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
The request for comment aims to help Treasury devise clear guidelines for stablecoin issuers, promote international coordination, and protect consumers from potential risks.
By Arthur S. Long, Parag Patel, Pia Naib, and Deric Behar
On September 19, 2025, the US Department of the Treasury (Treasury) issued an Advance Notice of Proposed Rulemaking (ANPRM), seeking public comment related to its implementation of the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), a comprehensive framework
The agencies pledge to “usher in a new era of innovation” through a collaboration on rules and exemptions that aims to provide digital asset markets with clarity.
By Stephen P. Wink, Zachary Fallon, Yvette D. Valdez, Douglas K. Yatter, Jenny Cieplak, Adam Bruce Fovent, and Deric Behar
The SEC’s Project Crypto and the CFTC’s Crypto Sprint were launched over the summer to implement the recommendations of the President’s Working Group on Digital Asset Markets
The FDIC seeks to avoid overburdening financial services providers with regulations regarding its logo after assessing market feedback and implementation issues.
By Arthur S. Long, Parag Patel, Pia Naib, Connor Jobes, and Deric Behar
On August 19, 2025, the Federal Deposit Insurance Corporation (FDIC) board of directors approved a proposed rule (the Proposal) that would amend signage requirements for insured depository institutions’ banking channels, including digital and online banking. The Proposal seeks to revise a 2023
DOJ will focus on criminal intent over mere code creation, seeking to balance legal accountability with support for innovation.
By Zachary Fallon, Jack McNeily, Benjamin Naftalis, Parag Patel, Barrie VanBrackle, Eric S. Volkman, Stephen P. Wink, Iris Xie, Douglas K. Yatter, and Deric Behar
On August 21, 2025, Acting Assistant Attorney General of the Criminal Division of the Department of Justice (DOJ), Matthew Galeotti, gave a speech at the American Innovation
The Staff provides the market with additional crypto clarity, holding that liquid staking does not qualify as a security under the Howey test.
By Jenny Cieplak, Zachary Fallon, Yvette D. Valdez, Stephen P. Wink, Hank Balaban,* Adam Bruce Fovent, Daphne Lambadariou, and Deric Behar
On August 5, 2025, the SEC’s Division of Corporation Finance (the Staff or Division) published a Statement on Certain Liquid Staking Activities clarifying that, in the Staff’s view, liquid
Regulators are directed to avoid reputation risk, identify banks that have engaged in unlawful debanking, and take appropriate remedial actions.
By Marc P. Berger, Betty M. Huber, Arthur S. Long, Benjamin Naftalis, Parag Patel, Stephen P. Wink, Douglas K. Yatter, Pia Naib, and Deric Behar
On August 7, 2025, President Trump issued an executive order titled “Guaranteeing Fair Banking for All Americans” (the Order). The Order, described further in an accompanying fact
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
The report reflects collaboration across federal agencies and aims to establish US leadership in digital assets through forward-thinking policy and a clear regulatory framework.
By Jenny Cieplak, Zachary Fallon, Arthur S. Long, Benjamin Naftalis, Parag Patel, Yvette D. Valdez, Eric S. Volkman, Stephen P. Wink, Iris Xie, Douglas K. Yatter, Pia Naib, Adam Bruce Fovent, and Deric Behar
On July 30, 2025, the Presidential Working Group on Digital