At the Crossroads of Law, Innovation and Commerce
By: Judith Rinearson and Kai Zhang
The United Kingdom is quickening the pace on the new crypto regulatory regime. The Financial Conduct Authority (FCA) published three papers in quick succession in May 2025: a discussion on key policy positions (DP25/1) and two consultations on detailed rules (CP25/14 and CP25/15). This blog focuses on CP25/15. Please see our separate blogs on the other proposals by going here and here.
Read MoreBy: Judith Rinearson and Kai Zhang
The United Kingdom is quickening the pace on the new crypto regulatory regime. The Financial Conduct Authority (FCA) published three papers in quick succession in May 2025: a discussion on key policy positions (DP25/1) and two consultations on detailed rules (CP25/14 and CP25/15). This blog focuses on CP25/14. Please see our separate blogs on the other proposals by going here and here.
Read MoreBy: Judith Rinearson and Kai Zhang
The United Kingdom is quickening the pace on the new crypto regulatory regime. The Financial Conduct Authority (FCA) published three papers in quick succession in May 2025: a discussion on key policy positions (DP25/1) and two consultations on detailed rules (CP25/14 and CP25/15). This blog focuses on DP25/1. Please see our separate blogs on the other proposals by going here and here.
Read MoreBy: Vivian K. Bridges, Joshua L. Durham, and Ryan T. Carney
On 29 May 2025 the House Financial Services Committee (HFSC) and the House Agriculture Committee (Ag) unveiled their highly anticipated cryptocurrency market structure legislation.
Read MoreBy: Judith Rinearson, Jeremy McLaughlin, Jennifer Crowder, and Joshua Durham
Within the past two months, three states have adopted the Money Transmission Modernization Act (MTMA). The governors of Virginia, Mississippi, and most recently Colorado, signed bills that implement the MTMA, and two other states are currently considering similar bills (Alaska and Nebraska).
Read MoreBy: Grant Bulter, Richard Kerr, and Win Gustin
The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (FRB) have issued new guidance that relaxes previous restrictions and requirements for banks engaging in crypto-related activities. The three agencies have also withdrawn two interagency statements, the Joint Statement on Crypto-Asset Risks to Banking Organizations (3 January 2023) and the Joint Statement on Liquidity Risks to Banking Organizations Resulting from Crypto-Asset Market Vulnerabilities (23 February 2023).
By: Keri E. Riemer, Richard F. Kerr, and Caroline N. Roethlisberger
On the heels of other guidance issued by the US Securities Exchange Commission’s (SEC) Division of Corporation Finance (Division), the Division released a statement (Statement) on 10 April 2025 addressing its views about, among other things, certain disclosure requirements for certain registration forms under the Securities Act of 1933, including Form S-1, and registration forms under the Securities Exchange Act of 1934, including Form 10. As Form S-1 is used by commodity based exchange-traded products (ETPs), including spot bitcoin and ether ETPs, the Division’s guidance will impact such ETPs and others that follow a similar registration path.
Read MoreBy: Jay Lee, Natalie Chow, and Alvin Lam
The Hong Kong Securities and Futures Commission (SFC) has recently unveiled a growth plan for the virtual asset (VA) industry, outlined in a five-pillar roadmap called “A-S-P-I-Re.” This roadmap consists of 12 initiatives organized into five categories: Access, Safeguards, Products, Infrastructure, and Relationships.
Read MoreBy: John ReVeal, Jeremy M. McLaughlin, Jennifer L. Crowder, and Linda C. Odom
On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency transaction reports (CTRs) for currency transactions of more than US$200 but not more than US$10,000. The regular CTR filing requirement for transactions of more than US$10,000 remains in place, but the GTO effectively reduces the threshold for such filings.
Read MoreBy: Cliff C. Histed, and Cheryl L. Isaac
In welcome news, the US Securities and Exchange Commission (SEC) Division of Corporation Finance (Division) yesterday announced “[a]s part of an effort to provide greater clarity” that meme coins do not involve the offer and sale of securities under the federal securities laws. This is to say that transactions in meme coins (as defined below) do not need to be registered with the SEC, but also that buyers and sellers are not protected by federal securities laws. Importantly, the Division limited this interpretation to meme coins that match the following descriptions:
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