DA-02 - The Structural Architecture of Blockchain and Web3 Systems Layered Analysis for Legal and Regulatory Classification

Evelyse Carvalho-Ribas

Abstract

Legal and regulatory classification of blockchain and Web3 systems has historically proceeded from surface characteristics — technical claims, economic narratives, or jurisdictional assumptions — without prior systematic separation and analysis of the distinct structural layers that compose these systems. This analytical sequence — from nominal labels toward governance reality — has generated persistent uncertainty, fragmented regulatory outcomes, and unstable classifications subject to revision as institutional understanding evolves.1

This paper inverts the analytical sequence. Rather than beginning with regulatory categories and asking whether a blockchain system fits within them, it begins with the structural architecture of the system itself: decomposing its technical infrastructure, token mechanics, economic incentive design, legal rights and obligations, governance arrangements, and jurisdictional exposure into six analytically distinct layers. Each layer operates under different institutional mandates, engages different regulatory authorities, and generates different legal consequences — yet the layers interact continuously and cannot be assessed in isolation without distorting the regulatory analysis.2

The six-layer decomposition — Infrastructure, Token Classification, Economic, Legal, Governance, and Jurisdictional — provides a practical framework for this analysis, rendering visible the points at which layers interact, the misalignments that may create regulatory vulnerability, and the opportunities for governance redesign that may reduce institutional concern without compromising functionality. The Multi-Layer Governance Framework for Blockchain and Digital Assets (Carvalho-Ribas) operationalises this approach by providing professionals, regulators, and policymakers with a shared vocabulary and analytical method for assessing how these systems are actually constructed, how authority and responsibility are distributed, and where gaps between governance design and legal expectations are likely to create friction or enforcement risk.3

The paper draws on regulatory regimes and supervisory practices across the European Union (MiCA, MiFID II, DAC8), the United Kingdom (FSMA 2023, FCA guidance), the United States (SEC enforcement and evolving policy), Singapore (Payment Services Act and stablecoin framework), Hong Kong (AMLO Part 5A), Japan (FIEA and PSA amendments), Australia (ASIC INFO 225 and token mapping), and Brazil (Lei 14.478/2022), alongside international frameworks including OECD CARF, FATF Recommendation 15, and emerging cross-border tax transparency obligations. It is intended for advanced professional audiences who are required to decide, classify, approve, audit, supervise, or regulate digital asset structures across multiple legal orders simultaneously.

Blockchain · Web3 · Digital Assets · Structural Layers · Governance Architecture · Token Classification · Legal Classification · Regulatory Perimeter · MiCA · DAOs · Decentralised Finance · Institutional Analysis · Cross-Border Regulation · Multi-Layer Framework

Definitions

This section establishes the operative definitions used throughout the paper. Consistent with DA-01, definitions are functional, governance-oriented, and system-neutral. They are constructed to support structural analysis rather than to reproduce the classificatory preferences of any single regulatory authority. Where official legal definitions exist, they are referenced accordingly. Where definitions are developed for the purposes of this paper, they are expressly identified as workable analytical definitions supporting governance-grade legal analysis across jurisdictions.4

Why Structural Separation Precedes Legal Classification

The standard approach to digital asset regulation begins with classification: ‘What is this token?’, ‘Which regulatory regime does it fall into?’, ‘Is it a security, a payment instrument, or a utility?’ This approach assumes that legal categories can be applied directly to digital assets without first understanding the structural architecture of the system within which those assets exist and function. In practice, this assumption fails repeatedly — producing classifications that are unstable, contested, and vulnerable to revision as institutional understanding deepens.12

The reason for this persistent instability is structural: digital assets are not discrete regulatory objects. They are components of multi-layered systems in which technical architecture, economic incentives, governance arrangements, legal obligations, and jurisdictional exposure interact continuously. A token’s legal classification depends not only on its formal characteristics but on who controls the system, how value is distributed, what governance mechanisms actually operate (as distinct from those claimed), and how multiple jurisdictions assert authority over different aspects of the same system. Classification that ignores these structural dimensions captures only a fraction of the regulatory reality.

This paper proposes that structural separation is the prerequisite for reliable legal classification. Before asking ‘what is this token?’, the practitioner must ask: ‘how is this system actually built?’, ‘who exercises control?’, ‘how is value captured and distributed?’, and ‘which jurisdictions can assert authority?’ Only after these structural questions are addressed can classification proceed on a stable foundation.

The analytical failure of classification-first approaches is visible across jurisdictions. Under MiCA, the EU’s comprehensive framework for markets in crypto-assets, token classification turns substantially on function — whether the token confers rights to payment (e-money tokens under Title IV), references other assets to maintain stable value (asset-referenced tokens under Title III), or provides utility access (other crypto-assets under Title II).13 But ‘function’ is not self-evident from the token’s description or whitepaper. A token described as ‘purely utility’ may function economically as an investment instrument if its value derives from network growth, scarcity mechanisms, or the discretionary decisions of a concentrated group of developers or validators. The structural context determines the regulatory outcome.

The SEC’s enforcement-driven approach in the United States illustrates the same point from a different direction. The Howey test asks whether there is an ‘investment of money in a common enterprise with an expectation of profits derived from the efforts of others’.14 In SEC v. Ripple Labs, the court distinguished between programmatic sales of XRP on public exchanges — where purchasers did not have a reasonable expectation of receiving profits from Ripple’s efforts — and institutional sales directly from Ripple, which did constitute unregistered securities offerings.15 This bifurcated outcome demonstrates that the same token can receive different regulatory treatment depending on the channel of distribution, the nature of the counterparty relationship, and the economic substance of the transaction — all structural variables that a classification-first approach fails to capture.

Singapore’s Payment Services Act 2019 (as amended 2021) classifies digital payment tokens as a distinct category for licensing purposes, while the Monetary Authority of Singapore’s stablecoin framework (August 2023) imposes additional structural requirements — including reserve composition, capital adequacy, and redemption mechanisms — that determine whether a stablecoin can be marketed as ‘MAS-regulated’.16 In Hong Kong, the VASP licensing regime under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO Part 5A, effective 1 June 2023) regulates centralised virtual asset trading platforms rather than classifying individual tokens — a regulatory approach that targets the institutional structure of intermediaries rather than the characteristics of assets.17

Across all of these jurisdictions, the pattern is the same: regulatory outcomes are determined not by the token’s label but by the structural architecture of the system, the governance arrangements that control it, the economic substance of the relationships it creates, and the jurisdictional channels through which authority is exercised. Structural analysis must precede classification.

The Infrastructure Layer and Token Classification

III.A — The Infrastructure Layer (L1–L3)

The Infrastructure Layer comprises three sub-layers: the protocol layer (consensus mechanisms, cryptographic primitives, data structures), the execution layer (smart contracts, state management, transaction processing), and the application and service layer (user interfaces, custody solutions, bridges, oracles, scalability solutions). Collectively, these layers define what a blockchain system technically allows, prevents, or makes difficult for participants to accomplish.18

From a regulatory and governance perspective, the Infrastructure Layer is examined not for its technical specifications, but for how architectural choices enable, constrain, or obscure legal accountability and institutional oversight. This distinction is crucial: a cryptographically secure protocol does not, by itself, establish legal responsibility or reduce regulatory risk if the governance, economic, or jurisdictional layers contain concentrated control or asymmetric benefit distribution. Conversely, decentralised or distributed technical architecture does not eliminate legal exposure if off-chain governance, intermediary involvement, or value concentration creates identifiable points of control or benefit.

Key regulatory implications of the Infrastructure Layer include: (1) whether the system is permissionless or permissioned, affecting financial regulation classification and AML/CFT obligations; (2) whether key functions such as upgrade authority, validator selection, or fee setting are technically decentralised or subject to de facto control; (3) the role of intermediaries (validators, custodians, bridges) in introducing points of legal exposure and institutional jurisdiction; (4) how the technical architecture shapes tax treatment of transactions and rewards; and (5) whether technical features such as immutability or transaction finality have regulatory significance.19

The Infrastructure Layer does not determine regulatory outcome by itself. Rather, it provides the technical context for the other structural layers — determining what governance arrangements are technically possible, what economic incentives the architecture enables, what legal relationships it makes visible or obscures, and what institutional actors have meaningful control or influence.

III.B — Token Classification as a Structural Exercise

Token classification — the legal qualification of a token or crypto-asset as a ‘security’, ‘commodity’, ‘utility’, ‘payment instrument’, ‘electronic money’, or some combination — is one of the most consequential and contested determinations in digital asset regulation. The standard regulatory approach asks: ‘What is this token called, what rights does it confer, and which legal regime does it fall into?’ This is a nominalist and documentary approach, focusing on form and label.20

This paper reframes token classification as a structural exercise, informed by a prior analysis of how value is distributed, who exercises control, what economic benefits accrue to different actors, and what governance decisions are made off-chain. In this structural approach, the question becomes: ‘Given the governance arrangements, economic incentives, and control structure of this system, and given the function this token actually serves within it, what regulatory classification is mandated by law and institutional practice?’

Under MiCA and comparable financial regulatory frameworks, token classification turns substantially on function: whether the token confers rights to payment, investment, utility access, or some combination thereof.21 But ‘function’ is not determined by whitepaper claims or protocol specifications; it emerges from how the token is actually issued, how its value is driven or maintained, what decision-making power it confers, and what economic benefits it distributes. A token may be described as ‘purely utility’ in documentation while functioning economically as an investment instrument if its value derives from network growth, scarcity mechanisms, or the discretionary decisions of a concentrated group of developers or validators. Conversely, a token with significant governance and economic rights may be accurately classified as a ‘payment instrument’ if transaction speed and cost efficiency are its primary design purpose and users value and trade it principally for that functionality.

The structural approach to token classification therefore requires integration with the Economic Layer (how value is created and distributed), the Governance Layer (who exercises control), and the Legal Layer (what rights and obligations are actually created). Classification divorced from this multi-layer context tends to be unstable, contested, and vulnerable to revision as institutional understanding evolves. A token classified as ‘not a security’ on its issuance may be reclassified if governance becomes concentrated, if secondary market development introduces investment characteristics, or if institutional expectations shift regarding the role of developers or foundation entities.22

The Economic and Legal Layers: Value, Rights, and Structural Interdependence

IV.A — The Economic Layer: Value Capture and Incentive Design

The Economic Layer comprises the mechanisms through which value is created, allocated, captured, and distributed within a blockchain system. This includes token issuance and distribution, vesting schedules, staking and reward mechanisms, treasury management and allocation, protocol-level revenues, developer compensation, and the incentive structures that motivate participation and network growth.23

From a legal and institutional perspective, the Economic Layer is essential to tax assessment, financial regulatory classification, and accounting treatment. It is also central to institutional assessment of control and governance alignment. Authorities consistently examine whether value distribution corresponds to claimed governance structures, whether concentrated tokenholders have influence proportionate to their economic interests, whether developer or validator rewards create conflicts of interest, and whether incentive structures are sustainable or reflect hidden dependencies on continued price appreciation.

Key regulatory and tax implications of the Economic Layer include: (1) the characterisation of tokens and token income for tax purposes (capital gains, income, investment, services rendered);24 (2) the identification of value creation points for transfer pricing and nexus analysis; (3) the assessment of whether economic substance justifies claimed legal characterisations (whether a ‘utility’ token truly functions as such, or whether value is principally speculative); (4) the evaluation of conflicts of interest or perverse incentives created by token distributions or treasury allocation; and (5) the assessment of sustainability and systemic risk where participants’ incentives depend on continued price appreciation or the discretionary actions of concentrated developer teams.

The Economic Layer frequently diverges from formal governance arrangements. A system may have highly decentralised protocol governance while concentrating economic benefits through treasury allocation, fee structures, or staking rewards. Conversely, a system with concentrated formal governance may distribute economic benefits widely through fair and transparent mechanisms. Regulatory and institutional assessment focuses on these interactions: where the Economic Layer reveals concentrated or asymmetric benefit distribution, governance claims of decentralisation become subject to heightened scrutiny, and regulatory classification tends to shift toward more intrusive regimes regardless of technical or formal governance features.25

IV.B — The Legal Layer: Rights, Claims, and Liability

The Legal Layer encompasses the rights, claims, obligations, and liabilities that arise in connection with participation in a blockchain system and holding of tokens. These include property rights (ownership, custody, transfer rights), contractual rights and obligations (imposed by protocol rules, terms of service, or governance documents), tortious liabilities (negligence in system operation, breaches of duty), criminal exposures (market manipulation, fraud, money laundering), regulatory compliance obligations (AML/CFT, disclosure, conduct of business), and tax obligations.

The Legal Layer is the domain in which blockchain and Web3 systems interface with formal legal systems. It is assessed through comparative law analysis rather than through technical description or protocol claims. The analysis must address: (1) what legal rights and interests are actually created by participation in the system; (2) what happens to those rights if the system malfunctions, is attacked, or is subjected to regulation or enforcement; (3) who bears liability for losses or harm, and what remedies are available; (4) how these rights and liabilities are distributed across different classes of participants (users, developers, validators, intermediaries, foundation entities); and (5) how these arrangements interact with applicable property law, contract law, corporate and governance law, and financial regulation.26

A particular focus of the Legal Layer is the question of responsibility and liability in the absence of traditional intermediaries or identifiable entities. In decentralised or semi-decentralised systems, who is responsible if a smart contract contains a bug that results in loss of funds? Who is liable if a consensus mechanism fails and a hard fork is required? Who manages disputes or compensates harmed parties? In systems where off-chain governance is diffuse or informal, authority may be opaque, and responsibility may be fragmented across developers, core contributors, major tokenholders, and foundation or company entities. This fragmentation itself becomes a source of regulatory concern, as it creates uncertainty regarding liability, enforcement targets, and the protection of affected parties.

The UK’s Property (Digital Assets etc) Bill, introduced in the House of Lords on 11 September 2024, represents a significant development in the Legal Layer. Building on the Law Commission’s 2023 report (Law Com No 412), the Bill confirms that digital assets can constitute personal property — a ‘third category’ beyond things in possession and things in action — providing foundational legal clarity for ownership, transfer, and enforcement.27 Similar developments are under consideration in other common law jurisdictions, reflecting growing recognition that existing property law categories require adaptation to accommodate digital assets.

Governance, Jurisdiction, and Multi-Layer Analysis

V.A — The Governance Layer: Decision Power and Accountability

The Governance Layer concerns the allocation of decision-making power, control mechanisms, and accountability within a blockchain system. This encompasses formal governance organs (boards, foundations, protocol governance through token voting or delegated voting, DAOs, stakeholder councils) and de facto control arrangements (developer dominance, validator authority, key custodian functions, treasury management by concentrated parties, off-chain coordination by core teams).28

This layer is often decisive in institutional and regulatory assessment of blockchain systems. Authorities consistently prioritise governance realities over technical features or decentralisation narratives. A system claimed to be ‘decentralised’ but in which a small group of developers exercises de facto control over protocol changes, treasury allocation, or platform direction, is assessed as concentrated governance. Conversely, a system with formal concentration but robust institutional checks, clear processes for decision-making, and transparent mechanisms for dispute resolution may be assessed as adequately governed despite concentrated formal authority.

The governance gap — the divergence between claimed governance structures and actual decision-making realities — is empirically well-documented. Research on DAO governance has shown that many nominally decentralised protocols exhibit concentrated voting power, low participation rates, and de facto control by founding teams or large token holders.29 The Compound governance incident of July 2024 — in which a concentrated group of whale voters passed Proposal 289 to allocate approximately $24 million from the protocol treasury to a yield-bearing vehicle they controlled — illustrates how token-weighted governance can be captured by concentrated economic interests.30 The Beanstalk flash loan attack of April 2022, where an attacker used borrowed capital to acquire enough governance tokens to pass a malicious proposal draining approximately $182 million, demonstrates the vulnerability of purely on-chain governance to economic manipulation.31

Governance assessment is particularly important for DAOs and decentralised finance protocols, where formal governance is often distributed while actual decision-making power may be concentrated. Regulatory and institutional practice shows that where nominal governance is decentralised but actual control is concentrated, or where governance structures lack processes for responding to regulatory direction, regulators are more likely to identify responsible actors, assert enforcement jurisdiction, and require governance redesign.32

V.B — The Jurisdictional Layer: Where Law Actually Bites

The Jurisdictional Layer addresses how legal authority, supervisory competence, and enforcement power attach to a blockchain system and its participants. It encompasses questions of territorial jurisdiction, nexus (what connects a system or actor to a particular legal order), extraterritorial reach, and the mechanisms through which multiple legal orders assert claims over a single distributed or semi-distributed system.

In principle, blockchain and Web3 systems are transnational: participants, developers, validators, and users may be located in different jurisdictions; value flows may cross borders; governance decisions may be made off-chain by geographically distributed parties. In practice, law asserts itself through multiple channels: regulation of intermediaries (custodians, exchanges, payment processors) located in a jurisdiction; regulation of ‘consumers’ or market participants resident in a jurisdiction; regulation of persons or entities providing services in relation to the system; regulation of financial instruments or payment systems; and regulation of providers of infrastructure or critical services.33

The Jurisdictional Layer has become increasingly important as regulators have recognised that decentralisation of technical infrastructure does not prevent legal authority from attaching. Through regulation of intermediaries — particularly custodians, exchanges, and payment processors — regulators in major jurisdictions (EU, UK, US, Singapore, Hong Kong, Japan) can impose significant compliance burdens on blockchain-based systems, forcing either adaptation or exit from those markets.

For blockchain systems operating across multiple jurisdictions, the Jurisdictional Layer creates a cumulative compliance burden: the system must satisfy AML/CFT obligations in each jurisdiction where it operates or where its intermediaries are located; must comply with securities regulation in each jurisdiction where its tokens are offered or traded; must respect consumer protection, data protection, and conduct-of-business rules in each jurisdiction; must respond to tax inquiries and reporting obligations in multiple jurisdictions; and must coordinate with regulators who may interpret existing legal frameworks differently or introduce new rules.34

V.C — The Multi-Layer Governance Framework

The analytical power of systematic structural separation emerges when these six layers are examined not in isolation but in interaction. The Multi-Layer Governance Framework for Blockchain and Digital Assets (Carvalho-Ribas) operationalises this integrative analysis by providing a disciplined method for: (1) decomposing a blockchain or Web3 system into its analytically distinct layers; (2) assessing what laws and institutional mandates apply to each layer; (3) identifying misalignments between layers (for example, where technical decentralisation obscures concentrated governance, or where claimed governance structures are contradicted by economic substance); (4) anticipating how different authorities are likely to assess the system; and (5) identifying points at which governance redesign, compliance infrastructure, or operational adaptation may be required.37

The Framework is system-neutral and jurisdiction-agnostic. It can be applied to permissionless and permissioned systems, centralised and decentralised structures, early-stage projects, and mature ecosystems. It does not prescribe outcomes; it offers a method for making governance dynamics visible and explicable. For practitioners, this means the ability to assess regulatory risk not through checklist compliance, but through analysis of how institutional actors are likely to interpret and interact with the system. For regulators, it provides a framework for coordinated assessment and the identification of gaps or inconsistencies in how different authorities approach similar arrangements. For policymakers, it supports the design of regulatory frameworks that acknowledge structural complexity rather than attempting to compress multi-layer arrangements into narrowly drawn categories.

The Framework operates across six layers that are conceptually separable, subject to distinct legal regimes, and regulated by distinct authorities, yet are structurally and functionally interdependent. By making these interactions explicit, the Framework supports more reliable anticipation of institutional responses and more robust governance design.

High-Value Domain for Global Practice

Blockchain, Web3, and digital assets constitute a high-value domain for legal, regulatory, and tax practice precisely because they concentrate multiple sources of legal and institutional complexity within a single operational field. This concentration generates sustained demand for advanced professional judgment, structured institutional engagement, and cross-border coordination — features that scholarship on complex financial infrastructures associates with high-value advisory work rather than routine compliance.38

From a professional practice perspective, value in this domain arises at the intersection of legal uncertainty, institutional discretion, and multi-jurisdictional exposure. Digital asset systems frequently operate across several legal orders while engaging regulatory regimes — financial regulation, tax law, AML/CFT frameworks, data protection, corporate governance — that were not designed to interoperate seamlessly. Professionals must translate risk and expectations across institutions with differing mandates, supervisory cultures, and enforcement priorities. This translation function requires not only doctrinal knowledge but also institutional literacy and the ability to anticipate how different authorities are likely to interpret and respond to similar arrangements.

The structural analytical framework introduced in this paper — decomposing systems into Infrastructure, Token Classification, Economic, Legal, Governance, and Jurisdictional layers — provides professionals with a disciplined method for this translation work. Rather than asking ‘is this a security?’, professionals can ask ‘what are all the distinct regulatory dimensions of this system, which authorities are likely to assess each dimension, and where are the pressure points at which institutional expectations are likely to be activated?’ This shift of focus from nominal classification to structural analysis marks the distinction between transactional support and high-value professional engagement.39

Governance design represents another area of significant value. In contrast to many regulated sectors where governance structures are standardised or prescribed, blockchain-based systems often embed governance choices within the product design itself: token rights and voting mechanisms, treasury allocation rules, upgrade procedures, and participation thresholds are designed as part of the protocol or ecosystem architecture. Professionals who understand how governance architecture translates into regulatory and tax consequences are able to influence system design ex ante, rather than merely reacting ex post to enforcement or regulatory change.

Jurisdictional coordination and cross-border strategy represent a third high-value area. Blockchain systems by definition operate across borders, yet regulators increasingly assert jurisdiction and coordinate enforcement. Professionals capable of assessing cumulative compliance burdens, identifying the key jurisdictions in which pressure is likely to materialise, and negotiating between institutional expectations — adapting governance or operations to satisfy regulatory mandates in multiple legal orders simultaneously — create measurable value in reducing enforcement risk, managing compliance costs, and preserving operational viability.40

Knowledge and Practice Continuity

This paper forms part of a structured doctrinal system dedicated to the legal, regulatory, and governance analysis of blockchain, Web3, and digital asset systems across multiple jurisdictions and institutional settings. Within this system, each paper performs a distinct analytical function while remaining structurally interdependent with the others. The series is designed to examine how blockchain and digital asset-based systems are shaped, constrained, and governed through the interaction of multiple governance layers — national, supranational, and international — and through the distinct analytical lenses of structural decomposition, institutional assessment, and comparative regulatory practice.

From a knowledge and practice architecture perspective, this Authority PDF constitutes a foundational layer, establishing the structural concepts, analytical frameworks, and diagnostic methods that are then deployed through structured professional training, advanced coursework, and implementation cohorts. Each tier builds on prior analytical clarity and institutional literacy, ensuring continuity between doctrine, interpretation, and professional practice.

Conclusions

Legal and regulatory classification of blockchain and Web3 systems has historically proceeded from surface characteristics, technical claims, or economic narratives, without prior systematic separation and analysis of the distinct structural layers that compose these systems. This analytical sequence — from nominal labels toward governance reality — has generated persistent uncertainty, fragmented regulatory outcomes, and unstable classifications that are subject to revision as institutional understanding evolves and new information becomes available.

By inverting the analytical sequence — moving from structural separation toward informed legal classification — this paper demonstrates that regulatory risk can be more reliably assessed, institutional responses can be more accurately anticipated, and governance design can be adapted to align with regulatory expectations. The six-layer decomposition (Infrastructure, Token Classification, Economic, Legal, Governance, Jurisdictional) provides a practical framework for this analysis, rendering visible the points at which layers interact, the misalignments that may create regulatory vulnerability, and the opportunities for governance redesign that may reduce institutional concern without compromising functionality.41

The Multi-Layer Governance Framework for Blockchain and Digital Assets (Carvalho-Ribas) operationalises this approach by providing professionals, regulators, and policymakers with a shared vocabulary and analytical method for assessing how these systems are actually constructed, how authority and responsibility are distributed, and where gaps between governance design and legal expectations are likely to create friction or enforcement risk. This is not a compliance tool or a technical specification; it is an interpretative framework designed to support institutional analysis, cross-border coordination, and the development of governance structures capable of evolving alongside the regulatory and supervisory landscape.42

In a domain characterised by rapid technological change, expanding regulatory activity, and persistent uncertainty regarding institutional expectations, the value of systematic structural analysis lies not in eliminating uncertainty — which is impossible — but in making governance dynamics visible and explicable, in supporting coordination across institutions and jurisdictions, and in enabling professionals and policymakers to develop and refine governance approaches grounded in institutional realities rather than in technical narratives or nominal classifications. This is the foundation upon which reliable, durable, and institutionally coherent digital asset systems are built.

Frequently asked

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Endnotes

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