Weekly Blockchain Blog – September 2025 #4

BakerHostetler
Contact

BakerHostetler

New Stablecoins Launch in Europe, U.S. Credit Card Offers Bitcoin Rewards

By Robert A. Musiala Jr.

Cryptocurrency exchange Bullish recently published a press release announcing that its European affiliate, Bullish Europe, will be the first exchange to offer USDCV, the U.S. dollar-backed stablecoin issued by one of Europe’s largest banks. According to the press release, Bullish Europe began offering the bank’s euro-based stablecoin, EURCV, in early June.

In related news, nine major European banks recently announced that they “have joined forces to launch a MiCAR-compliant euro-denominated stablecoin.” According to a press release, “The stablecoin will be regulated by the EU's Markets in Crypto-Assets Regulation (MiCAR) and is expected to be first issued in the second half of 2026.” According to the press release, the banks’ “stablecoin consortium … has formed a new company in the Netherlands, aiming to be licensed and supervised by the Dutch Central Bank as an e-money institution.” The press release notes that “The consortium is open to additional banks joining.”

In more stablecoin news, a recent blog post by LayerZero, a blockchain infrastructure provider, announced that the PYUSD stablecoin “will now be available through Stargate Hydra as a permissionless token, PYUSD0.” According to the blog post, PYUSD0 “extends” PYUSD “from its native deployments on Arbitrum, Ethereum, Solana and Stellar, bringing the stablecoin to Abstract, Aptos, Avalanche, Ink, Sei, Stable, and Tron – with more to come – while existing permissionless versions on Berachain (BYUSD) and Flow (USDF) will upgrade to PYUSD0.” The blog post further notes that “whether someone holds PYUSD or PYUSD0, it is one unified … stablecoin: fully fungible and interoperable across blockchains.”

In a final notable development, Fold, “the first publicly traded bitcoin financial services company,” recently announced a partnership with two major U.S. fintech and financial services companies to launch the Fold Bitcoin Credit Card, “a bitcoin-only rewards product designed to turn everyday spending into a direct path to bitcoin ownership.” According to a press release, “The card enables users to accumulate bitcoin with every purchase, offering a simple and consistent way to build long-term wealth.”

For more information, please refer to the following links:

Bank Industry Groups Provide Crypto Custody Recommendations to SEC

By Robert A. Musiala Jr.

A group of U.S. banking industry associations recently submitted a letter with joint recommendations to the U.S. Securities and Exchange Commission (SEC) seeking to “strengthen crypto custody requirements to protect customers and the financial system.” According to the letter, “Custodian banks have achieved the highest level of custody by adhering to three core principles: (1) segregation of client assets, (2) separation of custody from other financial activities, and (3) proper control over assets.” The letter argues that “These principles must be adhered to regardless of the asset class, underlying technology or custody provider to ensure the proper protection of client assets.” The letter goes on to make the following two key recommendations:

  1. The SEC must maintain rigorous standards of investor protection by ensuring that, to the extent that the definition of “qualified custodian” is expanded to allow new types of entities to custody crypto assets, any entity acting as a “qualified custodian” for crypto assets is subject to the same regulatory obligations and oversight that banks and other qualified custodians currently meet.
  • The SEC must not permit investment advisers to “self-custody” their clients’ crypto assets without requiring compliance with the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”) and related rules pertaining to the custody of securities, since this would expose investors to conflicts of interest and heightened risk of loss.

For more information, please refer to the following links:

CFTC Launches Initiative on Tokenized Collateral and Stablecoins

By Jonathan Cardenas

The U.S. Commodity Futures Trading Commission (CFTC) Acting Chairman Caroline D. Pham recently announced that the CFTC will launch an initiative focused on the use of tokenized collateral and stablecoins in derivatives markets. According to a CFTC press release, the initiative builds upon the CFTC’s Crypto CEO Forum of February 2025 and forms part of the CFTC’s Crypto Sprint initiative, which is designed to implement the recommendations of the President’s Working Group on Digital Asset Markets Report of July 30, 2025 (PWG Report). The PWG Report directs the CFTC to use its rulemaking, interpretative, and exemptive authority under the Commodity Exchange Act to “provide guidance on the adoption of tokenized non-cash collateral as regulatory margin to implement the CFTC’s GMAC DAMS recommendation.” As part of its initiative, the CFTC has invited interested stakeholders to submit feedback by October 20, 2025, on various subject areas related to the use of tokenized collateral and stablecoins in derivatives markets including, but not limited to, the CFTC’s GMAC 2024 recommendation, potential digital asset markets pilot programs, and amendments to CFTC regulations in connection with the PWG Report’s recommendations.

For more information, please refer to the following links:

NYDFS Issues Guidance to Banking Institutions on Use of Blockchain Analytics

By Amos Kim

On September 17, the New York State Department of Financial Services (NYDFS) announced new guidance “on the use of blockchain analytics tools for banking institutions contemplating or already conducting virtual currency-related activities.” According to the announcement, the guidance is intended to clarify compliance expectations and encourage the use of technology-driven control measures to mitigate risks. The announcement states that “New York State-regulated banking organizations are expected to consider incorporating blockchain analytics as an additional risk-management tool.” The guidance provides the following non-exhaustive list of example use cases for applying blockchain analytics tools within a banking institution's compliance program :

  • Screening wallets of customers who have disclosed or exhibited crypto-related transactions, to assess risk exposure;
  • Verifying the source of incoming funds originating from virtual asset service providers (“VASPs”);
  • Monitoring the crypto ecosystem holistically, to assess customer (e.g., VASP) exposure to money laundering, sanctions violations, or other predicate crimes;
  • Identifying and gauging the risk of third parties (e.g., VASP counterparties) with which a customer has engaged;
  • Evaluating expected versus actual activity (e.g., dollar thresholds) of customers engaging in virtual currency activity;
  • Utilizing intelligence gained from holistic monitoring to further develop the Covered Institution’s risk assessments and risk appetite;
  • Weighing the risks associated with a virtual currency product or service to be offered.

For more information, please refer to the following links:

U.S. Stock Exchange Publishes Paper on Crypto Wash Trading

By Keith R. Murphy

A major U.S. stock exchange recently published a white paper entitled “Wash Trading in Crypto Markets: What Financial Institutions Need to Know.” According to the white paper, the deceptive practice of wash trading is one of the most persistent threats to crypto market integrity. The white paper highlights global efforts to combat the practice, including the CLARITY Act in the United States, the CSA in Canada, as well as related efforts in the European Union, Asia, the Middle East, and United Kingdom. Among other points, the white paper argues that wash trading is not just a compliance issue, rather it rises to the level of a systemic threat, for which financial institutions must implement surveillance controls, among other efforts. It also highlights recent enforcement actions targeting market manipulation in cryptocurrency, analyzes the mechanics and motivations for wash trading in crypto assets and provides an overview of detection and prevention practices.

For more information, please refer to the following links:

U.S. and Canada Bring Crypto Enforcement Actions, DeFi Protocol Hacked

By Robert A. Musiala Jr.

The U.S. Department of Justice (DOJ) recently announced that the “Chief Executive Officer of a multi-level marketing and bitcoin trading firm pled guilty … to wire fraud and money laundering for operating a Ponzi scheme that defrauded over 90,000 investors worldwide.” According to a press release, the defendant represented to investors that he was engaged in bitcoin trading and promised daily returns of 0.5 to 3%, but in fact the defendant was “paying the investors back with their own money or with funds received from other investors.” The press release notes that the defendant solicited more than $201 million in the scheme, including at least 8,198 bitcoin worth $171,498,528, and investors suffered losses totaling at least $62,692,007.

In another enforcement action, the Royal Canadian Mounted Police (RCMP) recently announced what has been reported as its largest cryptocurrency seizure to date in which the RCMP took control of approximately $40 million in crypto from a “non-KYC exchange,” TradeOgre. The incident is also reportedly the first time the RCMP has dismantled a crypto exchange.

In a final notable item, decentralized finance (DeFi) protocol Yala recently published details of the events resulting in the recent $7.6 million hack of its platform. According to the blog post, “A hacker abused temporary deployment keys during authorized bridge deployment, set up an unauthorized cross-chain bridge, and extracted 7.64M USDC (~1,636 ETH)” from the Yala protocol. The blog post further noted that “No protocol vulnerability was exploited, and no Bitcoin reserves were compromised.”

For more information, please refer to the following links:

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© BakerHostetler

Written by:

BakerHostetler
Contact
more
less

What do you want from legal thought leadership?

Please take our short survey – your perspective helps to shape how firms create relevant, useful content that addresses your needs:

BakerHostetler on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide