• Permitted payment stablecoin issuers would be required to establish and maintain written, risk-based customer identification programs tailored to their size and business models.
  • The proposed requirements would include reasonable procedures for verifying customer identity, maintaining verification records, checking customers against relevant government

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 (VA advisory) and virtual asset management (VA management) services (Consultation Conclusions).

This follows their December 2025 consultation conclusions on virtual

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

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