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5.1 The Oracle Problem: Connecting On-Chain to Off-Chain Reality

What you'll learn

Why an RWA oracle usually carries one issuer's number rather than a market consensus, how tokens that trade all week are priced from business-day NAVs and weekday market feeds, why proof of reserve counts assets without valuing them, why splits and defaults are harder to carry on-chain than prices, what each pricing design trades away, and how much of the information layer runs through one provider.

An oracle does not bring the world on-chain. It brings someone's report of it. For a crypto asset traded on many venues, that report can aggregate many independent prices. For a tokenized fund, a stock certificate, or a loan pool, there is usually one authoritative number, published by one issuer, administrator, or custodian on its own schedule, and the oracle carries that number to the chain. Carrying it faithfully does not make it correct, current, or complete, yet a lending market that liquidates against it treats the report as the asset.

The risk is therefore not that oracles occasionally fail. It is that every pricing design chooses a failure mode. Mark a token to its own thin secondary market and the price can be pushed around. Mark it to the issuer and it inherits the issuer's clock, errors, and weekend silence. Guardrails move a protocol from one failure mode to the other without removing the choice. One limit on the evidence comes first: this paper found no documented case of a wrong tokenized-fund NAV being pushed on-chain and causing losses. What follows rests on design documents, regulators' assessments, and crypto-native incidents that share the mechanism. The RWA oracle stack runs in production, but it has not been stress-tested.

Section 4.5 closed Chapter 4 by asking what happens to the market when one of its dependencies fails. This section takes the first. Section 2.4 named oracles the information layer, asked "Who controls the facts the contract acts on?", warned that a stale or unaccountable oracle means "the contract acts on bad facts and does so automatically", and promised that Section 5.1 treats that failure mode in full. Section 3.4 showed that a token trading every hour on an asset that trades five days a week creates a new basis, and promised that Section 5.1 treats the oracle version of that problem in full. This section keeps both promises, and the one Section 1.4 made to developers about how oracle design affects pricing and corporate actions. It takes the checklist question from Section 4.3, "Who publishes the numbers, and who checks them?", and asks what happens when the answer fails.

RWA Oracles Import a Trusted Party by Design​

A 2023 BIS Bulletin set out the trade-off: "While introducing some degree of centralisation in oracles might boost efficiency, it also means adding trusted parties to a system designed to be trustless. As a result, crypto-based DeFi is likely to remain the preserve of cryptoassets only, rather than being used for real-world assets."1 Tokenized funds did reach DeFi, on exactly those terms: by accepting the trusted party.

The providers say so themselves. RedStone, which designed a NAV oracle with Securitize, writes that the funds it serves "have no continuous market price", that their value is "calculated off-chain by a fund administrator under standard fund accounting rules", and that "Multi-source aggregation, the default oracle model, does not apply to these kind of tokenized assets."2 Chainlink's documentation, describing feeds that rely on one source such as "a protocol-published NAV", warns that "If the underlying source or provider publishes incorrect data, omits data, changes its methodology, experiences an outage, is delayed, or is compromised, the feed may reflect that issue."3 Aave, whose Horizon market takes tokenized Treasury and credit funds as collateral, states that issuer-reported NAV "introduces a critical risk vector" and that "A simple operational error or a malicious act could lead to an incorrect NAV being published onchain, which could trigger faulty liquidations across the market."4

The engineering response has been to make the single source verifiable. RedStone chains "each NAV update to the previous one, with a full digital signature, timestamp, and hash"2; Chainlink calls its NAV feeds "real-time, tamper-proof"5. Both describe the pipe. A signed record proves who published a number and that nobody altered it in transit, not that the administrator calculated it correctly. Decentralising the nodes that carry a number does not decentralise the number.

Regulators locate the risk in the party behind the data. IOSCO warns that oracles create "exposure to a single point of failure or corruption where the oracles can be subject to manipulation, fraud or control by unknown parties who are not subject to third-party audit or evaluation"6. For tokenized money market funds, the ECB found in April 2026 that "Weaknesses in smart contracts or price oracles may additionally distort net asset value per share calculation, freeze transactions or misallocate assets."7

The NAV Clock Versus the 24/7 Chain​

The BIS describes the arrangement for tokenized money market funds: the NAV "relies on pricing information usually provided once per business day by off-chain services to which the blockchain has access ('oracles')."8 The token runs on a different clock.

Ondo's OUSG offers "Instant, 24/7/365 Minting & Redemption" at "the then-current NAV"9. That NAV typically moves "once every Business Day", and "because this is a manual process, it may sometimes take longer." Weekends and holidays are excepted, "since the next price update will not happen until the next Business Day."10 Superstate produces a continuous price for its funds by linear extrapolation "using the two newest NAV/S checkpoints", while the Chainlink feed for the same funds updates "once per day"11. That is reasonable for a Treasury fund whose value drifts predictably, and silent about anything since the last checkpoint.

Tokenized stocks sharpen the gap, because the reference market keeps hours. Chainlink's 24/5 US equity feeds "are not updated on weekends or US equity market holidays"3. Since 25 September 2026, seven Coinbase stock tokens have been accepted as collateral for USDC loans on Aave's V4 market on Base12. The technical review behind the listing, by LlamaRisk, a risk service provider funded in part by the Aave DAO, records a feed window of "120 of the 168 hours in a week", and that "While the market is closed the feed publishes nothing, including heartbeat updates, so the last value published before the Friday close stands with a stale timestamp until the Sunday evening reopen." The overnight session "is currently single-sourced"13. The listing does not pretend the weekend price is live: collateral factors of 65% to 79%14 treat each closure "as a window in which the position cannot be repriced"13. The protection is the haircut, not a price.

Gold goes the other way. When the metals market is closed, Chainlink's 24/7 gold feed "starts from the last observed open-market price and adjusts it with a blended signal derived from tokenized precious metals price streams", currently "XAUT/USD and PAXG/USD"15. At weekends the reference price for gold is inferred partly from the gold tokens themselves, one of which, PAXG, is attested monthly16.

Table 1 sets these designs side by side101121315.

ProductWhat the oracle carriesHow often it movesWhen the reference is closed
Ondo OUSGFund NAV, posted by OndoOnce per business day, manuallyNo update; minting and redemption continue at the last NAV
Superstate USTB and USCCNAV per share from the calculation agentChainlink feed daily; Superstate oracle on requestContinuous price extrapolated from the two newest NAVs
Apollo ACREDPrivate credit fund NAV, via RedStone24-hour heartbeatFeed stays fresh; the valuation inside moves on the fund's schedule
Coinbase stock tokens on AaveShare price times issuer multiplier, via Chainlink0.5% deviation or 24-hour heartbeat, 120 of 168 hoursFriday 20:00 ET value held until Sunday 20:00 ET
Chainlink tGLD/USDGold spot priceContinuously while the market is openLast spot price adjusted by XAUT and PAXG prices

The FSB warns that runs set off by automated liquidation of tokenized collateral "might be intensified if they happen when the reference asset markets are closed while trading of the token is still active (e.g. over a weekend)."17 Section 5.4 takes up the run itself; the point here is that over a weekend the on-chain price is frozen, extrapolated, or inferred from the tokens.

Freshness of the feed is also not freshness of the valuation. RedStone pushes the NAV of Apollo's private credit fund ACRED "on a 24-hour heartbeat"2, and Section 4.1 recorded ACRED as collateral in Morpho lending markets. The heartbeat says the number is recent, not how recently the loans behind it were valued. IOSCO is blunt: "Private valuations are inevitably stale", private funds "may value their assets as infrequently as quarterly, or even annually", and "There is usually a 2 or 3 quarter lag between a decline in public market valuations and the impact becoming fully evident in private markets."18 An oracle can deliver a daily feed of a quarterly mark, and a current timestamp on an old valuation is the most convincing stale price, because every freshness check in the consuming contract passes.

Counting Is Not Valuing​

Three products travel under similar names. An audit examines a fund's financial statements for a reporting period; Section 4.3 named PricewaterhouseCoopers as auditor of BUIDL and USTB. An attestation examines a specific assertion at a point in time: Paxos publishes monthly PAXG attestations, issued since February 2025 by KPMG under AICPA attestation standards16. A proof-of-reserve feed compares token supply on-chain against a reported reserve figure. Chainlink's documentation lists three sources for that figure: a third party such as an auditor, the bank or custodian, or an API the issuer hosts, with the warning that "Chainlink Labs is not responsible for the accuracy of self-reported reserves data." It adds that the custodian method works when the asset "requires no additional valuation"5.

Proof of reserve is sometimes presented as a substitute for the other two. Backed, a tokenized-stock issuer, described its Chainlink integration as "removing the need to conduct manual audits."19 Staff in the PCAOB's Office of the Investor Advocate took the opposite view in March 2023: "PoR engagements are not audits and, consequently, the related reports do not provide any meaningful assurance to investors or the public." Such procedures "likely do not address the crypto entity's liabilities, the rights and obligations of the digital asset holders"20.

The TrueUSD case shows counting and valuing coming apart. According to the SEC's complaint, TrueCoin "retained accounting firms to provide 'real-time' attestation services" for the reserves behind its TUSD stablecoin, and the reports did not disclose that a significant portion sat in an offshore commodity fund "which the attestation reports were valuing at cost without considering any adjustments." The SEC alleged that fund was approximately 24% of reserves in March 2023, while it had "liquidity issues and problems with redemptions"21. The companies settled without admitting or denying the allegations22. TUSD is a stablecoin, and Section 4.4 covers stablecoin reserves; the case matters here only as attestation design. The units were counted in real time. Their value was not.

A proof-of-reserve feed establishes quantity. It does not say what the reserve would fetch in a sale, whether it is pledged elsewhere, or whether the token holder has a claim on it if the issuer fails.

Events Are Harder Than Prices​

A price is a number that changes. A dividend, a split, or a default is a discrete, legally defined event, often announced in prose, that changes what the token entitles its holder to. The FSB lists "corporate activity or market events" among the information that could trigger smart contract actions17, and traditional markets have not solved the off-chain version. An initiative of Chainlink and 24 institutions including Swift, DTCC, and Euroclear cites Citi's 2025 Asset Servicing report for the finding that 75% of market participants still rely on manual data revalidation. Its pilots used large language models to turn announcements into "golden records onchain", and still added "institutionally-designated roles for data attestors and contributors"23.

The Coinbase stock tokens show what a corporate action does to a feed. Each token's value is the share price times an issuer-set multiplier, and a split is the dangerous case: "if the token applies the new multiplier before the feed applies the new price, or the reverse, the token is mispriced by the full split ratio until the two realign." The remedy is procedural. The issuer pauses minting, redemption, and the feed, updates the multiplier, and resumes, while "token transfers continue"; Aave pauses the reserve too, "since a token that continues to change hands against a frozen price is precisely the state in which a mispriced liquidation can occur." The oracle does not observe the event. It waits for the issuer: "A delayed corporate action is delayed onchain, and a cancelled action does not reach the chain." So far the multiplier has moved once, from 1.0 to 1.000377 for a GOOGLc dividend on 14 September 202613. Who holds the keys that can move the multiplier or halt the feed, each in a single transaction, is an execution-layer question for Section 5.5.

Defaults are harder still, because they are judgements. Goldfinch, which Section 4.1 records winding down in June 2026, ran two clocks. Off-chain, a borrower who missed a payment had a grace period of three to seven days. On-chain, the protocol waited 45 days before marking the loan as in default, then wrote it down on a daily linear basis over 120 days, reversing the writedown if repayments arrived24. By this paper's arithmetic, a missed payment could take up to 165 days to be fully reflected on-chain. Throughout that window the on-chain value followed the protocol's schedule, not the borrower's condition.

Mark to a Thin Market or Mark to the Issuer​

A token used as collateral can be priced from its own market or from its issuer. For deep markets the first is normal. For thin markets it makes the oracle something a trader can move, and Section 3.3 showed that secondary markets in tokenized RWAs are thin.

The incidents showing the mechanism are crypto-native analogues, not RWA cases. On 11 October 2022, according to the CFTC's complaint, a trader bought MNGO on the three exchanges feeding Mango Markets' oracle, and "the price of MNGO as reported by the oracle, jumped over 13-fold during a 30-minute span"; he borrowed against the inflated collateral and withdrew over $110 million25. The BIS, citing Chainalysis, counted $403.2 million lost "in 41 separate oracle manipulation attacks" in 20221.

A thin market can also fail with nobody manipulating it. Between 21:36 and 22:16 UTC on 10 October 2025, collateral tokens on Binance printed far below redemption value and set off forced liquidations. LlamaRisk traced the cause to a margin system that used Binance's "own spot order book as the primary price source for its collateral oracle", "creating a self-referential loop where the system's actions (liquidations) directly influence the data it uses for subsequent decisions." By its account USDe fell to around $0.60 on Binance, while Aave, which valued USDe against USDT, saw its $1.03 billion of USDe deposits remain stable26. Binance compensated users "without admission of fault or liability" and announced that "The redemption price will be added to the BNSOL, WBETH, and USDE price index weights."27

The standard remedy is the second choice, anchoring on NAV or redemption value, which brings back the issuer's clock, its single source, and its capacity for error. The guardrails then convert one risk into the other. On Aave Horizon, an issuer NAV outside preset bounds is rejected "and the oracle continues to report the last known valid price"4. LlamaRisk's LlamaGuard can "temporarily freeze the feed at the last known good value"28. A bound stops a mistyped NAV. It also freezes a true NAV that moves outside the band, which is what a genuine credit event looks like, so manipulation risk becomes staleness risk exactly when staleness costs most.

Safeguards can also supply the bad fact. In March 2026 a fault in Aave's CAPO safeguard, a "time-weighted upper bound on the exchange rate" of yield-bearing assets, pushed the cap below the live wstETH rate, causing "an approximately 2.85% decrease in the effective exchange rate used by the protocol, triggering roughly 10938 wstETH in E-Mode liquidations"; the protocol incurred no bad debt, according to Chaos Labs' post-mortem29. wstETH is not an RWA, and the root cause was a contract constraint of the kind Section 5.5 examines, but the lesson carries over: the safeguard was itself a supplier of facts, and the contract acted on its number automatically.

One Provider Behind Most of the Facts​

Few providers sit behind these feeds. DefiLlama measures each oracle's total value secured, the value in protocols "where oracle failure would equal TVS". In an Internet Archive capture of that page taken on 7 September 2026, whose latest data point is 6 September, Chainlink secured $40.03 billion of the $63.36 billion summed across 67 oracles, about 63% by this paper's calculation, ahead of Chronicle at $7.37 billion and RedStone at $4.20 billion; a year earlier its share was also about 63%30. Protocols using several oracles can be counted more than once, so this is a rough share of value exposed, not a market share.

On the RWA side the same provider recurs at every layer this section has described. Chainlink validates the NAV bounds on Aave Horizon4, carries Superstate's daily NAV11, supplies the Coinbase stock-token feeds13, runs the gold feed that reads tokenized gold at weekends15, and distributed the golden records in the corporate-actions pilots23. DTCC announced in May 2026 that "Chainlink will be integrated into DTCC's Collateral AppChain to enable the seamless pairing of asset prices, valuations and movement", with go-live expected in Q4 202631. RedStone covers much of the rest as "Securitize's primary oracle partner, delivering NAV feeds for BUIDL, ACRED, HLSCOPE, VBILL, and STAC"2. This is a different concentration from the bundling of roles inside one firm that Section 4.3 described and Section 5.3 examines: one external provider behind many unrelated issuers, so that a failure in its infrastructure could reach all of them at once.

Regulators track the concentration without yet assigning responsibility. The FSB's monitoring framework lists the "Emergence of dominant (third-party) service providers" and the "Number and size of third-party service providers such as oracles and their regulatory/supervisory treatment", and warns that frameworks for traditional data providers "may not entirely cover oracles in the context of DLT platforms"17. IOSCO's 2023 DeFi recommendations put the duty on the product: "Regulators should seek to require Responsible Person of DeFi products that rely on oracles and cross-chain bridges to identify, manage and mitigate the risks posed by such technology."32 The BIS found "little clarity on legal recourse if a smart contract were triggered by false information"1.

That leaves a regulatory question for Chapter 6: is the party that puts a NAV on-chain a data vendor, a benchmark administrator, an extension of the fund administrator, or an unregulated technology service, and who answers to the holder when a contract liquidates against its number? Every fact this section examined, the NAV, the reserve count, the multiplier, the default flag, describes the asset. None establishes whether the token holder owns it. A reserve feed can confirm that a custodian holds the right number of shares and say nothing about whose shares they are if the issuer fails. Section 5.2 takes up that question: custody and legal title, what claim a token actually gives, and what becomes of it when a custodian or issuer fails.

Key Takeaways
  • RWA oracles are usually single-source by necessity. A tokenized fund has one authoritative NAV, so multi-source aggregation does not apply, as RedStone and Chainlink both state. A 2023 BIS Bulletin expected DeFi to stay crypto-only unless it accepted trusted parties; RWA DeFi exists because it did.
  • The token's clock and the asset's clock differ. BIS research finds tokenized money market fund NAVs rely on pricing "usually provided once per business day"; Ondo updates OUSG's price manually once per business day while minting runs 24/7/365; and the feed behind Coinbase's stock tokens on Aave holds its Friday value for 48 hours.
  • Proof of reserve counts but does not value or establish claims. PCAOB investor-advocate staff warn that proof-of-reserve engagements "are not audits", and the SEC alleged that TrueUSD's "real-time" attestations valued an illiquid offshore fund, about 24% of reserves in March 2023, at cost.
  • Events are harder than prices. A split applied out of order misprices a Coinbase stock token by the full split ratio, a delayed corporate action is delayed on-chain, and Goldfinch marked a loan in default on-chain only after 45 days.
  • Every pricing design trades one failure for another: thin-market pricing failed at Mango Markets and Binance, and issuer pricing brings stale single-source numbers that guardrails freeze. Chainlink secures about 63% of the value DefiLlama attributes to oracles, by this paper's calculation, and the FSB tracks dominant providers as a stability indicator. No wrong tokenized-fund NAV pushed on-chain has yet been documented, so the RWA oracle stack remains untested.

Footnotes​

  1. BIS, The oracle problem and the future of DeFi, BIS Bulletin No 76 (7 September 2023) - https://www.bis.org/publ/bisbull76.htm ↩ ↩2 ↩3

  2. RedStone, Tokenize the World: RedStone's Role in the Securitize Ecosystem (6 July 2026) - https://blog.redstone.finance/2026/07/06/tokenize-the-world-redstones-role-in-the-securitize-ecosystem/ ↩ ↩2 ↩3 ↩4 ↩5

  3. Chainlink (docs), Selecting Quality Data Feeds (retrieved 28 September 2026) - https://docs.chain.link/data-feeds/selecting-data-feeds ↩ ↩2

  4. Aave (docs), Aave Horizon RWA Market (retrieved 28 September 2026) - https://aave.com/docs/aave-v3/horizon ↩ ↩2 ↩3

  5. Chainlink (docs), SmartData (retrieved 28 September 2026) - https://docs.chain.link/data-feeds/smartdata ↩ ↩2

  6. IOSCO, Tokenization of Financial Assets, Final Report FR/17/25 (11 November 2025) - https://www.iosco.org/library/pubdocs/pdf/IOSCOPD809.pdf ↩

  7. European Central Bank, Tokenised money market funds: new technology, familiar risks?, Macroprudential Bulletin 33 (April 2026) - https://www.ecb.europa.eu/press/financial-stability-publications/macroprudential-bulletin/html/ecb.mpbu202604_04.en.html ↩

  8. BIS, Bulletin 115: The Rise of Tokenised Money Market Funds (26 November 2025) - https://www.bis.org/publ/bisbull115.pdf ↩

  9. Ondo Finance (docs), OUSG Overview (retrieved 28 September 2026) - https://docs.ondo.finance/qualified-access-products/ousg/overview ↩

  10. Ondo Finance (docs), OUSG Yield (retrieved 28 September 2026) - https://docs.ondo.finance/qualified-access-products/ousg/yield ↩ ↩2

  11. Superstate (docs), Smart Contracts (retrieved 28 September 2026) - https://docs.superstate.com/investors/smart-contracts ↩ ↩2 ↩3

  12. TechFlow, Aave Launches Tokenized Stock Collateralized Lending, USDC Lenders Face Weekend Gap Risk (28 September 2026) - https://www.techflowpost.com/en-US/article/34260 ↩

  13. LlamaRisk via Aave Governance Forum, Coinbase B20 Equities on Base Assessments (24 September 2026) - https://governance.aave.com/t/coinbase-b20-equities-on-base-assessments/25690 ↩ ↩2 ↩3 ↩4 ↩5

  14. Aave Labs via Aave Governance Forum, ARFC: Deploy Aave V4 on Base (3 August 2026) - https://governance.aave.com/t/arfc-deploy-aave-v4-on-base/25427 ↩

  15. Chainlink (docs), 24/7 Extended-Hours Data Feeds (retrieved 28 September 2026) - https://docs.chain.link/data-feeds/24-7-extended-hours-data-feeds ↩ ↩2 ↩3

  16. Paxos, Pax Gold (PAXG) Transparency Reports (retrieved 28 September 2026) - https://www.paxos.com/paxg-transparency ↩ ↩2

  17. FSB, The Financial Stability Implications of Tokenisation (22 October 2024) - https://www.fsb.org/uploads/P221024-2.pdf ↩ ↩2 ↩3

  18. IOSCO, Thematic Analysis: Emerging Risks in Private Finance, Final Report FR10/23 (September 2023) - https://www.iosco.org/library/pubdocs/pdf/IOSCOPD745.pdf ↩

  19. Backed, Backed is integrating Chainlink Proof of Reserve to increase the transparency of bToken reserves (retrieved 28 September 2026) - https://backed.fi/news-updates/backed-chainlink-proof-of-reserve ↩

  20. PCAOB Office of the Investor Advocate, Investor Advisory: Exercise Caution With Third-Party Verification/Proof of Reserve Reports (8 March 2023) - https://pcaobus.org/resources/information-for-investors/investor-advisories/investor-advisory-exercise-caution-with-third-party-verification-proof-of-reserve-reports ↩

  21. SEC v. TrueCoin LLC and TrustToken, Inc., Complaint, Case 3:24-cv-06684, U.S. District Court for the Northern District of California (24 September 2024) - https://www.sec.gov/files/litigation/complaints/2024/comp-pr2024-145.pdf ↩

  22. SEC, SEC Charges Crypto Companies TrustToken and TrueCoin With Defrauding Investors Regarding Stablecoin Investment Program, Press Release 2024-145 (24 September 2024) - https://www.sec.gov/newsroom/press-releases/2024-145 ↩

  23. Chainlink via PR Newswire, Chainlink and 24 Leading Financial Market Participants Advance Industry Initiative To Solve $58 Billion Corporate Actions Problem (29 September 2025) - https://www.prnewswire.com/news-releases/chainlink-and-24-leading-financial-market-participants-advance-industry-initiative-to-solve-58-billion-corporate-actions-problem-302569071.html ↩ ↩2

  24. Goldfinch (docs), Default Process (retrieved 28 September 2026) - https://docs.goldfinch.finance/goldfinch/goldfinch-v1/protocol-mechanics/default-process ↩

  25. CFTC, CFTC Charges Avraham Eisenberg with Manipulative and Deceptive Scheme to Misappropriate Over $110 million from Mango Markets, a Digital Asset Exchange, Press Release 8647-23 (9 January 2023) - https://www.cftc.gov/PressRoom/PressReleases/8647-23 ↩

  26. LlamaRisk, When Pricing Breaks: A USDe Case (18 October 2025) - https://llamarisk.com/research/when-pricing-breaks-usde ↩

  27. Binance, Resolution of USDE, BNSOL, and WBETH Price Depeg and Risk Control Enhancements (11 October 2025) - https://www.binance.com/en/support/announcement/detail/0989d6c7f32545bfb019e3249eaabc3f ↩

  28. LlamaRisk, Introducing LlamaGuard NAV Powered by Chainlink Infrastructure (24 September 2025) - https://www.llamarisk.com/research/llamaguard-release ↩

  29. Chaos Labs via Aave Governance Forum, Post-Mortem: Exchange Rate Misallignment on wstETH Core and Prime Instances (10 March 2026) - https://governance.aave.com/t/post-mortem-exchange-rate-misallignment-on-wsteth-core-and-prime-instances/24269 ↩

  30. DefiLlama (Internet Archive capture), DeFi Oracle Rankings: Total Value Secured (7 September 2026) - https://web.archive.org/web/20260907113016/https://defillama.com/oracles ↩

  31. DTCC, DTCC Collaborates with Chainlink to Advance 24/7 Collateral Management (12 May 2026) - https://www.dtcc.com/press-releases/2026/dtcc-collaborates-with-chainlink-to-advance-24-7-collateral-management ↩

  32. IOSCO, Final Report with Policy Recommendations for Decentralized Finance (DeFi), FR/14/2023 (December 2023) - https://www.iosco.org/library/pubdocs/pdf/IOSCOPD754.pdf ↩