professional investors, such as investment firms and credit
institutions, leaving retail investors without access.
It should be noted that the U.S. spot crypto ETFs are actually exchange traded products (ETPs) and not
ETFs per se. ETPs, like ETNs, use an index to track the investment in the underlying physical
cryptoasset.
Global Digital Finance (GDF), the global digital assets industry association, surveyed major finance
firms in early 2024 in the US, Asia, Europe and the Middle East responsible for more than $221 billion
assets under management. The study found 93 percent were handling bitcoin with ETFs a major driver.
Madeleine Boys, GDF director of programs and innovation, said, "The list of U.S. 13F filings disclosing
institutional investments in U.S. crypto ETFs reveals a significant volume of investment coming from
non-retail segments, not yet witnessed in Europe."
Despite cryptocurrency being banned in mainland China, Hong Kong approved its first spot bitcoin ETFs in
April with six spot bitcoin and ether ETFs from China Asset Management, Harvest Global, Bosera, and
HashKey. The ETFs are the first in Asia to offer retail investors the ability to trade the
cryptocurrencies at spot prices. In Hong Kong, crypto futures ETFs are available but are restricted to
accredited investors.
Emerging Global Crypto ETF Investments
The limitations and hurdles including regulatory uncertainty across jurisdictions, account minimums, and
limited market hours, may appears to be limiting participation for retail investors to access crypto
ETFs across international markets.
Direct exposure to bitcoin and Ethereum through crypto ETFs is still in infancy so it remains to be seen
whether other countries will gain crypto ETF market share relative to the U.S. Many jurisdictions will
seek to follow the U.S. regulatory outcomes, where there a perceived level of security and legitimacy
granted to the crypto industry with U.S. ETF approvals.
The U.S.’s strong market entry may also suggest that other regions are struggling to attract investor
interest. Global market fragmentation and regulatory uncertainty with respect to crypto, especially
cross-borders, impacts international retail investors at a time when technology is making it easier than
ever to shift towards a global, interconnected market.
Alternative trading avenues for investors outside of the U.S. to access crypto assets include brokers
such as eToro, Interactive Brokers, and Revolut, but these are windows into exchange traded assets. For
example, all U.S. ETF positions opened by clients of eToro (Europe) Ltd and eToro (UK) Ltd who are
residents of the EEA or the UK are only available as CFDs. Retail traders can’t access U.S. ETFs in a
streamlined manner.
Brian Collins, CEO of Horizon and Co-Creator of Upstream says, “The current regulatory landscape falls
short in meeting the growing demand from retail investors for access to digital assets. The technology
to provide safe and secure access to crypto ETFs already exists, and we have made it our mission to
bridge that gap and empower investors worldwide.”
Upstream, a Seychelles regulated platform, allows investors to buy and sell stocks, options, warrants,
and collectibles from U.S. and international companies on a single global trading app. It is seeking to
attract crypto ETF funds to its platform to fill the growing gap for investor demand outside of the U.S.
to access crypto ETFs.
Go Physical Or Synthetic
Crypto ETFs, whether ETPs and ETNs, hold physical (or in the case of bitcoin and Ethereum, the digital)
cryptoassets in the underlying vehicle, just as ETFs hold physical (dematerialized, and digital)
securities such as stocks and bonds.
With the recent approval of options for crypto ETFs in the U.S. by the SEC, expect a greater number of
synthetic crypto fund and index products to hit the market. In synthetic ETFs, the price moves in tandem
with the derivative instrument's price rather than the sport price but converges on the spot price as
the option settlement date approaches.
In addition, the market is expecting hybrid synthetics soon which enable users to trade a thematic index
on their choses exchange or platform that buys, sells and rebalances cryptoassets which are hosted on
both non-custodial and custodial solutions.
Digital assets have made serious strides in 2024, meeting investors where they’re comfortable to
participate in the growing market. Regulatory uncertainty and streamlined access on a global scale may
be limiting traction and overall market participation in some jurisdictions, but solutions are emerging
for investors to find the exposure to crypto they wish to take.
Pressure from the success following the U.S. approvals and the apparent demand for crypto ETFs may
influence foreign governments and regulators to rethink more meaningful crypto regulation for retail
investors. This, combined with new and streamlined venues for retail investors to participate in the
growing demand for a variety of spot, derivate, and synthetic funds and indices is set to continue push
crypto ETF access to new heights.
It is an exciting new era for investors, wealth accumulation, and digital assets.
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Lawrence Wintermeyer
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