Illinois’s interchange fee law is permanently enjoined for most entities after OCC preemption, but a fragmented outcome sets the stage for further appeals.
By Arthur S. Long, Jack McNeily, Parag Patel, Barrie VanBrackle, Pia Naib, and Deric Behar
Key Points:
The Proposal would establish principles-based AML/CFT and sanctions compliance standards for stablecoin issuers aligned with FinCEN and OFAC, as well as supervision and enforcement provisions.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
Key Points:
Comprehensive regulation to come with further licensing regimes for crypto advisory and asset management services, in addition to crypto dealing and custody.
By Simon Hawkins and Adrian Fong
On 26 May 2026, the Hong Kong Financial Services and Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) issued consultation conclusions on their legislative proposals
Participants are invited to comment on the appropriateness of MiCA by 31 August 2026.
By Axel Schiemann, Thomas Vogel, Lasse Winzer, Stuart Davis, and Gabriel Lakeman
Key Points:
The Order aims to integrate digital asset providers and innovative technologies into traditional financial services via broader access to the FRB’s payment infrastructure.
By Jenny Cieplak, Zachary Fallon, Arthur S. Long, Parag Patel, Yvette D. Valdez, Stephen P. Wink, Pia Naib, and Deric Behar
Key Points:
The OCC issued two interim final actions preempting the Illinois Interchange Fee Prohibition Act, causing the Seventh Circuit to vacate and remand related proceedings to the district court.
By Arthur S. Long, Jack McNeily, Parag Patel, Barrie VanBrackle, Pia Naib, Connor Jobes, and Deric Behar
Key Points:
The guidance defines certain regulated cryptoasset activities broadly, potentially placing onerous authorisation obligations on DeFi and web3 user interfaces and wallets.
By Stuart Davis, Gabriel Lakeman, Brett Carr, Cameron Jones, and Imaan Nazir
On 15 April 2026, the FCA published draft perimeter guidance (in CP 26/13) that, if finalised in
The SEC Staff sets out conditions under which providers of certain cryptoasset securities-transaction interfaces may operate without broker-dealer registration.
By Zachary Fallon, Stephen P. Wink, Jenny Cieplak, Naim Culhaci, Haoyu Gu, Dallin Adams, and Deric Behar
Key Points:
The Interpretive Release supersedes prior Staff guidance on cryptoassets, establishing a five-part token taxonomy and formally recognizing that tokens can change their character as investment contracts.
By Jenny Cieplak, Paul M. Dudek, Zachary Fallon, Yvette D. Valdez, Stephen P. Wink, Douglas K. Yatter, Adam Bruce Fovent, E. Dafni
UK firms should expect heightened FCA attention on Consumer Duty, financial crime, and safeguarding compliance, with continually high standards at the application gateway.
By Brett Carr, Stuart Davis, Gabriel Lakeman, and Christian F. McDermott
On 25 March 2026, the FCA published its Regulatory Priorities report aimed at firms operating in the UK