President Trump’s crypto executive order (the Crypto Executive Order) was a first step in the Trump Administration’s articulation of a policy on promoting the lawful use of blockchain technology. It remains to be seen whether...more
1/31/2025
/ Anti-Money Laundering ,
CFTC ,
Compliance ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more
1/13/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Compliance ,
Cryptocurrency ,
CSBS ,
Digital Assets ,
Digital Currency ,
FinCEN ,
FinTech ,
Money Transmitter ,
Regulatory Agenda ,
Regulatory Requirements ,
State and Local Government
This week, Congress wrapped up its final session of the 118th Congress. Crypto legislation in the next Congress will likely be based on the bills introduced in the prior session, but we might see some significant changes to...more
This week, Congress wrapped up its final session of the 118th Congress. Crypto legislation in the next Congress will likely be based on the bills introduced in the prior session, but we might see some significant changes to...more
A significant headwind for companies in the digital asset space is that they have reportedly struggled to secure and maintain relationships with banks, in what is now called “Choke Point 2.0.” With the incoming Trump...more
12/16/2024
/ Cryptocurrency ,
Digital Assets ,
FDIC ,
Federal Reserve ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinTech ,
OCC ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Staff Accounting Bulletin ,
U.S. Treasury
In this update, we focus on the potential changes in the executive branch and on the congressional committees that have jurisdiction over cryptocurrency. As the transition unfolds, much attention is on who will stay from the...more
11/25/2024
/ Anti-Money Laundering ,
Board of Governors ,
Choke Point ,
Cryptocurrency ,
Digital Assets ,
Economic Action Plan ,
Executive Branch ,
FDIC ,
Federal Reserve ,
Financial Services Committee ,
Financial Services Industry ,
FinTech ,
GAO ,
NDAA ,
OCC ,
Secretary of the Treasury ,
Securities and Exchange Commission (SEC) ,
Trump Administration
On September 17, 2024, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) issued final “statements of policy” for transactions subject to the Bank Merger Act (“BMA”)....more
On May 16, 2024, the United States Supreme Court, in a 7-2 opinion authored by Justice Clarence Thomas, upheld the constitutionality of the funding mechanism of the Consumer Financial Protection Bureau (“CFPB” or “Bureau”)....more
5/21/2024
/ Appropriation ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Financial Protection Bureau v Community Financial Services Association of America Ltd ,
Federal Funding ,
Federal Reserve ,
Financial Services Industry ,
Regulatory Agencies ,
Regulatory Authority ,
SCOTUS
The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) recently issued a proposed rule that would prohibit financial institutions from charging nonsufficient funds (“NSF”) fees on instantaneously declined transactions....more
The U.S. Securities and Exchange Commission (“SEC”) recently proposed amendments to its so-called custody rule[1] under the Investment Advisers Act of 1940 (“Advisers Act”). The Proposed Rule seeks to expand the range of...more