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
On April 23, 2026, Rep. Young Kim (R-CA) and Rep. Sam Liccardo (D-CA) introduced a bill in the House of Representatives entitled the Payments Access and Consumer Efficiency (PACE) Act. The bill seeks to modernize the payment system by allowing qualified nonbank financial companies, including certain FinTech and digital asset businesses, to directly access Federal
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:
On April 13, 2026, staff in the US Securities and Exchange Commission (SEC) Division of Trading and Markets issued a Staff Statement Regarding Broker-Dealer Registration of Certain User Interfaces Utilized to Prepare Transactions in Crypto Asset Securities. Absent further action by the SEC, the statement will be considered withdrawn five years from the date of
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
The no-action relief permits use of non-custodial wallet software in connection with CFTC-regulated derivatives trading, subject to certain conditions.
By Yvette D. Valdez, Douglas K. Yatter, Adam Bruce Fovent, and Deric Behar
Key Points
Regulators establish a framework for coordinated oversight, joint product guidance, and aligned enforcement, with a particular focus on cryptoassets and emerging financial technologies.
By Marc P. Berger, Zachary Fallon, John J. Sikora Jr., Yvette D. Valdez, Stephen P. Wink, Douglas K. Yatter, and Deric Behar
Key Points:
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,
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