Participants are invited to comment on the appropriateness of MiCA by 31 August 2026.
By Axel Schiemann, Thomas Vogel, Lasse Winzer, Stuart Davis, and Gabriel Lakeman
Key Points:
The European Commission is reviewing MiCA’s suitability through a targeted public consultation, open for comment until 31 August 2026.
The review focuses on major policy questions, including the…
The Order aims to integrate digital asset providers and innovative technologies into traditional financial services via broader access to the FRB’s payment infrastructure.
By Jenny Cieplak, Zachary Fallon, Arthur S. Long, Parag Patel, Yvette D. Valdez, Stephen P. Wink, Pia Naib, and Deric Behar
Key Points:
The Order requires all federal financial regulators…
The OCC issued two interim final actions preempting the Illinois Interchange Fee Prohibition Act, causing the Seventh Circuit to vacate and remand related proceedings to the district court.
By Arthur S. Long, Jack McNeily, Parag Patel, Barrie VanBrackle, Pia Naib, Connor Jobes, and Deric Behar
Key Points:
The OCC issued an interim final rule…
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 its current form, could bring…
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:
The Statement lists 12 conditions (including routing transparency, disclosures, and the absence of discretionary functions) under…
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 (Daphne) Lambadariou, and Deric…
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 payments sector. The report sets…
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
The relief is a meaningful and incremental expansion on existing CFTC staff no-action relief on passive technology service provider and independent software vendor…
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:
The agencies plan to clarify product definitions…
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 Comptroller of the Currency (OCC)…
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 Final Rule amends the OCC’s chartering regulations to clarify that national trust banks are not limited to fiduciary activities as defined in the OCC’s…
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 March 2, 2026, the Seventh…
