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Anti-Money Laundering Aspects of the GENIUS Act

On March 13, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, which aims to establish a regulatory framework for payment stablecoins, passed the United States Committee on Banking,...more

Recent Developments Raise Significant Questions about the Future of Regulation and Enforcement of Cryptocurrency

Recent developments in the world of crypto have come at a rapid pace to open 2025 not only signaling but, in some instances, explicitly declaring the Trump Administration’s intent to significantly relax or eliminate...more

NYDFS to Virtual Currency Asset Custodians: Segregate, Don’t Integrate

On January 23, 2023, the New York Department of Financial Services (NYDFS) published a short but important notice to virtual currency asset custodians containing guidance on custodial structures in order to protect customers...more

A Taxonomy of Digital Assets: Is It a Security, Commodity, Banking Product, or Something Else?

Summary - The jurisdictional lines between the different types of digital assets remain unclear. As Congress weighs separate bills seeking to establish a clear and workable regulatory framework, market participants are...more

New Bill Proposes CFTC Should Regulate Spot Digital Currency Markets

Summary - U.S. Senators Debbie Stabenow (D-Mich.) and John Boozman (R-Ark.) of the Senate Agricultural Committee have formally proposed a new bill to regulate the digital asset market. The Digital Commodities Consumer...more

Federal Regulation for Digital Assets Could Be Coming Soon

Summary - Significant federal regulation may be coming soon for cryptocurrencies, blockchain, and non-fungible tokens (NFTs). On June 6, 2022, U.S. Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced...more

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