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
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 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
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
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:
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 Proposal addresses recent comments about the scope of permissible activities for national trust banks, as applications to charter new banks continue to be filed.
By Arthur S. Long, Parag Patel, Pia Naib, Connor Jobes, and Deric Behar
Key Points
The Staff statement provides a framework for broker-dealers seeking to maintain “physical possession” of digital asset securities, emphasizing operational security and risk mitigation.
By Zachary Fallon, Stephen P. Wink, Naim Culhaci, and Deric Behar
Key Points:
The proposal outlines the application process and the factors that the FDIC will consider in granting approval for an entity to issue payment stablecoins.
By Arthur S. Long, Parag Patel, Pia Naib, Connor Jobes, and Deric Behar
Key Points
The publication of the SI marks the latest regulatory development in the UK’s rapidly evolving cryptoasset landscape.
By Stuart Davis, Gabriel Lakeman, Brett Carr, Sam Maxson, and Emma Trankeenan
Key Points