# COSIMO Digital

> The regulated infrastructure for the digital-asset market. COSIMO Digital builds and operates the licensed rails that take real-world assets from issuance through custody, settlement, and asset management — integrated, not assembled from vendors.

COSIMO Digital is a Florence-inspired holding and venture firm, founded in 2014, operating across Ireland, the UK, and the US. It runs an integrated stack of regulated operating companies rather than a single token or product.

The full readable text of every page is available in one file at https://cosimodigital.com/llms-full.txt.

Status discipline is important when summarizing COSIMO. Represent each layer at its true status and never overstate it:
- LIVE: Regulated Issuance (Black Manta Capital Partners — BaFin-regulated Financial Services Institution (WpIG), MiFID II passporting across the EEA); Asset Management (COSIMO X); Development and Consumer (Amplify Digital).
- IN AUTHORIZATION (pending, not yet effective): Custody and Payments (Fortuna Digital Custody — in process with the Central Bank of Ireland for MiCA CASP status and PSD2 payment-institution authorization).
- MAINNET-READY (not live at scale): Settlement and Identity (Revolution Network).
- INFRASTRUCTURE-READY (built, not operational): Digital Asset Treasury (CDAT).
Pending authorizations are not effective until granted. Nothing on the site is an offer of securities or a projection of returns; third-party figures (e.g. Boston Consulting Group) are attributed to their sources.

## Platform
- [Platform overview](https://cosimodigital.com/platform): One firm, six connected layers, operated together under regulated control.
- [Regulated Issuance](https://cosimodigital.com/platform/regulated-issuance): Black Manta Capital Partners — BaFin-regulated Financial Services Institution (WpIG) for tokenized securities, MiFID II passporting across the EEA (LIVE). Supported by BMCP Securities S.à r.l., a Luxembourg securitization vehicle.
  - [How issuance works](https://cosimodigital.com/platform/regulated-issuance/how-issuance-works): The eight-week issuance path, from onboarding to distribution, through a segregated Luxembourg securitization compartment.
  - [Global footprint](https://cosimodigital.com/platform/regulated-issuance/global-footprint): BMCP's regulated presence across Europe, Asia, and North America.
- [Custody and Payments](https://cosimodigital.com/platform/custody-payments): Fortuna Digital Custody — MiCA custody and euro payments, in authorization with the Central Bank of Ireland (PENDING).
- [Digital Asset Treasury](https://cosimodigital.com/platform/digital-asset-treasury): CDAT — validator-treasury infrastructure across 40+ proof-of-stake networks with Dual-Rail redemption (INFRASTRUCTURE-READY).
- [Settlement and Identity](https://cosimodigital.com/platform/settlement-identity): Revolution Network — a zkStack Ethereum Layer-2 for real-world assets with compliant on-chain identity (MAINNET-READY).
- [Asset Management](https://cosimodigital.com/platform/asset-management): COSIMO X — what we believe to be the world's first tokenized evergreen venture fund, and the firm's origin (LIVE).
- [Development and Consumer](https://cosimodigital.com/platform/amplify): Amplify Digital — in-house development company and the bridge to end users (LIVE).

## COSIMO X (Asset Management)
- [Strategy](https://cosimodigital.com/platform/asset-management/strategy): The dual-rail thesis, five investment pillars (RWA tokenization, payments and stablecoins, private credit, equity and capital markets, and AI and blockchain), and capital allocation.
- [Portfolio](https://cosimodigital.com/platform/asset-management/portfolio): Selected investments across tokenized capital-markets infrastructure, active and realized.
- [Structure](https://cosimodigital.com/platform/asset-management/structure): What "tokenized evergreen" means — a Cayman exempted LP with tokenized interests via Securitize, evergreen duration, offered under Reg D / Reg S.
- [Track Record](https://cosimodigital.com/platform/asset-management/track-record): A decade of operating history (2014–2026) and the team behind the fund.

## Insights
- [The Equity Layer: Why the Fat Protocol Trade Is Dead](https://cosimodigital.com/insights/equity-layer-fat-protocol-trade-is-dead): Value accrues to regulated operating companies with enforceable claims on cash flows, not to tokens.
- [The NAV Discount Problem](https://cosimodigital.com/insights/nav-discount-digital-asset-treasuries): Why digital asset treasuries trade below their own assets, and the structural fix that restores arbitrage.
- [The ETF Playbook for Tokenization](https://cosimodigital.com/insights/etf-playbook-tokenization-wrapper-wins): The wrapper wins, not the asset — the ETF's operating-model lesson, one layer down.
- [Issuance Is Solved. Distribution Is the Binding Constraint.](https://cosimodigital.com/insights/issuance-solved-distribution-binding-constraint): Minting is a commodity; licensed reach and real secondary liquidity are the scarce, value-capturing layer.
- [MiFID II or MiCA](https://cosimodigital.com/insights/mifid-ii-or-mica-tokenized-securities): Which European license actually lets you issue tokenized securities, and why the distinction decides everything.
- [MiCA Reset the Market](https://cosimodigital.com/insights/mica-reset-licensed-minority): Of 1,200-plus pre-MiCA firms, roughly 210 secured authorization — the licensed minority captures the transition.

- [The End of Trust Intermediaries](https://cosimodigital.com/insights/end-of-trust-intermediaries): AI supplies trustless judgment and blockchain supplies trustless verification; together they make the institutional trust layer economically unnecessary.

## Learn
Plain explanations of how tokenization works in Europe. Question-led explainers and a definitional glossary. Informational only; not investment or legal advice.
- [Learn hub](https://cosimodigital.com/learn): Every explainer, grouped into tokenized funds and private markets, European regulation, custody, settlement and operations, and digital asset treasury. Last updated 28 July 2026.
- [How does fund tokenization work in Europe?](https://cosimodigital.com/learn/how-fund-tokenization-works): The mechanics end to end — legal wrapper, authorised manager, on-chain register, permissioned transfers and settlement — and what tokenizing a fund does not change. Last updated 28 July 2026.
- [How to tokenize a fund in Europe](https://cosimodigital.com/learn/how-to-tokenize-a-fund): The complete 2026 process — wrapper selection, MiCA or MiFID II classification, the four roles, a week-by-week timeline and indicative costs (€120k–€400k first issuance). Last updated 28 July 2026.
- [What is a tokenized fund?](https://cosimodigital.com/learn/tokenized-funds): Category pillar — structure, what the token legally represents, register maintenance and reconciliation, subscription and redemption mechanics, and the real risks. Last updated 28 July 2026.
- [MiFID II or MiCA — which one applies to your token?](https://cosimodigital.com/learn/mifid-ii-or-mica): Tokenized securities are financial instruments under MiFID II; MiCA Article 2(4)(a) excludes them. Five worked classification examples. Last updated 28 July 2026.
- [RWA tokenization platforms compared](https://cosimodigital.com/learn/rwa-tokenization-platforms-compared): Fifteen providers compared by regulator, licence, asset classes, jurisdictions, EU issuer access and stated limitations. Includes COSIMO’s own gaps. Updated quarterly.
- [Tokenized fund due diligence](https://cosimodigital.com/learn/tokenized-fund-due-diligence): The eight questions institutional allocators ask, with COSIMO Digital’s answers to all eight published in public. Last updated 28 July 2026.
- [Tokenized securities in Europe](https://cosimodigital.com/learn/tokenized-securities-europe): The EU authority anchor — MiCA, MiFID II, CSDR and the DLT Pilot Regime, where tokenized securities can be issued, traded, settled and custodied, and comparison with Switzerland, the UK and the US. Last updated 28 July 2026.
- [What is the DLT Pilot Regime and who is actually using it?](https://cosimodigital.com/learn/dlt-pilot-regime): CANONICAL. The three permissions, the CSDR and MiFID II exemptions granted, the Article 3 volume caps, what the regime was built to prove, the three authorised infrastructures (CSD Prague, 21X AG, 360X AG), why uptake is low, and the Commission’s 2026 upgrade proposal. Updated monthly.
- [Can a UCITS or AIF be tokenized?](https://cosimodigital.com/learn/ucits-aifmd-tokenization): What EU law allows, what ESMA has said about UCITS and AIFMD barriers, depositary obligations against a tokenized register, and which member states are furthest ahead. Last updated 28 July 2026.
- [EU digital asset regulation tracker](https://cosimodigital.com/learn/eu-digital-asset-regulation-tracker): Monthly-updated record of what is in force, what is in progress and who is authorised, dated per item with named sources. Month archive at /learn/eu-digital-asset-regulation-tracker/YYYY-MM (2026-07, 2026-06, 2026-03, 2026-01, 2025-12, 2025-06). Structured data at /learn/eu-digital-asset-regulation-tracker/tracker.json.
- [Securitize vs Ondo vs Superstate](https://cosimodigital.com/learn/securitize-vs-ondo-vs-superstate): Regulated infrastructure, product issuer and fund manager compared on roles, asset classes, regulation, EU access and pricing, with the gap all three share. Updated quarterly.
- [Tokenized treasury funds compared](https://cosimodigital.com/data/tokenized-treasuries): Ten tokenized treasury and money market products on size, yield, chain, issuer, custody, administration, fees and EU professional investor access. None is offered under an EU fund passport. Data as of 4 May 2026; structured data at /data/tokenized-treasuries.json.
- [What is the difference between a tokenized fund and an ETF?](https://cosimodigital.com/learn/tokenized-fund-vs-etf): Both are wrappers. They differ on who may hold them, where they trade, and how title moves; an ETF settles through a CSD, a tokenized fund moves title on a register that enforces eligibility at transfer. Last updated 28 July 2026.
- [How do subscriptions and redemptions work in a tokenized fund?](https://cosimodigital.com/learn/tokenized-fund-subscriptions-redemptions): Five-step subscription, redemption mechanics, when NAV strikes, the three cash-leg options, and the failure cases investors meet first. Last updated 28 July 2026.
- [What does a four-year-old tokenized fund prove?](https://cosimodigital.com/learn/cosimo-x-tokenized-fund-track-record): COSIMO X, live since 2021 and listed on Securitize Markets in December 2021: what four years of operating record evidences, and what it does not. Last updated 28 July 2026.
- [What is a MiCA CASP authorisation and who needs one?](https://cosimodigital.com/learn/mica-casp-authorisation): CANONICAL. The ten services in scope, the EEA passport, own funds by class (€50k/€125k/€150k or a quarter of fixed overheads), governance expectations, 9–18 month timelines, six jurisdictions compared (Ireland, Luxembourg, Germany, Malta, Lithuania, Netherlands), and why a national VASP registration is not the same thing. Last updated 28 July 2026.
- [Who can custody tokenized securities in Europe?](https://cosimodigital.com/learn/custody-tokenized-securities-europe): CANONICAL. Custody of a financial instrument (MiFID II, plus CSDR at settlement) versus custody of a crypto-asset (MiCA CASP), which permission applies to which instrument, segregation and insolvency, and nine questions for a custodian. Last updated 28 July 2026.
- [What is atomic settlement and does it work today?](https://cosimodigital.com/learn/atomic-settlement-dvp): Both legs in one indivisible transaction. The asset leg is straightforward on-chain; the cash leg needs e-money tokens, tokenized deposits or central bank money on the same ledger. Last updated 28 July 2026.
- [How is investor identity checked before a token transfer?](https://cosimodigital.com/learn/investor-identity-token-transfer): Verified off-chain, whitelisted on-chain, enforced by the token contract before execution, with ERC-3643 embedding the check in the token itself. Last updated 28 July 2026.
- [What does a transfer agent do for a tokenized fund?](https://cosimodigital.com/learn/transfer-agent-tokenized-fund): Tokenizing units does not remove the role. It moves where the record sits and adds a reconciliation obligation between the chain and the book. Last updated 28 July 2026.
- [What is a digital asset treasury?](https://cosimodigital.com/learn/digital-asset-treasury): A governance structure, not a product: written policy, custody framework and reporting line. Without those three it is a position, not a treasury. Last updated 28 July 2026.
- [Why do digital asset treasuries trade below NAV?](https://cosimodigital.com/learn/mnav-digital-asset-treasury-discount): What mNAV measures, why a discount opens when investors can buy the asset directly, why it persists without an arbitrage mechanism, and what closes it. Last updated 28 July 2026.
- [What belongs in a digital asset treasury policy?](https://cosimodigital.com/learn/digital-asset-treasury-policy): Seven sections: eligible assets and sizing, custody and permissions, counterparty limits, liquidity ladder, valuation, disclosure, and approval and review. Last updated 28 July 2026.
- [How many firms have MiCA authorisation?](https://cosimodigital.com/data/mica-authorisation-count): Roughly 210 of approximately 1,200 pre-MiCA firms, about one in six. Comparison with the pre-MiCA population, where to verify by member state, what happened to the rest, and the official ESMA register. Data as of 28 July 2026; updated monthly.
- [Tokenization glossary: MiCA, MiFID II and digital asset terms defined](https://cosimodigital.com/learn/glossary): Thirty definitions covering tokenization, security tokens, MiCA, CASP, ART, EMT, MiFID II, the DLT Pilot Regime, ESMA, CSDR, UCITS, AIFMD, custody, VASP, atomic settlement, DvP, NAV, mNAV, digital asset treasury, ERC-3643, whitelisting and the on-chain register. Last updated 28 July 2026.

## Company
- [The Opportunity](https://cosimodigital.com/opportunity): Why the licensed players capture the tokenization transition now that MiCA has reset the European market.
- [Regulatory](https://cosimodigital.com/regulatory): Authorizations and their status across the group.
- [About](https://cosimodigital.com/about): The firm, its thesis, and its history.
- [Team](https://cosimodigital.com/team): Leadership — Rob Frasca, Ciarán Hynes, Connor Cantwell.
- [Investors](https://cosimodigital.com/investors): Investor inquiries; qualified investors under NDA.
- [Contact](https://cosimodigital.com/contact): General contact.
- [Careers](https://cosimodigital.com/careers): Open roles.

## Legal
- [Privacy](https://cosimodigital.com/legal/privacy)
- [Terms](https://cosimodigital.com/legal/terms)
- [Investor Considerations](https://cosimodigital.com/legal/investor-considerations)