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OCC Proposes Comprehensive Rulemaking to Implement the GENIUS Act

On February 25, 2026, the Office of the Comptroller of the Currency (“OCC”) issued a Notice of Proposed Rulemaking (the “Proposal”) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the...more

Delaware Law Alert: New Perspectives on Earnouts

The Delaware Supreme Court has clarified important aspects of Delaware law in the context of an earnout dispute that the Delaware Chancery Court decided in favor of the sellers in 2024. We analyzed the Chancery Court’s...more

Virtual Currency Exchange Pleads Guilty to Criminal Charges Related to Anti-Money Laundering Violations and Pays Multi-Million...

On December 9, 2025, the US Department of Justice (“DOJ”) announced a guilty plea by a peer-to-peer convertible virtual currency exchange (the “CVC Exchange”) for conspiring to: (i) violate the Travel Act; (ii) operate an...more

FDIC Proposes GENIUS Act Application Process for IDI Subsidiary Stablecoin Issuers

On December 16, 2025, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors issued a proposal (the “NPRM”) to implement the application-related provisions of the Guiding and Establishing National Innovation...more

Treasury Takes Initial Steps Towards GENIUS Act Rulemaking

In July, Congress passed, and President Donald Trump signed, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”). The GENIUS Act was a watershed moment in the history of...more

Illinois Adopts Regulatory Regime for Digital Assets

On August 18, 2025, Illinois enacted Senate Bill 1797, the Digital Assets and Consumer Protection Act (the “Act”), establishing a regulatory framework designed to enhance customer protections for digital asset activities and...more

The Tornado Cash Trial’s Mixed Verdict: Implications for Developer Liability

On August 6, 2025, following a four-week trial, a jury in the Southern District of New York delivered a mixed verdict in the criminal case against Tornado Cash co-founder Roman Storm. The jury convicted Storm of conspiring to...more

President Trump Signs Debanking Executive Order

On August 7, 2025, President Donald Trump issued an Executive Order entitled “Guaranteeing Fair Banking for All Americans” (the “Order”). The Order announces the Administration’s plan to address the exclusion of certain...more

Key House Committee Chairs Release Draft Bill on Digital Asset Market Structure: Bill Would Establish CFTC/SEC Regulatory...

On May 5, 2025, the Republican committee chairs in the US House of Representatives with jurisdiction over digital asset legislation released a digital asset market structure discussion draft bill (the “Discussion Draft”). The...more

FDIC Streamlines Process for Cryptocurrency Activities by Banks It Regulates and Speculates on Additional Permissible Activities

On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more

Credibly Challenged Podcast: Interview With Mark Quandahl, Former Director of the Nebraska Department of Banking and Finance

Joe Castelluccio and Matt Bisanz interview Mark Quandahl, the former Director of the Nebraska Department of Banking and Finance. They discuss his role in the implementation of the Nebraska Financial Innovation Act, including...more

The SEC’s Staff of the Division of Corporation Finance Clarifies Its Views on Crypto Mining

On March 20, 2025, the SEC’s Staff of the Division of Corporation Finance (the “Division”) issued a statement providing its views that crypto mining activities (as defined in its statement) do not involve the offer and sale...more

Congress Moves Forward on Stablecoin Legislation: The US Senate Banking Committee Approves the GENIUS Act

On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more

OCC Streamlines Process for Cryptocurrency Activities by Banks It Regulates

On March 7, 2025, the Office of the Comptroller of the Currency (OCC) issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (“IL 1183”). This guidance is the...more

President Trump’s First Week in Office is a Momentous One for Digital Assets: An Executive Order, Repeal of SAB 121 and a Clear...

WHAT THIS MEANS FOR BANKS, FINANCIAL SERVICES AND THE DIGITAL ASSETS SECTOR - Just four days after his inauguration, President Donald Trump has initiated a fundamental shift in federal policy on digital assets with a...more

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

The Race to Develop Crypto Products is Now a Sprint, But Hurdles Remain: State Law Considerations in the New Crypto World Order

The outcome of the US presidential election this month, coupled with the prospect of a crypto-friendly president and Congress, have unleashed a torrent of enthusiasm that has been building throughout the crypto sector this...more

CFPB Finalizes Long-Awaited Rule to Accelerate Open Banking Development; Immediately Sued

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more

The US’s First ‘Crypto’ Election? Yes … But It Is More Complicated Than That

The 2024 presidential election in the United States is, without question, the country's first ‘crypto’ election. ...more

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more

House Passes Digital Asset Market Structure Legislation: Financial Innovation and Technology for the 21st Century Act (FIT21)

On May 22, 2024, the US House of Representatives passed H.R. 4763, the Financial Innovation and Technology for the 21st Century Act (FIT21), which would amend existing securities and commodity regulatory statutes to...more

SEC Approves Listings of Spot Ether ETFs: Waiting is the Hardest Part

On May 23, 2024, the Staff of the Securities and Exchange Commission’s Division of Trading and Markets (the “SEC”) approved rule changes (so-called “19b-4 forms”) permitting the listing and trading of eight separate...more

Investing in or Acquiring a Digital Assets Business? Watch Where You Step – Maximizing Value and Managing Risk in Digital Assets...

As applications and use cases for digital assets and their blockchain infrastructure grow and become more sophisticated, investments and valuations for businesses in these areas have grown as well. The growing number of...more

Crypto Asset Management: Expansion Roadmap for Managers and Investors (Part 1)

Asset managers who invest in crypto assets are expanding their footprint as managers of capital for investors. Investors are increasingly seeking out asset managers that have expertise in crypto assets. Likewise, crypto asset...more

Three-Body Problem: Challenges and Considerations for a First-of-Its-Kind Triple-Token Merger

Token holders for three different decentralized protocols have recently proposed a first-of-its-kind merger of tokens that would create an “Artificial Superintelligence Alliance” (“Alliance”) with a single token and a new,...more

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