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London Partner Roberta Downey Wired for Disputes: Tech, Infrastructure, and the New Frontier of Risk
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Compliance into the Weeds: Of Wal-Mart, Tariffs and Stakeholder Capitalism
Daily Compliance News: May 21, 2025, The I Want You Back Edition
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 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 This update, outlined in FIL-7-2025, rescinded the previous...more
On whether to recommend Bitcoin and other digital assets for clients, financial advisers are wary about their fiduciary duty to clients, according to a CoinShares survey....more
The Securities and Exchange Commission's (SEC) Division of Corporation Finance issued a significant statement yesterday that certain proof-of-work (PoW) mining activities do not constitute securities offerings under federal...more
The International Organization of Securities Commissions (IOSCO) has published its 2025 Work Program, setting out its ongoing and planned initiatives for 2025. These include: (i) prioritising issues related to non-bank...more
The European Supervisory Authorities (ESAs) have published guidelines on: (i) a common approach for the regulatory classification of crypto-assets under the Markets in Crypto-asset Regulation (MiCAR); and (ii) templates for...more
On March 7, the Office of the Comptroller of the Currency (OCC) issued a significant update regarding the involvement of national banks and federal savings associations in cryptocurrency activities. Interpretive Letter 1183...more
The Wolfsberg Group has published FAQs on defining digital assets. The FAQs propose definitions to be used by financial institutions, policymakers, supervisors and regulators to understand the characteristics of digital...more
On 25 February 2025, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – BaFin) published a consultation paper outlining a circular that addresses the responsibilities of...more
The Ontario Securities Commission (“OSC”) completed a focused compliance review of the know-your-client (“KYC”), account appropriateness assessment and Client Limit (as defined below) practices of crypto asset trading...more
On February 11, the White House nominated Brian Quintenz to replace Caroline Pham as Chairman of the CFTC. He previously worked as the Head of Policy at a venture capital fund that invests in cryptoassets. Quintenz previously...more
Recently, NYDFS published an industry letter to “all virtual currency business entities licensed under 23 NYCRR Part 200 or chartered as limited purpose trust companies under the New York Banking Law,” disclosing that it is...more
On January 23, 2025, President Trump signed an executive order titled Strengthening American Leadership in Digital Financial Technology (Crypto EO), which addressed a variety of crypto-related topics to the great relief of...more
The European Banking Authority has published a consultation paper on its draft Regulatory Technical Standards on the calculation and aggregation of crypto-exposure values under the Capital Requirements Regulation 3...more
I am very pleased to co-chair again the Practicing Law Institute’s 2024 Anti-Money Laundering Conference on May 23, 2024, starting at 9 a.m. in New York City (the event also will be virtual). I am also really fortunate to be...more
Don’t miss the opportunity to gain valuable insights from industry experts at Canadian Institute’s Annual Flagship Conference on Regulatory Compliance for Financial Institutions. This event will equip you with strategies to...more
On July 12, 2023, U.S. Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-N.Y.) proposed a revised version of their previously introduced crypto regulation bill to create better safeguards for the crypto industry...more
On 4 April 2023, in a welcome development the Central Bank of Ireland (the "Central Bank") updated its AIFMD Q&A (47th edition) to increase the investment limits for qualifying investor alternative investment funds ("QIAIFs")...more
On February 23, the FDIC, Federal Reserve Board, and OCC released a joint statement addressing bank liquidity risks tied to crypto-assets. The agencies warned that using sources of funding from crypto-asset-related entities...more
On December 12, 2022, Custodia Bank (“Custodia”) – a state-chartered, digital asset-focused bank based in Wyoming – was denied its motion for a default judgment in its battle with the Federal Reserve Board of Governors (the...more