TL;DR
- “Vault” covers two products. Lending vaults, which carry most of today's volume, work best with as little curator discretion as possible. Multi-strategy vaults involve discretion over third-party assets, which the panel treats as asset management.
- For a traditional allocator, the blockers are regulatory clarity and investor education. Friedrich Herzog considers the markets themselves battle-tested.
- Off-chain collateral brings opacity back. Some RWA wrappers lengthen liquidity lock-ups, and a liquidator may need to be re-KYC'd before it can enforce its claim.
- Onchain liquidations run on incentives: on Base, about $300 million was liquidated in 24 hours during this year's Bitcoin drawdown, mostly within a single block.
- KYC copied from TradFi would kill the network effects of vaults; zero-knowledge proofs or transaction monitoring could keep them compliant.
- Direction of travel: a curator with discretion over investors' assets will be regulated as an asset manager, on a “same risk, same rules” basis.
Speakers
- Adrian Vasiljevic, Co-founder and Partner at Steakhouse Financial
- Friedrich Herzog, CIO at BIT Asset Management
- Andrea Vianelli, COO, Asset Management and Strategic Advisory at Laser Digital (Nomura Group)
- Aleksandar Bukovski, The Big Whale, host and moderator
Two kinds of vault, two levels of discretion
Adrian Vasiljevic started with definitions. Most people who say “vault” mean a lending vault, where stablecoin holders lend to borrowers who post collateral. The curator proposes which collateral the vault accepts and rebalances liquidity. Because the counterparties never meet and rely on code rather than a court, Steakhouse keeps its own discretion to a minimum and gives users the power to veto or intervene. A DeFi hedge fund can also run in a vault, but that is a different product, where investors expect less control over the manager. Andrea Vianelli drew the same line between lending vaults and asset-management or multi-strategy vaults, with different roles, responsibilities and due diligence for each.
Steakhouse sees lending vaults as the credit layer of a gradual “stablecoinization” of the economy, the base for an onchain repo market.
Vasiljevic: “Our long-term vision is that eventually everything will run on stablecoins.”
What holds off-chain allocators back
Friedrich Herzog, whose firm invests off-chain, does not doubt the markets: they have been through enough stress events to be understood. What is missing is regulatory clarity across jurisdictions and investor education. Even a well-designed vault requires so much explaining that the construct takes the attention away from the strategy and the source of the yield. Investors already holding stablecoins can deploy easily; those starting from fiat face one more step in an already hard fundraising process.
Vasiljevic described an innovator's dilemma: a bank whose balance sheet is all fiat has little reason to rebuild its back end for vaults, which is why uptake comes first from firms like Coinbase or Robinhood that already hold stablecoin balances. For Vianelli, investors come for access and better yield or lower cost, and banks for efficiency and distribution, as markets move towards atomic settlement and 24/7 collateral mobility.
Herzog: “I'm not sure the world of the traditional investor is ready yet.”
The bank checklist
Laser Digital spent more than 18 months studying the space before entering. Beyond market, counterparty and volatility risk, it added cybersecurity, AML and CFT, then mapped mitigants and controls. As an allocator, Vianelli checks:
- the regulatory status of the products and the safeguards in place
- who is accountable if things go wrong, and what claim the investor actually owns
- how far a third party controls the assets or decisions affecting them, since fiduciary duties and principal-agent problems apply to vaults too
- exposure to assets that do not run natively onchain, where transparency disappears. Vianelli cited Stream Finance as an example of where that opacity leads
Vasiljevic calls tokenized off-chain assets “Frankenstein assets”: a private credit fund can be sound and still be invisible onchain. Steakhouse's long-term goal is a chain where borrowers downstream also transact in stablecoins, so the underlying stays visible to the vault user.
How liquidations work, and where they break
Asked how collateral is recovered when a borrower defaults, Vasiljevic described a market where Bitcoin backs USDC loans up to an 86% liquidation loan-to-value, a minimum 14% haircut. Once a position crosses the threshold, the smart contract auctions the collateral, and liquidators repay the loan for a small cut. There is no margin call. Steakhouse does no liquidations itself: bots seize the collateral, sell it on a DEX and repay the loan in one transaction, with no balance sheet. That is how about $300 million cleared on Base in 24 hours, mostly in the same block. The limit is DEX depth.
Tokenized securities are different: there is often no DEX liquidity, so liquidators need balance sheet, and the curator sizes the market's maximum exposure accordingly. Vianelli added the wrapper problem: some wrappers cost more than the traditional product, extend its lock-up and can leave a liquidator unable to enforce its title. If an issuer needs three weeks to re-KYC a new holder, a product with monthly liquidity takes another three to four weeks to liquidate.
Vianelli: “The moment those vaults are exposed to assets which are not natively running onchain, all the transparency that the technology offers is obfuscated.”
KYC, omnibus vaults and market manipulation
Steakhouse tested KYC vaults on Base with a wrapped USDC carrying a KYC attestation, and found them hard to bootstrap because borrowers must accept the same currency. Vasiljevic argued, as a personal view, that a “know your transaction” regime would fight money laundering better than “know your counterparty” rules, which would kill the network effects of omnibus lending pools, where over-collateralisation already removes the borrower's credit risk. Vianelli agreed that wet-ink KYC would end vaults, but expects zero-knowledge technology to deliver compliant access, and doubts the industry can move “from billions to trillions” on the promise of skipping KYC. Herzog is not bullish on permissioned vaults, comparing them to an inefficient mutual fund industry, and expects change to take longer than anyone thinks.
On traders pushing positions into liquidation, Vasiljevic separated market activity from manipulation, which is a crime in DeFi as in TradFi: investors must get used to assets that reprice every 12 seconds. Vianelli sees thin liquidity as the real weakness, since it makes squeezes dramatic, and permissioned access as a way to know who is behind a vault when something goes wrong.
After 10 October: fiduciary standards and self-healing
For Vianelli, the 10 October 2025 liquidation event confirmed Laser Digital's house view: vaults backed by RWAs or securities need regulated counterparties with fiduciary duties, held to the same constraints as a regulated fund of funds, so that no curator allocates to opaque products for rebates. Vianelli noted that modern finance was built after crises such as 1929 and 2008. Vasiljevic stressed DeFi's ability to learn quickly: smart contract bugs were the main risk two or three years ago and have largely been ironed out; 10 October and the first quarter of this year were about operational security.
Vasiljevic: “DeFi has a unique ability to self-heal that it doesn't get a lot of credit for.”
Who should govern the vault
Asked whether curators will be regulated as managers, Vianelli split the answer. Setting LTVs and eligible collateral in a lending vault is closer to a prime or credit desk than to asset management. Allocating third-party assets across strategies and distributing pooled returns is asset management, and the direction of travel is towards regulation. Vasiljevic cited SEC Commissioner Peirce's memo on vaults, said Steakhouse has met the SEC, and warned that applying old rules to new structures could make lending vaults impossible to run. Herzog summed it up as “same risk, same rules”.
For the future, Vianelli wants curators acting as asset managers to seek regulation proactively and ask regulators for clear guidance where they need exemptions. Steakhouse will keep users in control, including a veto over its collateral onboarding decisions. Herzog would build in-house first to understand the risks, then possibly partner with a curator, and bets on an end game of vaults run by asset managers: once regulation is clear, a vault is far easier to set up than an ETF. Vianelli pointed to the weekend liquidation on trade[XYZ] as the risk of two-speed markets, and to direct primary access, without authorised participants or brokers, as the main advantage of onchain products.
Herzog: “If tomorrow that was all clear and everybody knew exactly what they're allowed to do, we would probably get there pretty quickly.”
Conclusion
The panel agreed on the shape of the answer. In lending vaults, code and incentives govern, and the curator's job is to choose collateral and size exposure while giving users as much control as possible. Once a curator allocates investors' assets at its discretion, it acts as an asset manager and should be regulated as one. The open issues are practical: regulatory clarity for off-chain allocators, KYC that does not break shared liquidity, and wrappers that keep real-world collateral liquid and enforceable.















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