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The guidance defines certain regulated cryptoasset activities broadly, potentially placing onerous authorisation obligations on DeFi and web3 user interfaces and wallets.

By Stuart Davis, Gabriel Lakeman, Brett Carr, Cameron Jones, and Imaan Nazir

On 15 April 2026, the FCA published draft perimeter guidance (in CP 26/13) that, if finalised in its current form, could bring a large segment of global web3 interface providers and wallets within scope of UK cryptoasset licensing requirements. The guidance interprets…

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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…

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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 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 taken following expansion of the financial promotion regime to cryptoassets on 8 October 2023 — although we are aware that…