The enforcement action offers insight for global firms into the FCA’s approach under the financial promotions regime.
By Stuart Davis and Gabriel Lakeman
On 10 February 2026, the FCA publicised that it has commenced proceedings against an offshore crypto platform for breach of the UK financial promotions regime for cryptoassets. This is the first
The Staff statement provides a technology-neutral framework for understanding securities tokenization models and emphasizes the consistent application of the securities laws to such models.
By Jenny Cieplak, Paul M. Dudek, Zachary Fallon, Stephen P. Wink, Naim Culhaci, and Deric Behar
Key Points:
Key themes and emerging issues that organisations will need to navigate under the new cryptoasset regulatory regime.
By Brett Carr, Stuart Davis, Gabriel Lakeman, Maria Georgiou, Jasmine Hopkinson, Cameron Jones, Sam Maxson, Imaan Nazir, Ivan Pizeta, Emma Trankeenan,* and Ema Uncovska
Key Points:
On January 28, 2026, staff at the U.S. Securities and Exchange Commission (SEC) published a Statement on Tokenized Securities. The Statement describes different categories of tokenized securities of interest to the SEC staff, and includes technical descriptions of each category.Continue Reading ›
In mid-January 2026, key Senate committees published discussion drafts of market structure legislation for comprehensive federal regulation of digital assets. The Senate Banking Committee’s version of the bill is called the “Digital Asset Market Clarity Act.” The Senate Agriculture Committee’s version of the bill is called the “Digital Commodity Intermediaries Act.”Continue Reading ›
The Proposal addresses recent comments about the scope of permissible activities for national trust banks, as applications to charter new banks continue to be filed.
By Arthur S. Long, Parag Patel, Pia Naib, Connor Jobes, and Deric Behar
Key Points
The Staff statement provides a framework for broker-dealers seeking to maintain “physical possession” of digital asset securities, emphasizing operational security and risk mitigation.
By Zachary Fallon, Stephen P. Wink, Naim Culhaci, and Deric Behar
Key Points:
The proposal outlines the application process and the factors that the FDIC will consider in granting approval for an entity to issue payment stablecoins.
By Arthur S. Long, Parag Patel, Pia Naib, Connor Jobes, and Deric Behar
Key Points
The publication of the SI marks the latest regulatory development in the UK’s rapidly evolving cryptoasset landscape.
By Stuart Davis, Gabriel Lakeman, Brett Carr, Sam Maxson, and Emma Trankeenan
Key Points
The update will create significant time pressure for firms seeking UK authorisation.
By Stuart Davis and Gabriel Lakeman
On 8 January 2026 the FCA published an update on the cryptoasset gateway (the Gateway) for firms seeking approval under the future regulatory regime for cryptoasset activities.1 The timings set out by the FCA will create