In this issue:
In this issue:
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
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 ›
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