- Identifying and quickly closing gaps in their compliance with
FCA Outlines Priorities in Annual Report on Payments Sector
What the CFTC’s New No-Action Relief Really Means for Self-Custody Crypto Wallets
- The relief is a meaningful and incremental expansion on existing CFTC staff no-action relief on passive technology service provider and independent software vendor activities.
- While the no-action relief is specific to Phantom and is not issued as wide-spread market relief, it provides insight
SEC and CFTC Sign Landmark Memorandum of Understanding on Regulatory Harmonization
- The agencies plan to clarify product definitions and oversight through joint interpretations and rulemakings, including a fit-for-purpose regulatory framework for cryptoassets and other emerging technologies.
- The agencies
OCC Issues Proposal to Implement the GENIUS Act
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) issued a Notice of Proposed Rulemaking (the Proposal) to implement the Guiding and Establishing National Innovation for US Stablecoins Act
OCC Finalizes Rule on National Trust Bank Activities
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 regulations.
- The Final Rule is framed as a clarification to reduce regulatory ambiguity, not a change in chartering authority.
Introduction
SEC Staff Issues Statement on Tokenized Securities
- The Staff acknowledges both issuer- and third-party-sponsored tokenization models but highlights potential risks that can affect the latter.
- Regardless of whether distributed ledger technology is used or not, the format used to record
OCC Proposes Regulation to Clarify Permissible Activities for Trust Banks
- The Proposal would amend the OCC’s chartering regulations to clarify that national trust banks are not limited to fiduciary activities as defined by the OCC.
- If adopted as proposed, the Proposal would further increase the attractiveness
SEC Staff Provides Clarity on the Custody of Cryptoasset Securities
- The 2025 Crypto Custody Statement clarifies how broker-dealers can maintain “physical possession” of cryptoasset securities under the Customer Protection Rule, although does not provide further clarity on how broker-dealers can establish “control.”
- Private key protection is crucial, ensuring broker-dealers maintain exclusive
FDIC Issues Proposal to Implement GENIUS Act
- The Proposal would align stablecoin issuer reviews to five statutory factors, including the ability to meet reserve and disclosure requirements, management fitness and competence, and a clear, timely redemption policy.
- The FDIC may deny an application only
SEC Staff Issues No-Action Letter for DTC’s Tokenization Pilot
- The no-action letter permits DTC to run a pilot program for asset tokenization under strict guardrails for a three-year period. DTC has committed to extensive reporting obligations and operational safeguards during the pilot.
- DTC participants with registered wallets will