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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

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

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

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

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

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

WisdomTree Granted New York Limited Purpose Trust Company Charter

As federal regulation remains patchy, firms may want to consider a New York state charter as a potential avenue to expand digital asset offerings in a compliant manner. On March 22, 2024, WisdomTree, Inc., a global asset...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

FASB Adopts Changes to Accounting and Disclosure Standards for Digital Assets

The new standard aims to improve accounting treatment of certain digital assets under GAAP and may pave the way for increased institutional adoption. On September 6, 2023, the Financial Accounting Standards Board (FASB)...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

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...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

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