On September 29, 2025, staff in the SEC’s Division of Investment Management issued no-action relief for certain crypto asset custodians. Specifically, the relief will, under certain circumstances, allow SEC-registered investment advisers (Registered Advisers), registered investment companies and business development companies (collectively, Regulated Funds) to treat a state-chartered trust company as a “bank” (for custody purposes)
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Treasury Continues Implementation of GENIUS Act
On September 19, 2025, the Department of the Treasury published an advance notice of proposed rulemaking to solicit public comment on questions relating to implementation of the GENIUS Act. Comments are due October 20, 2025.Continue Reading ›
UK ICO Launches Consultation on Distributed Ledger Technologies Guidance
By Hunton
On August 28, 2025, the UK Information Commissioner’s Office initiated a public consultation on draft guidance on Distributed Ledger Technologies, focusing on blockchain.Continue Reading ›
Trump Signs Executive Order on “Politicized” and “Unlawful” Debanking
By Hunton
President Donald Trump has signed a sweeping Executive Order titled “Guaranteeing Fair Banking for All Americans,” aimed at preventing financial institutions from denying services to individuals or businesses based on political or religious beliefs, lawful business activities, or other constitutionally and statutorily protected attributes. While the impetus for debanking historically has been political and regulatory…
President’s Working Group Issues Report on Digital Financial Technology
On July 30, 2025, the President’s Working Group on Digital Assets released its report entitled “Strengthening American Leadership in Digital Financial Technology.” The report champions American innovation in crypto, and “endorses the notion that digital assets and blockchain technologies can revolutionize not just America’s financial system, but systems of ownership and governance economy-wide.”Continue Reading ›
States Shift Focus to Digital Assets
In recent weeks all eyes have been on Congress as various bills regulating digital assets advance. But state legislatures have been busy as well, with several considering new legislation on digital assets and cryptocurrency.Continue Reading ›
Senators Introduce Stablecoin Bill
On April 17, 2024, Senators Cynthia Lummis (R-WY) and Kirsten Gillibrand (D-NY) introduced a bill entitled the Lummis-Gillibrand Payment Stablecoin Act. The bill is the latest bipartisan effort by the two senators to provide a comprehensive federal oversight regime for the regulation of stablecoins.…
OFAC, BIS and DOJ Issue Guidance for Foreign Companies to Comply with US Sanctions and Export Control Laws
US Department of the Treasury’s Office of Foreign Assets Control (OFAC), the US Department of Commerce’s (Commerce) Bureau of Industry and Security (BIS) and the US Department of Justice (DOJ), collectively issued guidance regarding the obligations of non-US based companies and persons to comply with US sanctions (Tri-Seal Compliance Note: Obligations of foreign-based persons to…
SEC Expands “Dealer” Definition
On February 6, 2024, by a 3-2 vote, the US Securities and Exchange Commission adopted new rules that expand the definition of “dealer” under the federal securities laws. Ostensibly adopted to provide the SEC with greater oversight over the market for Treasury bonds, the new rules are not limited to any particular asset class, and…
Foreign Extortion Prevention Act Criminalizes Bribery Demands by Foreign Officials
On December 22, 2023, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law as part of the fiscal year 2024 National Defense Authorization Act. Although bribery always requires a giver and a receiver, US anti-corruption efforts have traditionally focused almost exclusively on those who pay bribes because of the way the Foreign Corrupt…