El Salvador’s National Commission on Digital Assets, in collaboration with U.S. law firm Perkin Law Firm and former Goldman Sachs partner Heather Shemilt, has proposed a cross-border crypto regulatory sandbox to the U.S. Securities and Exchange Commission.
The initiative, disclosed in SEC Crypto Task Force meeting minutes on April 22, is designed to provide the SEC with real-time data and insights from regulated digital asset activity in El Salvador.
The sandbox would allow U.S. and Salvadoran regulators to jointly observe small-scale tokenization projects under El Salvador’s digital asset regime, which has evolved over the past five years.
CNAD has developed a comprehensive risk matrix and regulatory model through live experiments in tokenization, particularly in real estate, and has attracted global players.
Two pilot programs for the sandbox
The proposal includes two pilot programs. The first involves a U.S.-licensed broker acquiring a limited-scope digital asset license from CNAD to launch a real estate tokenization platform. Investors would be able to purchase fractional shares in a Salvadoran property, with each scenario capped at $10,000 in exposure.
The project is intended to offer insights into investor protection, secondary trading of digital assets, and regulatory clarity around classifying certain tokens as “non-securities.”
The second scenario focuses on tokenized capital raising. A small business in El Salvador would raise funds via tokenized equity, again under the $10,000 limit. The goal is to evaluate how tokenized offerings compare to U.S. crowdfunding rules, potentially informing future SEC guidance.
The team behind the proposal includes Erica Perkin, a blockchain-trained attorney and advisor to CNAD; Juan Carlos Reyes, CNAD’s president; and Carmen Elena Ochoa de Medina, a former financial regulator now working in tokenization.
A U.S. broker will be selected with SEC input to ensure alignment with U.S. compliance standards.
The sandbox aligns with five priorities outlined in Commissioner Hester Peirce’s crypto policy statement, including cross-border collaboration, broker-dealer regulation, custody standards, and treatment of coin and token offerings.
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