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OCC Affirms Banks Can Engage in Crypto Custody and Execution Activities

The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more

FRB Rescinds Previous Guidance Regarding Crypto Activities in the Banking Sector

FRB eases crypto restrictions on supervised entities in alignment with the new administration’s support for the digital asset industry....more

SEC Staff Clarifies That Certain Dollar-Backed Stablecoins Do Not Implicate the Securities Laws

The Staff noted that a stablecoin generally is not subject to SEC jurisdiction if it is not an investment and used solely for commercial activity....more

SEC Staff Publishes Observations on Crypto Issuer Disclosures

On April 10, 2025, the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance (the Staff) published a Statement on Offerings and Registrations of Securities in the Crypto Asset Markets (the Statement)....more

Federal Banking Agencies Plan to Rescind Community Reinvestment Act Final Rule

In light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more

SEC Staff Clarifies That Crypto Mining Does Not Implicate the Securities Laws

The Staff Statement provides clarity that Proof-of-Work crypto mining does not involve securities, reducing regulatory uncertainty and enforcement risks for miners....more

FDIC Removes Roadblocks to Crypto Activities in the Banking Sector

New FDIC guidance permits crypto activities by supervised institutions without prior approval, emphasizing risk management and compliance with applicable laws and regulations....more

President Trump Issues Executive Order Establishing a Strategic Bitcoin Reserve

An executive order and related legislation centralizes Bitcoin and digital asset holdings across the federal government to optimize oversight and management of crypto as a US reserve asset. On March 6, 2025, President...more

OCC Affirms Regulated Entities Can Engage in Crypto and Stablecoin Activities

In a break from restrictive Biden-era policies, OCC-supervised banks may now engage in crypto without supervisory nonobjection, potentially opening new avenues for innovation....more

SEC Staff Clarifies That Meme Coins Are Not Securities

The Staff stated that most meme coins are not subject to federal securities laws or SEC fraud enforcement; who will oversee meme coins remains an open question. On February 27, 2025, the Securities and Exchange...more

FDIC Conducts Regulatory Review and Purge

Under its new acting chairman appointed by President Trump, the FDIC charges ahead with its new agenda by rolling back key Biden-era regulatory efforts. On March 3, 2025, the Federal Deposit Insurance Corporation (FDIC)...more

Competing Stablecoin Bills Reflect Consensus and Divergence on Key Issues

Stablecoin regulation is a top priority for lawmakers, and three recent proposals reflect differing perspectives on how to achieve regulatory clarity while balancing safety and innovation....more

SEC Withdraws Appeal of Court Decision to Vacate Its Dealer Rules

The SEC’s move is part of a recent shift toward a less enforcement-centric approach that is set to reshape the regulatory framework for digital assets in the US....more

The SEC’s Crypto Task Force Charts a New Course

Commissioner Hester Peirce outlined 10 priorities for the Crypto Task Force, aiming for regulatory clarity while promoting innovation in digital asset markets....more

NY Attorney General Secures $1 Billion-Plus Judgment for Illegal Loans Misrepresented as Merchant Cash Advances

On January 22, 2025, New York Attorney General (NYAG) Letitia James announced a judgment and settlement against cash advance provider Yellowstone Capital, its officers, and two dozen affiliates (Yellowstone) for more than $1...more

FDIC Acting Chairman Charts a Fresh Path Forward for the Agency

The FDIC seeks to stick to its statutory mandate while reducing impediments to fintech, innovation, mergers, bank formation, and efficient supervision....more

President Trump Issues Executive Order on Digital Assets

With its pro-crypto stance and urgent posture, the executive order promises to make the US the “crypto capital of the planet.” On January 23, 2025, President Trump issued a highly anticipated executive order on digital...more

Regulatory Reversals: Political Transitions and the Congressional Review Act

A Republican Congress and the incoming Trump administration may employ the CRA to quickly overturn recent rules that faced heavy criticism from the financial services industry....more

The Tides Are Changing (Again) for US “Fair Access” and “Anti-Debanking” Laws

“Fair access” banking laws, at the epicenter of the debates between ESG and “anti-woke” regulation and federal/state preemption, may see a resurgence under the incoming administration. In recent years, the landscape of...more

CFTC Issues Staff Advisory on the Use of Artificial Intelligence in CFTC-Regulated Markets

As AI use proliferates, the advisory reminds CFTC-regulated entities of their existing obligations and the CFTC’s intention to monitor for ongoing risks. On December 5, 2024, the staff of the Commodity Futures Trading...more

Fifth Circuit Overturns OFAC Sanctions Against Crypto Mixer Tornado Cash

The court ruled OFAC overstepped its authority in sanctioning Tornado Cash, holding that its smart contracts are not “property” under the governing statutes....more

On the Margins: CFTC’s Digital Asset Markets Subcommittee Recommends Expanded Use of Non-Cash Collateral Through Blockchain...

With appropriate safeguards, distributed ledger technology may expand the use of non-cash assets as derivatives collateral, while mitigating certain market infrastructure inefficiencies....more

FINRA Sets Up Shop in the Metaverse

On October 24, 2024, the Office of Financial Innovation (OFI) of the Financial Industry Regulatory Authority, Inc. (FINRA) published “The Metaverse and the Implications for the Securities Industry” (the Report)....more

CFPB Finalizes Open Banking Rule

The rule aims to reduce market concentration by guaranteeing consumer access to personal financial data, but faces strident criticism and immediate legal challenge....more

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