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Connecticut Updates Money Transmission Law to Cover Digital Wallets and Virtual Currency

On June 30, 2025, Connecticut Governor Ned Lamont signed Public Act No. 25-66, enacting broad revisions to Connecticut’s money transmission statutes. The new law, effective October 1, 2025, updates definitions, expands...more

Federal Banking Regulators Issue Joint Guidance on Crypto-Asset Safekeeping

On July 14, the OCC, Federal Reserve, and FDIC announced the release of a joint statement clarifying how existing laws and regulations apply to crypto-asset safekeeping services offered by banking organizations. The statement...more

DFPI Finalizes $300,000 Settlement with Crypto Kiosk Operator for Alleged Digital Asset Law Violations

On June 25, the California DFPI announced that it had finalized a consent order with a cryptocurrency kiosk operator, alleging violations of the Digital Financial Assets Law (DFAL) and the California Consumer Financial...more

Pennsylvania to Require Licenses for Virtual Currency Transmitters

On June 27, Pennsylvania enacted Senate Bill 202, which significantly expands the Commonwealth’s Money Transmitter Act (MTA) to include virtual currency transmission. Under the amended law, transmitting virtual currency is...more

FHFA Orders Fannie Mae and Freddie Mac to Consider Cryptocurrency Reserves in Mortgage Risk Assessments

On June 25, the Federal Housing Finance Agency (FHFA) issued a directive ordering Fannie Mae and Freddie Mac to prepare proposals for treating cryptocurrency held on U.S.-regulated exchanges as assets for reserves in...more

California Assembly Advances Bill to Permit Crypto Payments under DFAL

On June 2, the California State Assembly unanimously passed Assembly Bill 1180, which now moves to the California Senate for consideration. The bill would require the Department of Financial Protection and Innovation (DFPI)...more

Senate Advances Stablecoin Bill

On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle....more

OCC Confirms Banks Authority to Offer Crypto Custody and Execution Services

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

FTC Imposed $9.6 Million Judgement Against Debt Collector for Alleged Threats and Phantom Debt

On April 30, 2025, the FTC filed an amended complaint and final order in the U.S. District Court for the Northern District of Georgia against a debt collection company in connection with allegations that the company engaged...more

Digital Dollars, Not Investments: SEC Staff Weighs in on Stablecoins

On April 4, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued a statement clarifying that reserve-backed U.S. dollar stablecoins are not securities, at least under current law and...more

DOJ Narrows Crypto Enforcement Focus to Fraud and Criminal Conduct

On April 7, in a significant policy shift, the U.S. Department of Justice (DOJ) announced via the release of a memorandum that it will no longer pursue criminal enforcement actions that effectively impose regulatory...more

California DFPI Proposes Digital Asset Licensing Rule

On April 4, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations under the Digital Financial Assets Law (DFAL). The proposal provides clarification on DFAL’s licensing framework...more

FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks

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

Kentucky Enacts New Law Establishing Legal Framework for Blockchain and Digital Assets

On March 24, Kentucky enacted House Bill 701, establishing a statutory framework to support blockchain-based activity and clarifying the treatment of digital assets under state law. The legislation defines key terms, permits...more

Federal Crypto Ownership: Compliance Implications of the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile

Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, federal agencies and market participants may begin to grapple with the operational and compliance...more

FDIC Aims to Eliminate Reputational Risk from Supervision

On March 24, acting FDIC Chairman Travis Hill informed Congress that the agency is preparing to eliminate the use of “reputation risk” as a basis for supervisory criticism. In a letter to Rep. Dan Meuser (R-Pa.), Hill...more

From Seizures to Strategy: The U.S. Government’s Move Toward a National Crypto Reserve

Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve, released alongside a White House Briefing, the U.S. government has taken its most formal step yet toward integrating digital assets...more

SEC Creates New Tech-Focused Enforcement Team

On February 20, the SEC announced the creation of its Cyber and Emerging Technologies Unit (CETU) to address misconduct involving new technologies and strengthen protections for retail investors. The CETU replaces the SEC’s...more

OCC Signals Shift on Crypto and Debanking Under Acting Comptroller Hood 

On March 18, Acting Comptroller of the Currency Rodney Hood reiterated the OCC’s commitment to ensuring fair access to banking services, including for cryptocurrency firms. Speaking at a retail banking industry conference,...more

OCC Clarifies Banks’ Role in Cryptocurrency Activities

On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities,...more

California DFPI Reaches Settlement with Lender Over Crypto-Backed Loans

On December 23, 2024, the California Department of Financial Protection and Innovation (DFPI) announced a consent order with a lender to resolve its investigation into the company’s crypto-backed lending program, which the...more

Trump Administration Announces New Picks for the CFPB and OCC

On February 12, the Trump administration announced Jonathan McKernan as the Director of the CFPB and Jonathan Gould as the Comptroller of the Currency. McKernan and Gould will replace Acting Directors Russell Vought and...more

CFPB Proposes Interpretive Rule on Emerging Payment Mechanisms Under EFTA

On January 2, 2025, the Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule under the Electronic Fund Transfer Act (EFTA) and Regulation E to clarify how emerging payment systems, such as those used in...more

Fifth Circuit Overturns OFAC Sanctions on Blockchain-based Privacy Technology

On November 26, the U.S. Fifth Circuit Court of Appeals overturned sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) against a decentralized cryptocurrency mixing service (a...more

Crypto Platform Settles SEC and State Regulator Charges over Interest Bearing Feature on Customer Accounts

On February 7, a Florida-based cryptocurrency company agreed to settle charges brought by the SEC and the California Department of Financial Protection and Innovation alleging that, an interest-earning feature offered on the...more

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