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Senate Advances Stablecoin Bill

On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle....more

Chairman Atkins Outlines SEC’s New Roadmap for Crypto Reform

In a May 12, 2025 Keynote Address before the U.S. Securities and Exchange Commission (“SEC”) Crypto Task Force’s fourth industry roundtable on digital assets, newly-minted Chair Paul Atkins laid out a sweeping vision for...more

OCC Confirms Banks Authority to Offer Crypto Custody and Execution Services

On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC...more

FTC Imposed $9.6 Million Judgement Against Debt Collector for Alleged Threats and Phantom Debt

On April 30, 2025, the FTC filed an amended complaint and final order in the U.S. District Court for the Northern District of Georgia against a debt collection company in connection with allegations that the company engaged...more

Digital Dollars, Not Investments: SEC Staff Weighs in on Stablecoins

On April 4, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued a statement clarifying that reserve-backed U.S. dollar stablecoins are not securities, at least under current law and...more

DOJ Narrows Crypto Enforcement Focus to Fraud and Criminal Conduct

On April 7, in a significant policy shift, the U.S. Department of Justice (DOJ) announced via the release of a memorandum that it will no longer pursue criminal enforcement actions that effectively impose regulatory...more

California DFPI Proposes Digital Asset Licensing Rule

On April 4, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations under the Digital Financial Assets Law (DFAL). The proposal provides clarification on DFAL’s licensing framework...more

FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks

On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...more

Kentucky Enacts New Law Establishing Legal Framework for Blockchain and Digital Assets

On March 24, Kentucky enacted House Bill 701, establishing a statutory framework to support blockchain-based activity and clarifying the treatment of digital assets under state law. The legislation defines key terms, permits...more

Federal Crypto Ownership: Compliance Implications of the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile

Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, federal agencies and market participants may begin to grapple with the operational and compliance...more

CSBS Flags Key Risks in Draft Stablecoin Legislation

On April 1, the Conference of State Bank Supervisors (CSBS) submitted a letter to the House Financial Services Committee expressing concerns with an introduced draft of H.R. 2392—the Stablecoin Transparency and Accountability...more

FDIC Aims to Eliminate Reputational Risk from Supervision

On March 24, acting FDIC Chairman Travis Hill informed Congress that the agency is preparing to eliminate the use of “reputation risk” as a basis for supervisory criticism. In a letter to Rep. Dan Meuser (R-Pa.), Hill...more

From Seizures to Strategy: The U.S. Government’s Move Toward a National Crypto Reserve

Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve, released alongside a White House Briefing, the U.S. government has taken its most formal step yet toward integrating digital assets...more

SEC Creates New Tech-Focused Enforcement Team

On February 20, the SEC announced the creation of its Cyber and Emerging Technologies Unit (CETU) to address misconduct involving new technologies and strengthen protections for retail investors. The CETU replaces the SEC’s...more

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

California DFPI Reaches Settlement with Lender Over Crypto-Backed Loans

On December 23, 2024, the California Department of Financial Protection and Innovation (DFPI) announced a consent order with a lender to resolve its investigation into the company’s crypto-backed lending program, which the...more

SEC Withdraws from Prominent Crypto Enforcement Amid Regulatory Shift

Just over one month into the second Trump Administration, the crypto industry appears poised to notch yet another victory in its longstanding tug-of-war with regulators — perhaps its most significant to date. On February 21,...more

Trump Administration Announces New Picks for the CFPB and OCC

On February 12, the Trump administration announced Jonathan McKernan as the Director of the CFPB and Jonathan Gould as the Comptroller of the Currency. McKernan and Gould will replace Acting Directors Russell Vought and...more

SEC Launches Crypto Task Force Website to Bring Clarity to Crypto Regulation

The U.S. Securities and Exchange Commission (SEC) has launched a ‘Crypto Task Force’ page on its website, outlining the agency’s crypto regulatory agenda under the agency’s new leadership. This initiative follows the exit of...more

CFPB Proposes Interpretive Rule on Emerging Payment Mechanisms Under EFTA

On January 2, 2025, the Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule under the Electronic Fund Transfer Act (EFTA) and Regulation E to clarify how emerging payment systems, such as those used in...more

Riding the Wave: How the Crypto Surge is Influencing Finance

As 2024 concludes, financial markets are witnessing significant shifts, particularly within the world of cryptocurrency. As crypto investors profit, many cash out from more volatile assets, such as Bitcoin, to safer options...more

NFTs and Securities Law Issues Are on the Rise – SEC Analysis Relies on Resale Royalties

Until fall 2023, there were few SEC enforcements or litigations involving securities issues with non-fungible tokens (“NFTs”). This has changed dramatically. In rapid succession last fall, the SEC undertook two enforcements...more

NFT Legal Issues

This year, the SEC has ramped up its enforcement efforts against digital asset marketplaces for selling non-fungible tokens (“NFTs”) (and other digital assets) the agency alleges are securities. In response, some potential...more

Hawk Thua – Sue that Thing! When Will Celebrities Learn the Risks of Launching Crypto Tokens?

Yet another “celebrity” token memecoin project seeking to leverage a “cultural movement” has become the subject of a lawsuit alleging that the tokens were unregistered securities. A group of plaintiffs recently sued over the...more

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

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