• 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

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 CieplakPaul 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 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 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

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. ValdezDouglas 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 FallonArthur S. Long, Benjamin NaftalisParag Patel, Yvette D. ValdezEric 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

The statute’s new regulatory framework for payment stablecoins paves the way for increased digital asset adoption and innovation.

On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), legislation that establishes a regulatory framework for payment stablecoins. It is the first federal legislation on digital assets to be enacted since President Trump issued an executive order aiming to make the US the “crypto capital of the world.”

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