Banks and crypto companies are pursuing acquisitions that add licenses, payment networks, and trading capabilities while prospective sellers face a discerning IPO market, according to industry sources.

Last month, the Senate failed to advance the CLARITY Act, a proposed framework for digital asset markets, but the delay may affect pricing, approvals, and contractual protections more than acquisition appetite, said Dario de Martino, partner at White & Case.

“I don’t think I’ve been this busy ever. And it’s all about crypto M&A,” said de Martino, who used to represent mostly fintechs and is now seeing an even mix of fintechs and banks.

Public and IPO-track crypto companies and traditional financial institutions are acquiring “a specific missing piece” rather than an entire platform, said Vanessa Grellet, managing partner of Austin, Texas-based crypto venture firm Arche Capital. Stablecoins and payments remain the clearest area of interest, she added.

MoonPay agreed in September to buy North Capital Investment Technology, which runs Securities and Exchange Commission-registered broker-dealers, a transfer agent, and an alternative trading system. Circle agreed the same month to buy Singapore-based cross-border payments company Tazapay for USD 400m in stock.

Standard Chartered signed definitive agreements on 21 October to buy crypto custodian Zodia Custody, which has regulated businesses in five countries.

Some of this year’s largest deals were signed while the bill was still pending, including Mastercard’s purchase of stablecoin payments company BVNK, valued at up to USD 1.8bn.

“The deals getting done this year were not waiting for Congress,” de Martino said. “They were basically buying licenses, infrastructure, and rails.”

Acquiring an existing licensed business can offer a faster route than building a regulated operation from scratch, with the congressional delay probably extending that acquisition rationale, de Martino said.

“Regulated infrastructure keeps its premium because the alternative to buying it did not get easier,” he added.

Negotiating around uncertainty

Many institutional and traditional financial participants had already assumed CLARITY might fail to advance, said Mike Frisch, a partner at Winston Taylor. He does not expect the setback to have a significant long-term effect on M&A unless the next administration changes course dramatically.

Stablecoin and payments infrastructure companies were not waiting for CLARITY’s outcome since the GENIUS Act already gave them their own rules when it became law in July 2025.

Clients have asked White & Case to prepare deal terms on two tracks: with and without CLARITY’s passage. The two tracks differed on pricing, representations, and warranties, as well as some escrow and indemnity terms. He expects more contingent consideration and clauses covering regulatory change. Buyers must still plan around existing state and federal approvals, which will show up in deal timelines, de Martino said.

“The stall doesn’t create new uncertainty, it just prolongs existing uncertainty that people were already pricing into their deals,” he said.

Circle’s agreement to buy Tazapay, for example, allows Circle to walk away if certain regulatory conditions are unmet or specified adverse regulatory developments occur, according to its securities filing.

De Martino expects a slower market for targets whose value depends on whether their tokens are classified as securities or commodities. Buyers will want to see where the SEC lands on its proposed Regulation Crypto Assets before paying full price for those businesses, he said.

Back to fundamentals

Buyers are scrutinizing cash flow and the capital needs of a business post-acquisition, said Raphael Zagury, CEO of bitcoin treasury company Twenty One Capital. “Regulation will not make an uneconomic business profitable.”

Bitcoin-native businesses remain priced for a bear market, while companies with an artificial intelligence angle attract a premium, according to Zagury, who said a valuation from the last round serves as a reference point, “not an obligation for the next investor.”

Investors place greater weight on revenue quality, regulatory standing, fee economics, and actual adoption, while discounting growth stories and revenue dependent on tokens, Arche Capital’s Grellet said. Private funding has continued but become more selective, favoring later-stage companies with revenue, licenses, or regulated infrastructure, she added.

Zagury sees interest in profitable mining and lending businesses that can absorb additional capital. Bitcoin-backed lending should grow as capital providers get more comfortable with the collateral, he said, although underwriting must account for sharp price declines.

Miners locked into long-term AI contracts are unlikely to return soon, which helps those still mining bitcoin, Zagury said. Good energy assets poorly suited to AI are also available at a discount.

Sell or wait

Companies that shelved IPO plans late last year are starting to dust them off, said Will Braeutigam, US capital markets transactions leader at Deloitte. “Those pencils are starting to be picked back up, with plans for testing the market in the second and third quarters of next year.” A stronger crypto environment and successful fintech listings that deliver positive returns for investors are needed to support demand for new offerings, Braeutigam said.

Winston Taylor’s Frisch expects more IPO activity in 2027 and sees particular appeal in infrastructure businesses with underlying utility and economic value.

Selective listings of profitable, regulated infrastructure and fintech-adjacent companies are possible in coming quarters, Grellet said. A broad wave will depend on stabilizing rates, a durable crypto recovery, and the absorption of competing AI listings.

Zagury said broader public market access requires stable markets, clearer rules, and a stronger record from companies already listed. “The companies that widen the window will be the ones that report consistently and deliver after they list,” he noted.

Blockchain.com’s planned IPO will be the first real test of whether the crypto rally reaches crypto stocks, according to Grellet. The company is reportedly seeking to raise about USD 500m at a valuation of USD 4bn–USD 6bn, below its USD 14bn peak in 2022.

Meanwhile, Hong Kong-based crypto payments company RedotPay is reportedly weighing a confidential US IPO filing by year-end and discussing a pre-IPO funding round at a valuation of USD 4bn–USD 5bn. It has more than 9m customers and annualized run-rate revenue above USD 180m, according to press reports.

Some of the bankers de Martino speaks with do not expect the IPO window to reopen in a meaningful way before late 2027, he said. Weak trading by previously listed crypto companies and competition from AI for capital have weighed on the market.

Digital-asset infrastructure provider Fireblocks, which has been working toward an IPO, told Mergermarket last week that market conditions have not been conducive to crypto listings this year.

Crypto companies that have been successful have had revenue models more closely aligned with traditional financial services, Fireblocks Chief Strategy Officer and Head of Banking Stephen Richardson said. That includes stablecoin issuers like Circle and trading platforms like Coinbase. Infrastructure companies like Fireblocks, driven primarily by contracts and annual recurring revenue growth, are more comparable to BitGo, which has struggled in the public markets, he noted.

Fireblocks does not want to pursue an IPO only to see its share price fall sharply after listing, Richardson said.

Passing the bill might have encouraged more IPOs, but listings had gone quiet well before the vote. “It didn’t close the window because the window was already effectively closed,” de Martino said.

“We’re seeing a pause in listings though not a pause in equity activity,” he added. Companies are still raising equity outside the traditional IPO route, through private placements, SPAC combinations, at-the-market programs, and convertible financing.

Some owners who delayed selling in anticipation of legislation and higher valuations may now reconsider with the IPO window silent, the lawyer said. Some crypto treasury companies trading below the value of their coin holdings face a narrowing set of choices, including buybacks or a sale, he added.

“It may be an accelerated M&A market for regulated infrastructure companies and for sellers that don’t want to wait any longer,” de Martino said.

With the CLARITY vote behind them, “now folks at least have the full picture,” Frisch added. “At this point they can evaluate what the market looks like and whether now would be a good time for an IPO or another transaction.”