Focus on Fintech - Q3 2022

Welcome to Wilson Sonsini’s Focus on Fintech newsletter. This quarterly newsletter provides ongoing analysis and commentary on regulatory developments impacting the fintech industry.

The third quarter of 2022 has been a busy one in the fintech space. In this issue of Focus on Fintech, we discuss various regulatory developments related to banking and payments programs, including an update on the anticipated launch of FedNow, regulatory concerns related to “buy now pay later” programs and banking-as-a-service in connection with bank-fintech partnerships, expanded access to the Federal Reserve Bank accounts and services, and the FDIC’s concerns with misleading statements. We also discuss FinCEN’s final regulations on beneficial ownership reporting requirements and their effects, as well as the increased regulatory scrutiny on blockchain and crypto assets by the CFTC, OFAC, the SEC, and the White House. Finally, we wrap up this edition with state-level updates in the digital asset space and an overview of new agency-level departments that have been created to address the unique challenges posed by digital assets.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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