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The Staff’s most recent actions continue to set the stage for notice-and-comment rulemaking long-awaited by the digital asset industry....more
On May 15, the SEC staff provided guidance to SEC-registered broker-dealers and transfer agents on how they can custody and recordkeep digital assets. According to the guidance, non-securities are not subject to the...more
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
Situation Overview: The SEC’s Crypto Task Force is advancing its exploration of regulatory frameworks for digital asset custody. What: The SEC hosted its third roundtable, Know Your Custodian, focusing on challenges and...more
The federal banking agencies continue to open the channels for regulated entities to engage in digital asset activities. On May 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter...more
Regulator sets out its expectations for banks looking to provide digital asset custody services, and sell and distribute tokenised products. On 20 February 2024, the Hong Kong Monetary Authority (HKMA) published two...more
The bipartisan bill would provide a federal safe harbor for non-custodial blockchain service providers from state money transmission and digital asset licensing laws. On March 23, 2023, US House of Representatives...more
Institutional investors, corporations, exchanges, individuals, and crypto miners all have strong demand for crypto custody services, as provided by special market participants. These services intend to safeguard customers’...more
Christmas came early for many in the digital asset community by way of a statement from the U.S. Securities and Exchange Commission (“SEC” or “Commission”) on December 23, 2020 that grants relief in the area of broker...more
Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more
On Wednesday, July 22, 2020, Acting Comptroller of the Currency Brian Brooks reaffirmed his interest in being seen as an agent of modernization in a letter clarifying the authority of national banks and federal savings...more
On July 22, 2020, the Office of the Comptroller of the Currency (the “OCC”) issued Interpretive Letter No. 1170 (the “Letter”) authorizing national banks and federal savings associations to provide cryptocurrency custody...more
On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter confirming that national banks and federal savings associations (banks) may provide cryptocurrency custody services to...more
Although still actively developing, current UK policy thinking in relation to cryptocurrencies was set out by the UK Cryptoassets Taskforce in its Final Report (the “Taskforce Report”), published in October 2018. The...more
New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more