President Donald Trump has signed a sweeping Executive Order titled “Guaranteeing Fair Banking for All Americans,” aimed at preventing financial institutions from denying services to individuals or businesses based on political or religious beliefs, lawful business activities, or other constitutionally and statutorily protected attributes. While the impetus for debanking historically has been political and regulatory
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President’s Working Group Issues Report on Digital Financial Technology
On July 30, 2025, the President’s Working Group on Digital Assets released its report entitled “Strengthening American Leadership in Digital Financial Technology.” The report champions American innovation in crypto, and “endorses the notion that digital assets and blockchain technologies can revolutionize not just America’s financial system, but systems of ownership and governance economy-wide.”Continue Reading ›
States Shift Focus to Digital Assets
In recent weeks all eyes have been on Congress as various bills regulating digital assets advance. But state legislatures have been busy as well, with several considering new legislation on digital assets and cryptocurrency.Continue Reading ›
Senators Introduce Stablecoin Bill
On April 17, 2024, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced a bill entitled the Lummis-Gillibrand Payment Stablecoin Act. The bill is the latest bipartisan effort by the two senators to provide a comprehensive federal oversight regime for the regulation of stablecoins.…
OFAC, BIS and DOJ Issue Guidance for Foreign Companies to Comply with US Sanctions and Export Control Laws
US Department of the Treasury’s Office of Foreign Assets Control (OFAC), the US Department of Commerce’s (Commerce) Bureau of Industry and Security (BIS) and the US Department of Justice (DOJ), collectively issued guidance regarding the obligations of non-US based companies and persons to comply with US sanctions (Tri-Seal Compliance Note: Obligations of foreign-based persons to…
SEC Expands “Dealer” Definition
On February 6, 2024, by a 3-2 vote, the US Securities and Exchange Commission adopted new rules that expand the definition of “dealer” under the federal securities laws. Ostensibly adopted to provide the SEC with greater oversight over the market for Treasury bonds, the new rules are not limited to any particular asset class, and…
Foreign Extortion Prevention Act Criminalizes Bribery Demands by Foreign Officials
On December 22, 2023, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law as part of the fiscal year 2024 National Defense Authorization Act. Although bribery always requires a giver and a receiver, US anti-corruption efforts have traditionally focused almost exclusively on those who pay bribes because of the way the Foreign Corrupt…
AI and Emerging Technologies Year in Review
2023 was a year filled with remarkable AI-related legal developments in legislation, litigation, and regulation. Recent headlines indicate that 2024 will be noteworthy as well. In our AI and Emerging Technologies Year in Review, we take a look at what happened over the past year and predict how key AI issues and trends in the…
Corporate Transparency Act: FinCEN Updates FAQs on Beneficial Ownership Information
On January 12, 2024, FinCEN updated its Beneficial Ownership Information Frequently Asked Questions (“FAQs”) to include new information and clarifications about reporting companies, beneficial owners, company applicants, and other reporting requirements. We discuss these developments in our post.…
FINRA Continues Focus on Crypto Asset Securities
FINRA, the self-regulatory organization overseeing the US broker-dealer industry, recently announced two items of interest for broker-dealers offering crypto asset securities. On January 9, 2024, FINRA published its 2024 Annual Regulatory Oversight Report, which includes a detailed section for broker-dealers conducting a crypto asset business. Then, on January 23, 2024, FINRA published a report detailing…
