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In the short term, firms are likely to face dual authorisation and significant regulatory requirements. On 10 June 2025, the European Banking Authority (EBA) issued a No Action letter on the relationship between the...more
Three Commission Delegated Regulations supplementing Regulation (EU) 2023/1114 (the EU Markets in Crypto Assets Regulation) (MiCAR) have been published in the Official Journal of the European Union, namely: - Commission...more
Published concurrently with Consultation Paper 25/14 (CP 25/14) on the proposals for stablecoin issuance and cryptoasset custody in the UK, Consultation Paper 25/15 (CP 25/15) sets out the UK Financial Conduct Authority’s...more
Following the publication by HM Treasury of the draft legislation establishing a financial services regulatory regime for cryptoassets in the UK, on 28 May 2025 the UK Financial Conduct Authority (FCA) published Consultation...more
The UK Financial Conduct Authority (FCA) has published consultation paper CP25/14 (CP) on stablecoin issuance and cryptoasset custody, accompanied by an updated webpage. This follows the FCA's discussion paper published in...more
The UK Financial Conduct Authority (FCA) has published consultation paper CP25/15 on its proposed prudential regime for cryptoasset firms, also accompanied by an updated webpage. This is intended to be read together with...more
A May 29, 2025, U.S. Securities and Exchange Commission ("SEC") Division of Corporation Finance statement explains that "Covered Crypto Assets"—crypto tokens without any inherent rights to passive income, business enterprise...more
On 15 May 2025, the US Securities and Exchange Commission’s Division of Trading and Markets (Division) released Frequently Asked Questions (FAQs) clarifying how certain broker-dealer and transfer agency rules relate to crypto...more
The UK’s Financial Conduct Authority (FCA) is consulting on draft rules relating to the issuance of stablecoins in the UK and on custody of cryptoassets. What has happened? On 28 May 2025, the FCA published a Consultation...more
On May 7, the OCC clarified permissible activities for national banks and federal savings associations regarding crypto-asset custody and execution services by publishing Interpretive Letter 1184. This letter confirmed...more
The UK Financial Conduct Authority (FCA) has published a discussion paper (DP25/1) on proposals for regulating cryptoasset activities, with a new webpage and press release. The FCA is seeking to develop a safe, competitive...more
The European Banking Authority (EBA) has issued its final report on draft regulatory technical standards (RTS) amending Commission Delegated Regulation (EU) 2018/1108, on the criteria for the appointment of central contact...more
The European Securities and Markets Authority (ESMA) has published its final report on the guidelines on supervisory practices for National Competent Authorities (NCAs) to prevent and detect market abuse under the Market in...more
As previously summarized here, since SEC Commissioner Mark T. Uyeda was named Acting Chairman on January 21, 2025, the SEC has significantly shifted its approach to cryptocurrency regulation and enforcement actions, including...more
The European Commission (EC) has adopted a Delegated Regulation supplementing Regulation (EU) 2023/1114 on markets in cryptoassets (MiCAR), with regard to regulatory technical standards (RTS) specifying the arrangements,...more
The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more
Since December 2024, cryptoassets and related services are regulated in the European Union by the Markets in Crypto-Assets Regulation (MiCA). Although the regulation provides a comprehensive set of rules for issuers of...more
For years, the Securities and Exchange Commission’s invitation to crypto companies sounded simple: “Come in and register.” But there was no map, no guide and no obvious way forward – only uncertainty and risk. That changed on...more
The Federal Reserve has announced multiple decisions to rescind existing requirements for crypto-asset activities. The April 24 announcement included the rescission of a 2022 supervisory letter that required state member...more
Numerous jurisdictions across the globe are developing their own cryptoasset regulatory frameworks—the UK is no exception. Cryptoasset businesses overseas looking to enter the UK market, or to offer services to customers in...more
Three months into the life of the U.S. Securities and Exchange Commission’s Crypto Task Force, the SEC staff has begun taking tangible steps to define its evolving approach to the regulation of digital assets. In a series of...more
This periodic bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets. While the use cases for blockchain...more
On April 8, 2025, Natasha Cazenave, executive director of the European Securities and Markets Authority (ESMA), addressed the European Parliament’s Economic and Monetary Affairs Committee, offering key insights into the...more
As part of an effort to provide greater clarity on the application of the federal securities laws to crypto assets, the SEC’s Division of Corporation Finance has provided its views about the application of certain disclosure...more
On March 28, the FDIC announced new guidance allowing FDIC-supervised institutions to engage in permissible crypto-related activities without prior approval. This update, outlined in FIL-7-2025, rescinded the previous...more