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FDIC Streamlines Process for Cryptocurrency Activities by Banks It Regulates and Speculates on Additional Permissible Activities

On March 28, 2025, the Federal Deposit Insurance Corporation (FDIC) issued guidance on state nonmember bank and state savings association participation in certain cryptocurrency activities (“FIL-7-2025”). ...more

Credibly Challenged Podcast: Interview With Mark Quandahl, Former Director of the Nebraska Department of Banking and Finance

Joe Castelluccio and Matt Bisanz interview Mark Quandahl, the former Director of the Nebraska Department of Banking and Finance. They discuss his role in the implementation of the Nebraska Financial Innovation Act, including...more

The SEC’s Staff of the Division of Corporation Finance Clarifies Its Views on Crypto Mining

On March 20, 2025, the SEC’s Staff of the Division of Corporation Finance (the “Division”) issued a statement providing its views that crypto mining activities (as defined in its statement) do not involve the offer and sale...more

Congress Moves Forward on Stablecoin Legislation: The US Senate Banking Committee Approves the GENIUS Act

On March 13, 2025, the US Senate Banking Committee passed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 or “GENIUS Act,” out of committee by a vote of 18-6....more

OCC Streamlines Process for Cryptocurrency Activities by Banks It Regulates

On March 7, 2025, the Office of the Comptroller of the Currency (OCC) issued guidance on national bank and federal savings association participation in certain cryptocurrency activities (“IL 1183”). This guidance is the...more

President Trump’s First Week in Office is a Momentous One for Digital Assets: An Executive Order, Repeal of SAB 121 and a Clear...

WHAT THIS MEANS FOR BANKS, FINANCIAL SERVICES AND THE DIGITAL ASSETS SECTOR - Just four days after his inauguration, President Donald Trump has initiated a fundamental shift in federal policy on digital assets with a...more

Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash and Limits Federal Government’s Ability to Police Crypto Transactions

On November 26, 2024, the United States Court of Appeals for the Fifth Circuit issued a landmark decision holding that the Treasury Department’s Office of Foreign Assets Control (“OFAC”) exceeded its statutory authority by...more

The Race to Develop Crypto Products is Now a Sprint, But Hurdles Remain: State Law Considerations in the New Crypto World Order

The outcome of the US presidential election this month, coupled with the prospect of a crypto-friendly president and Congress, have unleashed a torrent of enthusiasm that has been building throughout the crypto sector this...more

CFPB Finalizes Long-Awaited Rule to Accelerate Open Banking Development; Immediately Sued

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rulemaking on Personal Financial Data Rights (the “Final Rule”). The Final Rule is intended to accelerate a shift towards open banking in the...more

The US’s First ‘Crypto’ Election? Yes … But It Is More Complicated Than That

The 2024 presidential election in the United States is, without question, the country's first ‘crypto’ election. ...more

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more

House Passes Digital Asset Market Structure Legislation: Financial Innovation and Technology for the 21st Century Act (FIT21)

On May 22, 2024, the US House of Representatives passed H.R. 4763, the Financial Innovation and Technology for the 21st Century Act (FIT21), which would amend existing securities and commodity regulatory statutes to...more

SEC Approves Listings of Spot Ether ETFs: Waiting is the Hardest Part

On May 23, 2024, the Staff of the Securities and Exchange Commission’s Division of Trading and Markets (the “SEC”) approved rule changes (so-called “19b-4 forms”) permitting the listing and trading of eight separate...more

Investing in or Acquiring a Digital Assets Business? Watch Where You Step – Maximizing Value and Managing Risk in Digital Assets...

As applications and use cases for digital assets and their blockchain infrastructure grow and become more sophisticated, investments and valuations for businesses in these areas have grown as well. The growing number of...more

Crypto Asset Management: Expansion Roadmap for Managers and Investors (Part 1)

Asset managers who invest in crypto assets are expanding their footprint as managers of capital for investors. Investors are increasingly seeking out asset managers that have expertise in crypto assets. Likewise, crypto asset...more

Three-Body Problem: Challenges and Considerations for a First-of-Its-Kind Triple-Token Merger

Token holders for three different decentralized protocols have recently proposed a first-of-its-kind merger of tokens that would create an “Artificial Superintelligence Alliance” (“Alliance”) with a single token and a new,...more

Quick Reference Chart On Key Global Climate-Related Disclosure Rules

Climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating from numerous governmental authorities and non-governmental...more

Global Climate Change Disclosure Initiatives and Board Corporate Governance Considerations

Executive Summary- Climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating from numerous governmental authorities and...more

Transactional Liability Insurance in Renewable Energy and Climate/Clean Technology M&A: Insights Into Deploying a Critical Risk...

The renewable energy and climate/clean technology sectors have witnessed substantial growth and investment in recent years, spurred by accelerating energy transition initiatives and financial incentives passed into law. As...more

Without a TARDIS or a DeLorean, We Did the Best We Could: Five Blockchain Predictions for 2024

While the blockchain universe continues to expand, the direction and pace of its development will continue to be influenced by a number of variables – including financial markets, regulatory environments and politics. While...more

For the First Time, the US SEC Sanctions an NFT Issuer for Selling Unregistered Securities in SEC v. Impact Theory

In a published settlement of the charges on August 28, 2023, the US Securities and Exchange Commission (“SEC”) stated that non-fungible tokens (“NFTs”) issued by Impact Theory, LLC (“Impact”) were “securities” under US...more

Ripple is Not a Tidal Wave – the SEC’s Case Against Terraform Labs Provides a Quick Counterpoint to the Recent Ripple Ruling

Just weeks after the novel securities analysis in SEC v. Ripple Labs was handed down by Judge Analisa Torres, a different judge in the Southern District of New York has distinguished the approach taken in Ripple and argued...more

Defining Digital Asset Securities: US District Court Issues Summary Judgment Rulings in SEC v. Ripple Labs

For the past several years, many have viewed “SEC v. Ripple” as one of the defining conflicts in the US crypto regulatory landscape. At the heart of this dispute is the question of whether digital tokens are “securities” for...more

Virtual Currency Activity Prior Approval Requirement Established by NYDFS

On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related...more

What the FSOC Report Signals About the Future of Crypto-Asset Policy

On October 4, 2022, the US Financial Stability Oversight Council (FSOC) released its Report on Digital Asset Financial Stability Risks and Regulation (FSOC Report). The report is the latest in a series of reports issued...more

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