A recent decision from an Indiana federal court underscores that the principles behind what makes “clickwrap” assent enforceable are not limited to websites and apps found through smartphones and laptops. In Beckett v. Bitcoin Depot, Inc., No. 25-01450 (S.D. Ind. Feb. 26, 2026), the court granted a Bitcoin ATM operator’s motion to compel arbitration,
SEC Issues Interpretive Guidance on Crypto Assets
On March 17, 2026, the US Securities and Exchange Commission (SEC) announced the release of interpretive guidance (Guidance) seeking to clarify the application of the federal securities laws to various categories of crypto assets. The Commodity Futures Trading Commission also joined the guidance to assure market participants it would interpret the Commodity Exchange Act in
Treasury Issues Report on Innovative Technologies to Counter Illicit Finance Involving Digital Assets
On March 6, 2026, the Treasury Department published a report to Congress entitled “Innovative Technologies to Counter Illicit Finance Involving Digital Assets.” Required under the GENIUS Act, the report evaluates how financial institutions can use new technologies to detect and prevent illicit finance involving digital assets, and recommends regulatory and policy actions.Continue Reading ›
OCC Issues Proposal to Implement the GENIUS Act
The Proposal would establish many requirements for OCC supervised entities, including reserves, capital standards, redemption timelines, and the extent of OCC supervisory authority.
By Jenny Cieplak, Arthur S. Long, Parag Patel, Yvette D. Valdez, Barrie VanBrackle, Pia Naib, and Deric Behar
On February 25, 2026, the Office of the
OCC Finalizes Rule on National Trust Bank Activities
The Rule provides critical regulatory clarity for entities seeking national trust bank charters to engage in digital asset activities.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
Key Points
- The Final Rule amends the OCC’s chartering regulations to clarify that national trust banks are not limited to fiduciary activities
OCC Proposes Stablecoin Rules
On February 25, 2026, the federal Office of the Comptroller of the Currency (OCC), published draft regulations for payment stablecoin issuers under the GENIUS Act. The proposed rules focus on stablecoin activities of entities that the OCC will supervise under the GENIUS Act, including stablecoin issuers that are owned or chartered as national banks,
Federal Court Partially Upholds Illinois Law Limiting Interchange Fees
The decision clears a legal path for state-level regulation of credit and debit card swipe fees (while striking down data usage restrictions), setting the stage for a high-stakes appeal.
By Arthur S. Long, Jack McNeily, Parag Patel, Barrie VanBrackle, Pia Naib, and Deric Behar
Updated on March 5, 2026
On
FCA Takes First Enforcement Action Under UK Crypto Marketing Regime
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
SEC Staff Issues Statement on Tokenized Securities
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:
- The Staff acknowledges both issuer- and third-party-sponsored tokenization
UK Cryptoasset Regime: What to Know About the FCA Consultation Papers
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:
- The 12