The first of what may be a series of crypto no-action letters supports the view that programmatic token distributions serving as network incentives are not securities.
By Jenny Cieplak, Paul M. Dudek, Zachary Fallon, Stephen P. Wink, Hank Balaban, Daphne Lambadariou, and Deric Behar
On September 29, 2025, the
The request for comment aims to help Treasury devise clear guidelines for stablecoin issuers, promote international coordination, and protect consumers from potential risks.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
On September 19, 2025, the US Department of the Treasury (Treasury) issued an Advance Notice of Proposed Rulemaking
The agencies pledge to “usher in a new era of innovation” through a collaboration on rules and exemptions that aims to provide digital asset markets with clarity.
By Stephen P. Wink, Zachary Fallon, Yvette D. Valdez, Douglas K. Yatter, Jenny Cieplak, Adam Bruce Fovent, and Deric Behar
The SEC’s
The FDIC seeks to avoid overburdening financial services providers with regulations regarding its logo after assessing market feedback and implementation issues.
By Arthur S. Long, Parag Patel, Pia Naib, Connor Jobes, and Deric Behar
On August 19, 2025, the Federal Deposit Insurance Corporation (FDIC) board of directors approved a proposed rule
DOJ will focus on criminal intent over mere code creation, seeking to balance legal accountability with support for innovation.
By Zachary Fallon, Jack McNeily, Benjamin Naftalis, Parag Patel, Barrie VanBrackle, Eric S. Volkman, Stephen P. Wink, Iris Xie, Douglas K. Yatter, and Deric Behar
On August
The Staff provides the market with additional crypto clarity, holding that liquid staking does not qualify as a security under the Howey test.
By Jenny Cieplak, Zachary Fallon, Yvette D. Valdez, Stephen P. Wink, Hank Balaban,* Adam Bruce Fovent, Daphne Lambadariou, and Deric Behar
On August 5, 2025,
Regulators are directed to avoid reputation risk, identify banks that have engaged in unlawful debanking, and take appropriate remedial actions.
By Marc P. Berger, Betty M. Huber, Arthur S. Long, Benjamin Naftalis, Parag Patel, Stephen P. Wink, Douglas K. Yatter, Pia Naib, and Deric Behar
On August
As the SEC unveils a strategic plan to modernize securities regulations and drive US leadership in blockchain integration within financial markets, the CFTC launches a corresponding “crypto sprint.”
By Stephen P. Wink, Zachary Fallon, Yvette D. Valdez, Douglas K. Yatter, Jenny Cieplak, Adam Bruce Fovent, Daphne Lambadariou, Connor
The report reflects collaboration across federal agencies and aims to establish US leadership in digital assets through forward-thinking policy and a clear regulatory framework.
By Jenny Cieplak, Zachary Fallon, Arthur S. Long, Benjamin Naftalis, Parag Patel, Yvette D. Valdez, Eric S. Volkman, Stephen P. Wink, Iris Xie
Considerations on the proposed expansion of CFTC commodity pool regulation.
By Yvette D. Valdez, Adam Fovent, and Mia Stefanou
On July 17, 2025, the House of Representatives passed the Digital Asset Market Clarity Act of 2025 (the CLARITY Act). This pivotal legislation introduces a comprehensive regulatory framework for the digital asset sector and