Crypto custody services under the microscope: EU regulators turn their attention to compliance with digital operational resilience rules.
By Stuart Davis, Gabriel Lakeman, and Alain Traill
On 8 July 2026, the European Securities and Markets Authority (ESMA) announced the launch of a Common Supervisory Action (CSA) focusing on the digital operational resilience of
ESMA’s statement reinforces that existing EU Member State product intervention measures on binary options apply to event contracts which constitute financial instruments.
By Gabriel Lakeman, José María Alonso, Axel Schiemann, Thomas Vogel, and Paloma Arizon
Key Points:
The rules cover trading admission and market abuse, stablecoin issuance, regulated activities, and how prudential and FCA Handbook requirements will apply to cryptoasset firms.
By Stuart Davis, Gabriel Lakeman, Brett Carr, Emma Trankeenan, Cameron Jones, and Imaan Nazir
On 30 June 2026, the FCA published a suite of policy statements
The proposal seeks to mitigate illicit finance risks while protecting the US financial system and national security interests.
By Arthur S. Long, Parag Patel, Hanyu (Iris) Xie, Pia Naib, and Deric Behar
Key Points:
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
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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
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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
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