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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 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

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

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

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

US Senators Introduce Comprehensive Stablecoin Bill

The bipartisan bill seeks to foster innovation and promote US dollar dominance while protecting consumers and mitigating illicit finance risks. On April 17, 2024, US Senators Cynthia Lummis from the Senate Banking...more

FinCEN Seeks Enhanced Oversight of Crypto Mixing

A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors. On October 19, 2023, the US Department of the Treasury’s Financial Crimes...more

California Adopts Digital Financial Assets Law

Licensees, exchanges, and other market participants should prepare to comply with the listing, disclosure, capital, and other requirements that the new law imposes. On October 13, 2023, California Governor Gavin Newsom...more

NYDFS Proposes Updated Guidance on Crypto Listing

The Proposed Guidance would require enhanced criteria for coin-listing and delisting procedures for New York-licensed virtual currency entities. On September 18, 2023, the New York Department of Financial Services (DFS)...more

SEC Continues Enforcing Against NFT Projects

In its second action involving NFTs, the SEC targets an offering tied to fundraising and promises of future value. On September 13, 2023, the Securities and Exchange Commission (SEC) issued a cease-and-desist order (the...more

DeFi Crypto Platform Not Liable for Scam Tokens

A federal court’s dismissal of claims against a decentralized cryptocurrency platform and its investors for the actions of scam token issuers is a case of first impression with wider significance. On August 29, 2023, the...more

SEC v. Ripple: A Tale of Two Token Transaction Types

A bifurcated decision in a highly anticipated digital assets enforcement action may not provide the clarity that market participants want or need. On July 13, 2023, Judge Analisa Torres of the US District Court for the...more

What’s Next for DAOs in the Wake of the Ooki Decision?

The viability of DAO structures draws attention after a judge declares that a decentralized autonomous organization is a “person” under the law. On June 8, 2023, the US District Court for the Northern District of...more

New York Attorney General Proposes Stringent Crypto Bill

The CRPTO Act is intended to increase transparency and consumer protections, and reduce conflicts of interest, through heightened disclosures and penalties. On May 5, 2023, New York Attorney General (NYAG) Letitia James...more

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