digital wallet

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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 subject certain large non-bank companies offering wallet and payment services to federal regulatory oversight on par with banks and credit unions.

By Jenny Cieplak, Parag Patel, Barrie VanBrackle, and Deric Behar

On November 7, 2023, the Consumer Financial Protection Bureau (CFPB) proposed a rule, Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (the Proposal), to supervise large providers of digital wallets and payment apps. The Proposal aims to ensure that US-based non-bank financial service companies providing digital wallets and payment apps will be subject to the same federal supervisory rules as banks, credit unions, and other financial institutions that the CFPB already supervises.

According to the CFPB, fintech companies and other firms offering novel products and services in the consumer finance space have “blur[ed] the traditional lines of banking and commerce.” The Proposal therefore aims to “enable the CFPB to monitor for new risks to both consumers and the market,” and to “promote fair competition” through consistent enforcement between depository and non-depository institutions.