News & Analysis as of

BSA/AML Digital Assets

Orrick, Herrington & Sutcliffe LLP

Fed’s Barr highlights gaps in GENIUS Act for regulators to bridge

On October 16, Fed Governor Michael Barr spoke on the rapid pace of payments innovation, highlighting both the opportunities and risks presented by technologies such as stablecoins, AI, and real-time payments. ...more

Loeb & Loeb LLP

OCC Grants Conditional Approval to First Full-Service Crypto Bank

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Marking a significant milestone in the acceptance of cryptocurrency into the world of traditional finance, the Office of the Comptroller of the Currency (OCC) has granted conditional approval for a national bank charter to...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – October 2025 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Davis Wright Tremaine LLP

Wolfsberg Report Casts Light on Path Forward for Crypto Risk Management

New analysis provides insights into managing AML risks for digital asset entities - Detailed recommendation for modern risk management design...more

Haynes Boone

Financial Regulatory Roundup October 2025

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We’re pleased to share the October edition of our Financial Regulatory Roundup Newsletter, highlighting key developments shaping the financial regulatory landscape. In the latest issue we discuss: - NYDFS Issues Two...more

Orrick, Herrington & Sutcliffe LLP

Treasury extends comment period on GENIUS Act notice to November

On October 1, the Treasury published a notice in the Federal Register that it will extend the comment period for its advance notice of proposed rulemaking implementing the GENIUS Act by 15 days, to November 4. The extension...more

Loeb & Loeb LLP

GENIUS Act: Payment Stablecoins Coming to a Retailer Near You (Maybe)

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The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) (S. 1582) establishes the first U.S. framework specifically regulating “payment stablecoins,” and sets forth regulatory and licensing...more

Orrick, Herrington & Sutcliffe LLP

Treasury publishes notice to industry on implementing GENIUS Act

On September 18, the Treasury published an advance notice of proposed rulemaking in the Federal Register to solicit comments on the implementation of the GENIUS Act, which provides a comprehensive framework for regulating...more

Troutman Pepper Locke

New York Issues Guidance on Blockchain Analytics for Banking Institutions

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On September 17, the New York State Department of Financial Services (DFS) issued new guidance on the use of blockchain analytics tools. This new guidance builds upon the blockchain guidance issued by DFS in 2022, and applies...more

Davis Wright Tremaine LLP

Treasury Issues Advanced Notice of Proposed Rulemaking on GENIUS Act Implementation

Now that the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act has now been enacted into law, the focus moves to the agency rulemaking that will implement it. On September 18, 2025, the U.S....more

Jones Day

Senators Release Updated Discussion Draft of the "Responsible Financial Innovation Act of 2025"

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On September 5, 2025, Senators Tim Scott (R-SC), Cynthia Lummis (R-WY), Bill Hagerty (R-TN), and Bernie Moreno (R-OH) released an updated discussion draft of the "Responsible Financial Innovation Act of 2025" ("RFIA"), which...more

Orrick, Herrington & Sutcliffe LLP

FinCEN director signals AML reporting reform and highlights priorities in congressional testimony

On September 9, FinCEN Director Andrea Gacki testified before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions, regarding FinCEN’s ongoing efforts to...more

Sheppard Mullin Richter & Hampton LLP

OCC Terminates 2022 Consent Order Against National Bank

On August 18, the OCC terminated its 2022 consent order against a national bank. The order was issued under the Bank Secrecy Act and related anti-money laundering regulations, and required the bank to implement corrective...more

Orrick, Herrington & Sutcliffe LLP

OCC terminates 2022 consent order against federally chartered digital asset bank

On August 18, the OCC terminated its 2022 consent order against a federally chartered bank specializing in digital assets. The OCC, in support of its decision, cited the safety and soundness of the bank and its compliance...more

Ballard Spahr LLP

Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed...

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On August 6th, 2025, following a four-week trial, a jury found Roman Storm, the founder of a crypto mixing service called Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. The jury was...more

Troutman Pepper Locke

Senate Banking Committee Releases Draft Digital Asset Market Structure Bill and Request for Information

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Since the House passed the CLARITY Act on July 17, the U.S. Senate Banking Committee, which has oversight of the Securities and Exchange Commission (SEC), has been busy working on its own version of the U.S. crypto regulatory...more

Womble Bond Dickinson

Update on 2025 U.S. Stablecoin Legislation

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In July 2025, the U.S. Congress advanced a landmark package of legislative measures aimed at establishing a comprehensive federal framework for the regulation of cryptocurrencies and stablecoins. ...more

Eversheds Sutherland (US) LLP

The GENIUS Act: US law for payment stablecoins

The first piece of major US federal legislation in the global digital assets space was signed into law on July 18, 2025, by President Trump.1 Declared by President Trump as positioning the United States to be the “crypto...more

BCLP

The GENIUS Act Ushers in a New Era for Stablecoin Regulation

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On July 17, 2025, Congress passed the Guiding and Establishing National Innovation for U.S Stablecoins Act (“GENIUS Act” or “Act”) – a landmark piece of legislation that received bipartisan support and was signed into law by...more

Alston & Bird

GENIUS Act Establishes Federal Regulatory Oversight of Global Stablecoin Industry

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Our Privacy, Cyber & Data Strategy and White Collar, Government & Internal Investigations Teams examine how the GENIUS Act’s framework for stablecoin issuers will impact the cryptocurrency sector....more

Latham & Watkins LLP

Banking Agencies Issue Joint Statement on Risk-Management Considerations for Cryptoasset Safekeeping

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Banking organizations safekeeping digital assets for customers must do so in a safe and sound manner and in compliance with applicable laws and regulations....more

Troutman Pepper Locke

The GENIUS Act: What Is It and What’s Next?

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On June 17, the U.S. Senate voted 68-30 to pass S.1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the Act). This represents a landmark effort by the U.S. Congress to...more

Carlton Fields

Crypto Business Compliance: U.S. Licensing and Regulations

Carlton Fields on

The crypto industry is evolving rapidly, and regulatory enforcement is keeping pace. Businesses engaged in crypto transactions, custody, lending, trading, or payments must navigate know your customer (KYC) and anti-money...more

BakerHostetler

Weekly Blockchain Blog - August 2024 #3

BakerHostetler on

Crypto Firms Announce New Products in Payments, Investments, Custody - A major U.S. digital asset management company recently announced the creation and public launch of its MakerDAO Trust, which “offers investors the...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

Ballard Spahr LLP on

The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

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