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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

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  • 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
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An interactive online resource covering the UK’s rapidly evolving cryptoasset landscape.

By Stuart Davis, Gabriel Lakeman, and Emma Trankeenan

Latham & Watkins has launched the UK Cryptoasset Regulatory Tracker, a new online resource that provides cryptoasset businesses with critical information to help them navigate the latest regulatory developments in cryptoassets.

The UK framework for cryptoassets is shifting, with significant regulatory and legislative developments expected in 2026. The UK government has published draft legislation for cryptoassets, which…

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  • The FDIC plans to propose an application process for stablecoin issuance by FDIC-regulated institutions by the end of 2025, and is also collaborating with other banking regulators to develop broader prudential standards for all stablecoin issuers as required under the GENIUS
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The first of what may be a series of crypto no-action letters supports the view that programmatic token distributions serving as network incentives are not securities.

By Jenny Cieplak, Paul M. Dudek, Zachary Fallon, Stephen P. Wink, Hank Balaban, Daphne Lambadariou, and Deric Behar

On September 29, 2025, the SEC Division of Corporation Finance issued a no-action letter (NAL) stating that it would not recommend enforcement against a certain foundation company and blockchain token…