Three years after withdrawing from the US retail market and agreeing to a $45 million settlement, Nexo has quietly rebooted its US presence with a markedly different architecture. The relaunch is not a flashy rebrand of the old Earn product; it is a structural shift toward regulated infrastructure, designed to satisfy a regulatory framework that favors licensed intermediaries over direct yield issuance. The company’s comeback comes as the broader US crypto lending landscape continues to evolve—tethered to state-by-state licensing, disclosures, and ongoing scrutiny of how retail users are exposed to yield and risk. This piece examines what changed, why regulators pushed back in 2023, and how the 2026 model is positioned within a shifting enforcement environment, while outlining what US users should monitor before engaging with crypto-backed loans or yield-like offerings.

Key takeaways

• After paying a $45 million settlement in 2023 and exiting the market, Nexo has reentered the US with a redesigned product model focused on regulatory alignment rather than direct yield issuance.

• The 2023 crackdown centered on unregistered securities concerns. The SEC alleged that Nexo’s Earn Interest Product functioned as an unregistered security, raising questions about retail yield marketing, transparency, custody practices and counterparty risk.

• The new model relies on licensed US partners. Instead of directly offering yield products, Nexo now operates through regulated US intermediaries, including licensed entities and, where required, SEC-registered investment advisers.

• The Bakkt partnership anchors the compliance strategy. By collaborating with Bakkt, a publicly traded US crypto firm with regulatory licenses, Nexo shifts from a direct issuer model to a partner-delivered framework embedded within regulated infrastructure. (EXCHANGE: BKKT)

• The comeback is a structural overhaul rather than a mere timing shift. US users should watch for disclosures, custody arrangements, and the role of intermediaries as the model unfolds.

Three years after exiting the US retail market and settling with federal and state regulators, Nexo’s return signals a deliberate pivot. It is not simply a resumption of old products under a new banner; it is an attempt to align with a regulated ecosystem that emphasizes transparency, risk controls and clearly defined counterparty relationships. The 2026 framework appears designed to keep yield-generating services within a compliant infrastructure, reducing the likelihood of unregistered securities concerns that previously drew regulatory heat.

What changed is not only the timing or political backdrop; it is the way these products are designed, delivered and supervised. The company’s latest disclosures stress an architecture in which licensed intermediaries and, when required, investment advisers sit between the user and any yield-like opportunity. The shift is part of a broader rethinking of how centralized crypto lending should operate in the United States, especially after the industry experienced liquidity strains and opaque yield structures in the wake of 2022’s market stress.

As part of its updated model, Nexo states that it will offer crypto-backed loans and yield-generating products through a network of licensed US partners. Crypto-backed loans, which use digital assets as collateral, require careful structuring around loan-to-value thresholds and liquidation terms. By channeling these products through regulated entities, Nexo aims to provide a more robust framework for risk disclosures and custody arrangements, addressing some of the concerns that regulators highlighted in the 2023 action.

The Bakkt partnership: Compliance by design

A central plank of the relaunch is the collaboration with Bakkt, a publicly traded US crypto firm with regulatory licenses. This partnership is meant to anchor the compliance framework by moving away from a direct issuer model to a partner-delivered ecosystem housed within regulated infrastructure. In practical terms, trading, custody, and advisory services would sit with licensed entities, while product components could be distributed through registered intermediaries. The approach is designed to satisfy regulator expectations for disclosures, risk management and clear line-of-sight into who is providing which service.

From a practical standpoint, the shift to a partner-led model reduces the direct exposure of retail customers to an issuer’s internal yield generation mechanics. Instead, the revenue and risk flow through an ecosystem of regulated participants, which in theory should improve oversight and reduce the potential conflicts of interest that can arise when an unregistered product is marketed to everyday investors. This approach also aligns with a broader trend in the US crypto industry: leveraging established, licensed infrastructure to deliver crypto services in a compliant manner rather than pushing the envelope on securities law through standalone product issuance.

It’s also worth noting that the regulatory backdrop remains nuanced. While enforcement actions shifted in late 2020s policy discussions, federal and state authorities continue to scrutinize offerings that resemble investment contracts or that blur the line between traditional banking and crypto lending. The Bakkt-backed model represents an attempt to thread the needle—offering access to lending and yield opportunities while embedding the activities within structures that regulators can monitor and regulate more effectively.

Beyond Bakkt, Nexo’s plan dovetails with ongoing regulatory discussions around custody, disclosures, and the sources of yield. The broader debate about how to classify crypto-based investment products—whether as securities, commodities or a new category—continues to shape the design of compliant offerings. For readers following the policy arc, recent coverage of how regulatory proposals could redefine commodities and securities remains relevant as the industry tests compliant wrappers for yield-related products.

Market context

Market context: The US regulatory environment for crypto lending remains fragmented, with federal and state authorities evaluating risk, disclosures and investor protection. The 2023 crackdown highlighted concerns about retail access to high-yield products and theOpacity around how returns were generated. Since then, enforcement has shown signs of recalibration, with some actions winding down and others continuing, but the industry is increasingly experimenting with partner-led models that align with licensed infrastructure and enhanced disclosures.

Why it matters

The Nexo return matters because it could signal a broader shift in how offshore or non-US-centric crypto firms re-enter the United States. If more projects adopt partner-led models with licensed intermediaries, it may reduce the likelihood of abrupt withdrawals and punitive penalties that followed early-2020s enforcement actions. For users, the implication is clearer disclosures, potentially better custody arrangements, and a framework where the counterparty risk and revenue sources are more explicit.

From a builder’s perspective, the emphasis on regulated wrappers could spur innovation in compliant product design. Companies may be more willing to collaborate with licensed intermediaries and investment advisers to offer yield-oriented products within a transparent, auditable structure. Critics, however, will watch closely to ensure that “compliant by design” does not become a cover for reduced access to liquidity or less competitive yields. The distinction between compliant structure and risk-free products remains critical; even with licensing and custody safeguards, users should assess loan terms, LTV thresholds, and potential fees with a critical eye.

In the broader industry, Nexo’s comeback is part of a larger pattern of cross-border crypto firms seeking to re-engage with the US market through compliant, partner-led approaches. If the model proves viable, it could open the door for other international players to reenter through similar regulatory wrappers rather than direct issuance. In the near term, the emphasis on disclosure quality, risk management, and clarity around revenue sources will be pivotal in determining whether this structural shift sustains long-term legitimacy in the eyes of regulators and investors alike.

What to watch next

• Details of the licensing framework and the specific US partners involved in the model.

• Regulatory approvals or filings at the federal or state level that may affect rollout timelines.

• Progress of Bakkt’s integration and the distribution of product elements through licensed intermediaries.

• Any new risk disclosures or consumer-protection measures required by regulators and how they are communicated to users.

• Developments in US crypto lending regulation and how future policy could shape partner-led models.

Sources & verification

• Nexo’s 2023 settlement with the SEC and NASAA over the Earn product; verify via the referenced coverage describing a $45 million settlement and the scope of the unregistered securities allegations.
• Nexo’s 2026 return to the US through a press release announcing the relaunch and the partnership-driven structure.
• Nexo’s public blog post about the updated US strategy for clients, detailing the shift to licensed intermediaries and advisers.
• Cointelegraph reporting on related regulatory actions and market context, including coverage of Gemini Earn developments and broader enforcement trends.

Nexo’s US comeback: a structural overhaul anchored in regulated infrastructure

Nexo’s latest iteration presents a reimagined blueprint for delivering crypto-backed lending and yield opportunities within a regulated framework. The company emphasizes that the core idea—allowing users to borrow against digital assets and to earn yield through compliant means—remains intact. What has evolved is the wrapper around the product. The Earn-like offerings of the pre-2023 era were designed and marketed in ways regulators found problematic, particularly when returns were advertised to retail users without transparent disclosures or a clear line of counterparty risk. The 2023 settlement underscored these concerns and set the stage for a redesigned approach that prioritizes compliance from the outset.

In the 2026 structure, Nexo positions its services within the ecosystem of licensed US participants, with custody and advisory functions distributed across regulated entities. Bakkt (EXCHANGE: BKKT), a partner in this strategy, is intended to provide the regulated backbone that supports the delivery of crypto-backed loans and other yield-generating services. By embedding activities within a regulated infrastructure, the company aims to address the transparency and risk-management questions that regulators raised in 2023, including how returns are generated, who truly bears the risk, and how assets are custodied and safeguarded.

From a regulatory vantage point, the shift toward partner-led models reflects a broader trend in the industry: policymakers are seeking to separate product design from issuance while ensuring that every layer of the stack—custody, trading, lending, and advisory—operates under licensed oversight. The recalibration aligns with the idea that compliant structure can coexist with innovative financial services in the crypto space, provided clear disclosures, robust risk controls, and rigorous oversight are in place. While this does not guarantee a risk-free experience, it offers a pathway for legitimate participation in crypto lending that respects the nuanced regulatory landscape and the practical realities of retail investors seeking access to new financial instruments.

As the US regulatory conversation evolves, Nexo’s rehabilitation of its business model may serve as a blueprint for other firms seeking to re-enter through compliant channels rather than direct issuance of high-yield products. The ultimate test will be whether the heightened governance, partner alignment, and custody standards prove resilient to evolving rules and enforcement priorities. For users, the key takeaway remains vigilance: even within a compliant wrapper, understanding who the counterparty is, how assets are held, and how yields are generated remains essential as the market navigates a new era of governance and transparency in crypto finance.