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Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

Regulators Sharpen Focus on Anti-Money Laundering Expectations for Crypto Industry

U.S. regulators are signaling heightened expectations for anti-money laundering compliance within the crypto industry. Although FinCEN issued guidance in 2013 interpreting virtual currency “administrators” and “exchanges” as...more

In Depth: President Biden Proposes New Administrative Forfeiture Process and Other Legislative Changes to Address Ukraine Crisis

Alongside the slew of new sanctions imposed in response to Russia’s invasion of Ukraine, the Biden administration also has been laying the groundwork to maximize the impact of those sanctions. Just days after Russian military...more

New Biden Executive Order on Digital Assets

President Biden issued an executive order (“EO”) recently on “Ensuring Responsible Development of Digital Assets.” The EO calls for an aligned, all-of-government approach to digital assets, which the EO defines to include,...more

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