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…
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 enforcement action the FCA has…
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:
The Staff acknowledges both issuer- and third-party-sponsored tokenization models but highlights potential risks…
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 12 February 2026 deadline for firms…
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 Proposal would amend the OCC’s chartering regulations to clarify that national trust banks are not…
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 2025 Crypto Custody Statement clarifies how broker-dealers can maintain “physical possession” of cryptoasset securities under the Customer Protection Rule, although…
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 Proposal would align stablecoin issuer reviews to five statutory factors, including the ability to meet reserve…
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
On 15 December 2025, HM Treasury published the final draft statutory statement (the SI) setting out how activities in relation to qualifying cryptoassets (QCs) will…
