The proposed amendments would strengthen existing transfer agent compliance, risk management, and safeguarding standards; permit the use of distributed ledger technology for recordkeeping; and introduce certain new gatekeeper obligations.
By Jenny Cieplak, Paul M. Dudek, Zachary Fallon, Dan Gibbons, Robert A. Koenig, Elisabeth M. Martin, Stephen P. Wink, Naim Culhaci, Dylan H.
The Proposal would establish two offering exemptions, a conditional safe harbor for investment contracts and broad preemption of state securities laws registration and qualification requirements.
By Paul M. Dudek, Zachary Fallon, Stephen P. Wink, and Deric Behar
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Recent developments signal that the regulatory treatment of cryptoasset lending may be shifting.
By Gabriel Lakeman, Axel Schiemann, Thomas Vogel, and Ivan Pizeta
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Crypto vaults are drawing regulatory attention, with a recent statement by SEC Commissioner Hester Peirce addressing the application of federal securities laws to these structures.
By Jenny Cieplak, Zachary Fallon, Laura Ferrell, Aaron Gilbride, Yvette D. Valdez, Stephen P. Wink, Adam Bruce Fovent, Haley Hohensee, Daphne Lambadariou, Ivan Pizeta, and…
Crypto custody services under the microscope: EU regulators turn their attention to compliance with digital operational resilience rules.
By Stuart Davis, Gabriel Lakeman, and Alain Traill
On 8 July 2026, the European Securities and Markets Authority (ESMA) announced the launch of a Common Supervisory Action (CSA) focusing on the digital operational resilience of cryptoasset service providers (CASPs), with…
ESMA’s statement reinforces that existing EU Member State product intervention measures on binary options apply to event contracts which constitute financial instruments.
By Gabriel Lakeman, José María Alonso, Axel Schiemann, Thomas Vogel, and Paloma Arizon
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The rules cover trading admission and market abuse, stablecoin issuance, regulated activities, and how prudential and FCA Handbook requirements will apply to cryptoasset firms.
By Stuart Davis, Gabriel Lakeman, Brett Carr, Emma Trankeenan, Cameron Jones, and Imaan Nazir
On 30 June 2026, the FCA published a suite of policy statements setting out the final rules…
The proposal seeks to mitigate illicit finance risks while protecting the US financial system and national security interests.
By Arthur S. Long, Parag Patel, Hanyu (Iris) Xie, Pia Naib, and Deric Behar
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Illinois’s interchange fee law is permanently enjoined for most entities after OCC preemption, but a fragmented outcome sets the stage for further appeals.
By Arthur S. Long, Jack McNeily, Parag Patel, Barrie VanBrackle, Pia Naib, and Deric Behar
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Comprehensive regulation to come with further licensing regimes for crypto advisory and asset management services, in addition to crypto dealing and custody.
By Simon Hawkins and Adrian Fong
On 26 May 2026, the Hong Kong Financial Services and Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) issued consultation conclusions on their legislative proposals to regulate virtual asset advisory…
The Proposal would establish principles-based AML/CFT and sanctions compliance standards for stablecoin issuers aligned with FinCEN and OFAC, as well as supervision and enforcement provisions.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
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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
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