News & Analysis as of

U.S. Treasury Regulatory Reform

Polsinelli

Blockchain+ Bi-Weekly; Crypto Legislation Breaks Through: GENIUS Act Signed, CLARITY Advances and Other Key Web3 Legal Highlights:...

Polsinelli on

In a historic week for digital assets, the United States has officially enacted its first federal crypto legislation with the GENIUS Act signed into law on July 18, 2025. Passed after the longest House vote in history, this...more

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

Proskauer - Blockchain and the Law

Crypto in the Capitol: States Take the Lead on Strategic Bitcoin Reserves

As the digital economy continues to evolve, the U.S. government and a handful of states are beginning to experiment with new strategies for financial resilience, including the creation of Strategic Bitcoin Reserves (“SBR”)....more

Ropes & Gray LLP

Senate Passes Landmark Legislation to Regulate Payment Stablecoins

Ropes & Gray LLP on

On July 18, 2025, U.S. President Donald J. Trump signed the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins Act), an act designed to establish a framework for the regulation of “payment...more

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Sheppard Mullin Richter & Hampton LLP

Unpacking the U-Turn: What the Syria Sanctions Repeal Really Means

The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we...more

Morrison & Foerster LLP

The GENIUS Act: A New Federal Regulatory Framework for Payment Stablecoins

On July 18, 2025, President Trump signed into law S. 1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act” or the “Act”). The Act covers payment stablecoins[1]—a relatively new form...more

Cozen O'Connor

Passage of the GENIUS Act: A Turning Point in Stablecoin and Digital Asset Regulation

Cozen O'Connor on

President Donald J. Trump has signed into law the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 or the GENIUS Act of 2025), establishing the first comprehensive federal framework for...more

Davis Wright Tremaine LLP

Rethinking Bank Leverage and Capital Requirements in 2025

On July 10, 2025, the federal banking agencies published a proposed rule to change the enhanced supplementary leverage ratio (eSLR) for U.S. global systemically important bank holding companies (GSIBs) and their subsidiary...more

Orrick, Herrington & Sutcliffe LLP

Treasury revokes final rule following Congress’s repeal

On July 11, the IRS published a rule in the Federal Register revoking a rule the IRS had issued in December 2024 after the rule had been repealed by Congress under the Congressional Review Act. The final rule, “Gross Proceeds...more

Foley Hoag LLP

Unpacking the U.S. Sanctions Reversal on Syria: Implications and Future Outlook

Foley Hoag LLP on

Key Takeaways: - Executive Order 14312 revokes the six executive orders that formed the foundation of the Syrian Sanctions Program, terminates the national emergency underlying those executive orders and waives and relaxes...more

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Foley & Lardner LLP

What U.S. Businesses Need to Know About Reentering the Syrian Market & the Changing Post-Assad Sanction Landscape

Foley & Lardner LLP on

On May 23, 2025, approximately five months after the Assad regime was overthrown, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) officially issued Syria General License (GL) 25, which lifted the...more

Latham & Watkins LLP

Banking Regulators Propose to Ease Enhanced Supplementary Leverage Ratio for Large US Banks

Latham & Watkins LLP on

The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....more

Husch Blackwell LLP

New Executive Order Targets Wind and Solar Tax Credits

Husch Blackwell LLP on

On July 7, 2025, President Trump signed the executive order “Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources.” The EO directs the Secretary of the Treasury to “strictly enforce” the...more

McGuireWoods LLP

EO Directs Treasury to Issue Guidance on Beginning of Construction, BBB FEOC Restrictions

McGuireWoods LLP on

On July 7, 2025, President Donald Trump issued an executive order titled “Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources.” The EO directs the U.S. Department of the Treasury to issue new...more

Akin Gump Strauss Hauer & Feld LLP

Ending Market Distorting Subsidies for Unreliable, Foreign Controlled Energy Sources (Trump EO Tracker)

Directs the Secretary of the Treasury to issue new guidance within 45 days to enforce the termination of Sections 45Y and 48E tax credits for wind and solar under the One Big Beautiful Bill Act, including restricting safe...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Skadden, Arps, Slate, Meagher & Flom LLP

The CIP Rule Gets an Upgrade: What Banks and Fintechs Need to Know About the New Exemption

Key Points - On June 27, 2025, the Federal Deposit Insurance Corporation (FDIC), the Office of Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) exempted supervised banks and credit...more

Katten Muchin Rosenman LLP

President Trump Issues Executive Order Lifting Longstanding Sanctions on Syria

On June 30, 2025, President Trump issued Executive Order 14312 (“E.O. 14312” or the “E.O.”) titled “Providing for the Revocation of Syria Sanctions,” which terminates, effective July 1, 2025, the longstanding U.S. sanctions...more

Katten Muchin Rosenman LLP

Countdown to the Treasury Clearing Mandate: Will the Capital Rules Keep Pace?

We're still a year and a half from the effective date of the US Treasury Clearing mandate for cash trades and two years from the effective date for US Treasury repo transactions. But participants in the largest and most...more

Perkins Coie

GENIUS Act Passes US Senate in Significant Step Towards Regulatory Clarity for Stablecoins

Perkins Coie on

The U.S. Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins Act or GENIUS Act (S.1582) (the Act) in a 68-30 bipartisan vote on June 17, 2025. The GENIUS Act would provide a clear regulatory...more

Holland & Knight LLP

Treasury Secretary Asks for Removal of Section 899 Measures from One Big Beautiful Bill

Holland & Knight LLP on

In an announcement that had been anticipated for the past few days and will be welcomed by many industry stakeholders, U.S. Treasury Secretary Scott Bessent said late on June 26, 2025, that he has asked leaders in the U.S....more

Kohrman Jackson & Krantz LLP

Federal Reserve Signals Shift Toward Pragmatic Banking Regulation

With a focus on pragmatic and risk-based oversight, new leadership at the Federal Reserve signals a shift in the regulatory landscape for U.S. banks. Earlier this month, the Senate confirmed Federal Reserve Governor Michelle...more

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