News & Analysis as of July 13, 2025

Virtual Currency

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Virtual Currency (aka Digital Currency or Digital Money) is a type of currency or medium of exchange that is not issued by any government nor guaranteed by a government currency. Despite lacking legal tender status, Virtual Currency is still traded and exchanged in some environments, typically online environments or communities. Bitcoin is the most well-known form of Virtual Currency. less -

Association of State Financial Regulators Issues Guidance on Virtual Currency for Licensed Money Transmitters

Wilson Sonsini Goodrich & Rosati on 7/10/2025

Recognizing the evolving landscape of digital finance, the Conference of State Bank Supervisors (CSBS), an association of state financial regulators, issued advisory guidance on the treatment of virtual currency held on a...more

FATF publishes targeted update and guidance on virtual assets and VASPs

A&O Shearman on 7/9/2025

The Financial Action Task Force (FATF) has published its sixth targeted update on the implementation of its standards for virtual assets (VAs) and virtual asset service providers (VASPs), alongside an updated webpage. The...more

CSBS Issues Guidance on Virtual Currency and Tangible Net Worth

Troutman Pepper Locke on 7/9/2025

On June 26, the Conference of State Bank Supervisors (CSBS) released new guidance regarding the treatment of virtual currency in the calculation of a licensee’s tangible net worth under the Money Transmission Modernization...more

Connecticut provides new laws for seizure and forfeiture of virtual currency and virtual currency wallets

Orrick, Herrington & Sutcliffe LLP on 6/30/2025

On June 23, the governor of Connecticut approved SB 6990 to establish new laws and amend existing ones regarding the seizure and forfeiture of virtual currency and virtual currency wallets in Connecticut. The new law states...more

Rhode Island enacts new virtual currency kiosk provisions

Orrick, Herrington & Sutcliffe LLP on 6/30/2025

On June 23, the governor of Rhode Island signed into law HB 5121 which grants Rhode Island new currency transmission laws to regulate and establish new licensing, disclosure and anti-fraud requirements for virtual currency...more

NYDFS Issues Guidance on Heightened Cybersecurity and Sanctions Risk from Global Conflict

Alston & Bird on 6/30/2025

Overview - On June 23, 2025, the New York State Department of Financial Services (“NYDFS”) issued an industry letter encouraging all regulated entities to review their cybersecurity and sanctions compliance programs in light...more

NYDFS Warns of Heightened Risk From Global Conflicts: What Regulated Entities Must Do Now

Troutman Pepper Locke on 6/27/2025

On June 23, the New York State Department of Financial Services (NYDFS) issued an industry letter to all regulated entities — banks, insurers, money transmitters, virtual currency companies, and others — cautioning that...more

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

Troutman Pepper Locke on 6/25/2025

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

NY Department of Financial Services Issues Guidance to its Regulated Industry As a Result of the Ongoing Global Conflict

Bressler, Amery & Ross, P.C. on 6/24/2025

The New York State Department of Financial Services (the “Department”) has issued guidance (“Guidance”) to all individuals and entities regulated by the Department (“Regulated Entities”) to underscore the importance of...more

The GENIUS Act Advances in the Senate

Troutman Pepper Locke on 5/28/2025

The U.S. Senate’s proposal to regulate stablecoins, known as the GENIUS Act, has successfully cleared a significant procedural hurdle, moving closer to a full floor debate. On May 19, lawmakers voted to invoke cloture on the...more

Recent Passing of Hong Kong Stablecoins Bill

Seyfarth Shaw LLP on 5/27/2025

On May 21, 2025, Hong Kong’s Legislative Council passed the Stablecoins Bill, establishing a regulatory framework for stablecoins–cryptocurrencies whose value is tied to an external asset or commodity. This marks an important...more

United States: The Continuing Shift to Modern Money Transmission Laws

K&L Gates LLP on 5/13/2025

Within the past two months, three states have adopted the Money Transmission Modernization Act (MTMA). The governors of Virginia, Mississippi, and most recently Colorado, signed bills that implement the MTMA, and two other...more

The crypto question: Digital currency dealmaking set to boom in 2025

White & Case LLP on 5/12/2025

Dealmaking within the US and Europe is climbing as crypto assets increasingly enter the mainstream - Dealmaking in the digital currency space is flourishing, buoyed by strong industry growth, political backing and supportive...more

FINRA’s Blueprint for the Metaverse

Carlton Fields on 5/6/2025

In October 2024, FINRA released its blueprint for the securities industry’s use of the metaverse — the metaverse report. The metaverse, often framed as “the next evolution of today’s internet,” is a loosely defined term used...more

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – April 2025 # 5

Troutman Pepper Locke on 5/1/2025

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

Regulatory Update: Cayman Islands VASP Licensing Regime Now in Effect

Conyers on 4/23/2025

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

Arkansas adds crypto kiosk provisions to its money transmission act

Orrick, Herrington & Sutcliffe LLP on 4/21/2025

On April 14, Arkansas enacted HB 1467 (the “Act”) to amend the Arkansas Uniform Money Services Act to enhance consumer protection and transparency in virtual currency transactions, particularly those through kiosks. The Act...more

Global Financial and Economic Crime Outlook: Introducing the Secretariat Economic Crime Index 2025

Secretariat on 4/10/2025

The global financial landscape is under siege by increasingly sophisticated financial and economic crimes. Money laundering, fraud, corruption, and market abuse pose ever-growing risks, compounded by rapid advancements in AI,...more

Ten things every VASP should know about the BVI Virtual Assets Service Providers Act, 2022

Carey Olsen on 4/8/2025

The Virtual Assets Service Providers Act, 2022 (the “VASP Act”) came into force on 1 February 2023. The VASP Act regulates virtual asset service providers (“VASPs”) and requires that VASPs be registered with the BVI Financial...more

Anti-Money Laundering Enforcement Risk Still Remains for Virtual Asset Services Providers

Paul Hastings LLP on 4/7/2025

Despite the Trump administration’s generally favorable stance toward cryptocurrency and blockchain innovation, virtual asset services providers (VASPs) must remain vigilant in complying with anti-money laundering (AML)...more

EU: New European Consumer Protection Guidelines for Virtual Currencies in Video Games

Sheppard Mullin Richter & Hampton LLP on 4/1/2025

On March 21, 2025, ahead of a consultation and call for evidence on the EU’s Digital Fairness Act, the Consumer Protection Cooperation (CPC) Network highlighted the pressing need for improved consumer protection in the...more

Amendments to the regulatory framework for virtual assets in the Cayman Islands

Carey Olsen on 3/31/2025

On 1 April 2025, several key updates will be made to the framework for the regulation of virtual assets in the Cayman Islands. These updates include the introduction and commencement of the VASP licencing framework for...more

Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on 3/19/2025

In the latest episode of Payments Pros, hosts Keith Barnett and Carlin McCrory discuss the latest FinCEN and OFAC guidance on virtual currency transactions, specifically tailored for companies in the payments industry. They...more

Pixels, Pennies, and Punishments: Virtual Currency Costs Company $25M

Fenwick & West LLP on 3/13/2025

The house doesn’t always win—a federal jury awarded nearly $25 million in damages to a class of consumers in Washington State after a district court in Larsen v. PTT, LLC determined that certain “social casino” games operated...more

SEC Declares Meme Coins Are Not “Securities” In New Statement

A&O Shearman on 3/12/2025

On February 27, 2025, the Securities and Exchange Commission (the “SEC”) issued a statement to provide clarity on the application of federal securities laws to crypto assets by declaring that “meme coins” do not fall under...more

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Virtual Currency

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