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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…

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 Circuit granted the banking and credit union trade groups’ unopposed motion to fast-track their appeal, seeking resolution on whether and…

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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…

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Spain follows the trajectory of other EU Member States that have similarly recalibrated their transitional periods since ESMA first published its consolidated list.

By Gabriel Lakeman, Paloma Arizón, and Ivan Pizeta

On 1 December 2025, the European Securities and Markets Authority (ESMA) published an updated list of grandfathering periods decided by EU Member States under the Markets in Crypto-Assets Regulation (MiCA). These transitional periods enable firms currently providing services pursuant to pre-MiCA Virtual Asset Service Provider (VASP) registrations…

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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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As the SEC unveils a strategic plan to modernize securities regulations and drive US leadership in blockchain integration within financial markets, the CFTC launches a corresponding “crypto sprint.”

By Stephen P. Wink, Zachary Fallon, Yvette D. Valdez, Douglas K. Yatter, Jenny Cieplak, Adam Bruce Fovent, Daphne Lambadariou, Connor Jobes, and Deric Behar

On July 31, 2025, Securities and Exchange Commission (SEC) Chair Paul Atkins delivered a significant digital asset policy speech at…

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In the short term, firms are likely to face dual authorisation and significant regulatory requirements.

By Stuart Davis, Gabriel Lakeman, Brett Carr, and Emma Trankeenan

On 10 June 2025, the European Banking Authority (EBA) issued a No Action letter on the relationship between the Markets in Crypto-Assets Regulation (MiCA) and the Payment Services Directive 2 (PSD2).

The No Action letter responds to a request from the European Commission (Commission) in December 2024 that sought clarification on issues…