News & Analysis as of

Digital Assets Risk Management FinTech

Ballard Spahr LLP

FinCEN’s Focus on Cryptocurrency Kiosks and Financial Crime

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On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also...more

Buchalter

As Federal Government Works to Liberalize the Crypto Payment Regulatory Regime, Federal Reserve Eliminates Specialty Supervisory...

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In its Client Alert of August 4, 2025, Buchalter discussed the new Genius Act creating a regulatory regime for stable coin payments, and other steps as the federal government looks to create a more favorable crypto currency...more

Orrick, Herrington & Sutcliffe LLP

Fed’s Bowman discusses blockchain and new technologies in banking

On August 19, the Fed’s Vice Chair for Supervision, Michelle W. Bowman, addressed a blockchain symposium and outlined the Fed’s approach to blockchain technology, the costs of “reputational risk” in bank supervision, and...more

Foley & Lardner LLP

Banking and Digital Assets: Key Takeaways from the President’s Working Group Report

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On July 30, 2025, the President’s Working Group on Digital Asset Markets (PWG) released “Strengthening American Leadership in Digital Financial Technology,” a comprehensive digital asset report (Report) mandated by President...more

Troutman Pepper Locke

The Federal Reserve’s Shift in Supervision Strategy for Novel Activities

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On August 15, the Federal Reserve Board announced a significant shift in its approach to supervising novel activities within banking organizations. The Board decided to sunset its Novel Activities Supervision Program, which...more

K&L Gates LLP

UK Office for Financial Sanctions Implementation Crypto-Assets Threat Assessment (July 2025): Key Lessons for Sanctions Compliance

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On 21 July 2025, the UK Office for Financial Sanctions Implementation (OFSI) published its latest sector-specific threat assessment focusing on UK crypto-asset firms’ exposure to financial sanctions breaches, covering...more

Paul Hastings LLP

Banking Regulators Clarify Crypto Custody Expectations, Congress Advances Landmark Digital Asset Legislation and Senate Releases...

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In a pivotal week for digital asset policy, federal banking regulators issued long-awaited guidance outlining risk-management expectations for crypto-asset safekeeping activities. The OCC, Federal Reserve and FDIC released a...more

DLA Piper

Stablecoins and the Genius Act: What You Need to Know

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On July 17, 2025, the US Congress passed the Guiding and Establishing National Innovation for US Stablecoins Act (Genius Act or Act) by 308–122 vote, a landmark piece of legislation establishing the first federal regulatory...more

Walkers

Balancing innovation and compliance in digital assets

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Establish a compliance framework to innovate confidently and avoid regulatory missteps. Use testing licenses and sandbox environments to trial new products under regulatory supervision....more

Baker Donelson

The GENIUS Act: A New Era for Stablecoins Begins – What the Fintech, Investment and Banking Industry Sectors Need to Know?

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On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 – better known as the GENIUS Act. The GENIUS Act establishes the most comprehensive federal...more

A&O Shearman

ESMA publishes final guidelines under MiCAR for CASP staff providing crypto-asset information

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The European Securities and Markets Authority (ESMA) has published its final guidelines under the Markets in Crypto-Assets Regulation (MiCAR) specifying the criteria for assessing the knowledge and competence of staff at...more

A&O Shearman

ESMA statement advises CASPs on mitigating investor risks over unregulated products

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The European Securities and Markets Authority (ESMA) has issued a public statement addressed to crypto-asset service providers (CASPs) that offer both regulated and unregulated services under the Markets in Crypto-Assets...more

Shumaker, Loop & Kendrick, LLP

Client Alert: Senate Passes GENIUS Act

The recent advancement of the GENIUS Act marks a turning point in the regulatory treatment of stablecoins in the United States, establishing a federal framework for the issuance and supervision of payment stablecoins. The...more

Orrick, Herrington & Sutcliffe LLP

OCC’s Hood remarks on building a “resurgent” financial system

On June 3, the OCC Acting Comptroller, Rodney E. Hood, delivered remarks outlining how he plans to build a resilient and resurgent financial system. The Acting Comptroller emphasized four key strategies: accelerating...more

Goodwin

Acting Comptroller of the Currency Discusses OCC’s Regulatory Agenda

Goodwin on

In recent remarks delivered at the U.S. Chamber of Commerce Capital Markets Summit, Acting Comptroller of the Currency, Rodney E. Hood, outlined the OCC’s strategic priorities for building a resilient and revitalized federal...more

Troutman Pepper Locke

FOIA Litigation Unveils Important Supervisory Insights and Needed Reform

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Following the Freedom of Information Act (FOIA) litigation brought against the Federal Deposit Insurance Corporation (FDIC) in 2024, on February 5, 2025, the FDIC released hundreds of pages of documents related to its...more

Cadwalader, Wickersham & Taft LLP

Rules in Motion, May 2025 - IOSCO Publishes Final Reports on Finfluencers, Online Imitative Trading Practices and Digital...

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

Skadden, Arps, Slate, Meagher & Flom LLP

Cybersecurity Trends in the Digital Asset Space

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

Conyers

Regulatory Update: Cayman Islands VASP Licensing Regime Now in Effect

Conyers on

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

Patomak Global Partners

FDIC Highlights Policy Priorities Impacting FinTechs and Large Banks

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

Walkers

The BMA invites proposals to test Embedded Supervision in DeFi

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The Bermuda Monetary Authority ("BMA") has issued an invite for proposals from voluntary participants to take part in a pilot project aimed at testing Embedded Supervision practices within the context of DeFi. Embedded...more

Sheppard Mullin Richter & Hampton LLP

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

Ballard Spahr LLP

Crypto Clarity: OCC’s New Guidelines Pave the Way for Banking Innovation

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On March 7, 2025, the Office of the Comptroller of the Currency (“OCC”) released Interpretive Letter 1183, marking a pivotal change in regulatory guidance for national banks and federal savings associations engaging in...more

A&O Shearman

IOSCO publishes 2025 Work Program

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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

Wilson Sonsini Goodrich & Rosati

A Crypto-Friendly Pivot in Bank Supervision: Three Practical Action Items for Innovators

A federal banking agency, the Office of the Comptroller of the Currency (OCC), has smoothed the way for national banks and federal savings associations to engage in crypto-related activities with the issuance of Interpretive...more

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