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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

OCC Reiterates Full Scope of Crypto Custody Authority of Banks It Regulates

On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued Interpretative Letter 1184 (“IL 1184”) confirming that national banks and federal savings associations may provide cryptocurrency custody...more

SEC Division of Trading and Markets Releases FAQs on Crypto Asset Activities and Distributed Ledger Technology; 2019 Joint Staff...

On May 15, 2025, the staff of the Securities and Exchange Commission (“SEC”) Division of Trading and Markets (the “Staff”) published responses to certain frequently asked questions (“FAQs”) relating to crypto asset activities...more

SEC Crypto Task Force Holds Roundtable on Tokenization

On May 12, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore an appropriate regulatory framework for tokenized securities. In the keynote address, Chair Paul Atkins, stated...more

SEC Commissioner Peirce remarks on the Regulation of Tokenized Securities

On May 8, 2025, the Securities and Exchange Commission (“SEC”) held the 31st International Institute for Securities Market Growth and Development. Commissioner Peirce used this opportunity to discuss an approach to regulating...more

Credibly Challenged Podcast: Interview with Ross Delston, Financial Crime Compliance Expert and Former FDIC Attorney

Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more

SEC Crypto Task Force Holds Roundtable on Crypto Custody

On March 25, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore regulatory considerations surrounding custody of crypto assets through broker-dealers and other financial...more

Refresher: EU Capital Requirements Directive 6 (“CRD6”) – What Cross-Border Financial Institutions Need to Know

Many US and other non-EU financial institutions which lend or undertake trade finance business on a cross border basis into Europe do so in reliance upon exemptions under local law.  These exemptions typically permit these...more

IRS-CI Announces a New Initiative to Enhance BSA Information-Sharing with Financial Institutions

On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more

OCC Withdraws Climate Risk Management Principles

On March 31, 2025, the Office of the Comptroller of the Currency withdrew its participation in the interagency principles for climate-related financial risk management for large financial institutions (the “Climate...more

Next Steps for Companies that Filed CTA Reports

Millions of reporting companies breathed a sigh of relief on March 21, 2025, when the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempted all domestic entities from...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

End of the Road: FinCEN Adopts Interim Final Rule Virtually Eliminating CTA Filing Requirements

On March 21, 2025, the US Financial Crimes Enforcement Network (“FinCEN”) issued an interim final rule (the “IFR”) that exempts all domestic entities from beneficial ownership information reporting requirements under the...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

Whiplash: FinCEN Reverses Course, Delays CTA Enforcement Once Again

On February 27, 2025, the US Financial Crimes Enforcement Network (FinCEN) announced that it will not issue fines or penalties or take any other enforcement actions against companies that fail to comply with the March 21,...more

The Time Has Come: Court Reinstates CTA Filing Requirements, FinCEN Sets New Deadline For Compliance

AT A GLANCE - On February 17, 2025, the US District Court for the Eastern District of Texas stayed its January 7 order, enjoining enforcement of the Corporate Transparency Act and suspending the effectiveness of the...more

What to Expect in Banking In 2025

Since President Donald Trump took office last month, his actions have marked a significant shift in federal policy, paving the way for the creation of a new regulatory framework impacting banks, financial services, and the...more

FinCEN Confirms Suspension of Corporate Transparency Act

FinCEN has confirmed that, since December 7, 2024, reporting companies have not been, and will continue to not be, required to file beneficial ownership reports for as long as an injunction of the CTA remains in effect....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

Not Quite Yet: Supreme Court Stays CTA Injunction, But Filing Requirements Remain Suspended

AT A GLANCE - The US Supreme Court has stayed the injunction against the Corporate Transparency Act (CTA), but the requirement for companies to file beneficial ownership information remains suspended, creating ongoing...more

Federal Reserve and FDIC Withdraw From the Network for Greening the Financial System

AT A GLANCE - The Federal Reserve and FDIC have withdrawn from the Network for Greening the Financial System due to concerns that its activities exceeded the Federal Reserve's and the FDIC's statutory mandates—and amid...more

Interview with Steve Gandy, Securitization Innovator

Matt Bisanz interviews Steve Gandy, formerly with Santander, about his long career designing innovative securitization structures around the globe....more

How Regulation W Affects Subscription Credit Facilities

EXECUTIVE SUMMARY - Section 23A of the Federal Reserve Act and its implementing regulation, Regulation W, impose restrictions on banks concerning “covered transactions” with their affiliates. With the increasing...more

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