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On May 19, 2025, the International Organization of Securities Commissions (“IOSCO”) published its Final Reports on Finfluencers, Online Imitative Trading Practices and Digital Engagement Practices (the “Reports”), as part of...more
The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. On April 25, the Federal Reserve Board...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
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
On April 21, 2025, the Commodity Futures Trading Commission (CFTC) Divisions of Market Oversight, Clearing and Risk, and Market Participants issued two Requests for Comment (RFCs) on 24/7 trading and clearing of derivatives...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
On May 7, 2025, the Office of the Comptroller of the Currency (“OCC”) issued a follow up to its July 2020 Interpretative Letter 1170, which allowed national banks to provide cryptocurrency custody services to their customers....more
After years of regulatory uncertainty, the Trump administration has signaled a new approach to digital assets, including by establishing a working group focused on digital assets and nominating crypto-friendly chairs to the...more
The Financial Stability Board (FSB) has published a letter, along with a press release and webpage, from its Chair, Klaas Knot, to G20 finance ministers and central bank governors ahead of their meeting on 23-24 April. The...more
Well-drafted and enforceable terms of use are an essential risk management tool for any business, particularly e-commerce sellers and online service providers. Despite their importance, however, terms of use are often...more
The OCC has removed “reputational risk” from its handbooks and guidance and the FDIC is moving to do the same. ...more
On April 21, 2025, Commodity Futures Trading Commission (“CFTC”) staff issued two Requests for Comment (“RFCs”) aimed at gathering public input on emerging areas of interest in the derivatives markets....more
The Cayman Islands Government has taken a significant step in the regulation of virtual asset service providers (VASPs) with the commencement of the licensing regime under the Virtual Asset (Service Providers) Act (as...more
In April 2025, Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill announced that the FDIC is focused on four key policy areas: de novo bank formation, digital assets and blockchain activities, resolution...more
A recent court case has unveiled a new level of sophistication in attacks targeting high-net-worth cryptocurrency holders. In a meticulously orchestrated scheme, hackers managed to steal more than $40 million in bitcoin from...more
The Guidance provides the Division’s views regarding certain disclosure requirements under Regulation S-K, specifically with respect to disclosures contained within Form S-1 (registration statements), Form 10-K (reporting...more
On April 10, 2025, the SEC’s Division of Corporation Finance issued a staff statement (the “Statement”) titled “Offerings and Registrations of Securities in the Crypto Asset Markets.” This development underscores the...more
On April 4, US Securities and Exchange Commission (SEC) Commissioner Caroline A. Crenshaw, the sole Democrat serving as a Commissioner, issued a statement critiquing the Division of Corporation Finance’s analysis in its...more
On April 4, 2025, the Division of Corporation Finance (the “Division”) of the U.S. Securities and Exchange Commission (the “Commission”) published a statement (the “Statement”) outlining its position on stablecoins, a...more
New Bitcoin Strategic Reserve: On March 7, 2025, the White House hosted a Digital Assets Summit to celebrate the creation of a Bitcoin Strategic Reserve and a Digital Assets Stockpile by an Executive Order titled,...more
As in-game economies evolve, the complexity surrounding virtual goods and services, content creation, and payment structures deepens. As part of this ongoing series on in-game economies, this installment explores issues...more
Friday, March 27, 2025, the US Commodity Futures Trading Commission (CFTC) formally withdrew two crypto-related staff advisories, Staff Advisory No. 18-14 (advisory with respect to virtual currency derivative product...more
On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes...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