Digital Assets Hub

Categories: Client Alert, Staking Jurisdiction: United States

Summary: On March 17, 2026, the Securities and Exchange Commission and the Commodity Futures Trading Commission jointly released interpretive guidance (Release No. 33-11412) to address the application of the Federal securities laws to crypto assets and related transactions.

Additional Information: Read more here.

Category: Client Alert Jurisdiction: United States

Summary: The United States is progressing through a patchwork of federal and state measures, but with the adoption of the GENIUS Act, there is increasing comfort that the U.S. will implement a clear regulatory framework. The European Union has adopted a comprehensive, passportable regime for cryptoassets and connected services. The United Kingdom is bringing crypto-assets, including stablecoins, within its regulatory framework. Hong Kong recently implemented a licensing regime for fiat-referenced stablecoin issuers. Singapore is finalizing a stablecoin framework emphasizing reserve quality, par-value redemption and disclosures. The United Arab Emirates supervises issuance, custody, and marketing through a mix of federal oversight and financial free-zone regimes. Other markets—from Japan and Switzerland to Canada, Australia, and Brazil—are likewise codifying rules that vary in scope, timing, and supervisory style.

Additional Information: Read more here.

Categories: Client Alert, Custody Jurisdiction: APAC

Summary: On December 24, 2025, the Financial Services and the Treasury Bureau and the Securities and Futures Commission published consultation conclusions on legislative proposals to regulate virtual asset dealing and custodian service providers in Hong Kong. The Consultation Conclusions follow the FSTB and the SFC’s joint consultations on VA dealing and custodian regimes launched on June 27, 2025.

Additional Information: Read more here.

Category: Client Alert Jurisdiction: United States

Summary: December has brought a range of activity at the SEC and beyond. From the SEC issuing its first enforcement press release in several months, filing multiple actions including one for alleged accounting and disclosure fraud, to US prosecutors announcing criminal action on a matter that first hit the news just in September. But a pair of regulatory releases by the SEC’s Division of Trading and Markets (TM) are also due attention. Our rundown of those releases follows in an area we are keeping watch.

Additional Information: Read more here.

Categories: Client Alert, Tokenization Jurisdiction: Europe

Summary: Our lawyers discuss the U.K. Financial Conduct Authority’s recently published Consultation Paper CP25/28, which sets out proposals and a roadmap to accelerate the adoption of fund tokenization in the U.K. asset management sector.

Additional Information: Read more here.

Category: Exchange Jurisdiction: United States

Summary: On September 2, staff from the SEC's Division of Trading and Markets and the CFTC's Division of Market Oversight and Division of Clearing and Risk issued a joint statement clarifying their views that SEC- and CFTC- registered exchanges are not prohibited from facilitating the trading of certain spot commodity products. This includes CFTC-registered designated contract markets (DCMs), foreign board of trade (FBOTs), and SEC-registered national securities exchanges (NSEs). “Market participants should have the freedom to choose where they trade spot crypto assets. The SEC is committed to working with the CFTC to ensure that our regulatory frameworks support innovation and competition in these rapidly evolving markets,” said SEC Chairman Paul Atkins.

Category: Exchange Jurisdiction: United States

Summary: On August 28, the U.S. Commodity Futures Trading Commission (CFTC) issued an advisory reaffirming the CFTC's foreign board of trade (FBOT) registration framework as a viable path for entities legally organized and operating outside the United States seeking to provide U.S. customers with direct market access to their trading platforms. In an accompanying statement, the agency clarified that the “FBOT registration framework applies to all markets, regardless of asset class, and includes both traditional and digital asset markets.” “American companies that were forced to set up shop in foreign jurisdictions to facilitate crypto asset trading now have a path back to U.S. markets,” said Acting CFTC Chairman Caroline Pham.

Category: Exchange Jurisdiction: United States

Summary: On August 26, U.S. District Judge K. Michael Moore of the Southern District of Florida awarded the SEC over $46 million in combined payments from cryptocurrency mining company, Mining Capital Coin (MCC), and its founders, Luiz Carlos Capuci Jr. and Emerson Sousa Pires, in connection with allegations that Capuci and Pires orchestrated a scheme that defrauded investors through deceptive promotion of cryptocurrency mining and trading activities. Judge Moore also concluded that director and officer bars for both individual defendants were warranted given the allegedly "complex, multi-layered scheme" involving "a persistent pattern of deception.”

Category: Exchange Jurisdiction: APAC

Summary: On August 22, Taiwan prosecutors announced the conclusion of an investigation into a cryptocurrency exchange scam that allegedly defrauded over 1,500 victims of more than NT$1.27 billion ($41million USD). The investigation, led by the Shilin District Prosecutor’s Office, resulted in indictments against 14 individuals allegedly operating under the guise of BitShine, a legal exchange which had passed Taiwan’s Financial Supervisory Commission checks, to conceal the activities of another unlicensed firm, Biying Technology. According to local media reports, the group allegedly utilized various deceptive tactics to mislead victims into investing in cryptocurrency. The group would instruct investors to purchase cryptocurrency using cash, then laundered the funds by converting them into US dollars and transferring them overseas. Investors were also directed to transfer cryptocurrency into specific cold wallets in an effort to obscure the money trail. Between January 2024 and April 2025, prosecutors estimated that the group laundered more than NT$2.3 billion ($75 million USD).

Category: Exchange Jurisdiction: United States

Summary: On August 21, Matthew J. Galeotti, Acting Assistant Attorney General of the DOJ’s Criminal Division, spoke at an event hosted by cryptocurrency advocacy organization American Innovation Project, suggesting that the DOJ will be changing its approach to certain cryptocurrency enforcement actions. “[O]ur Deputy Attorney General, Todd Blanche, has asked me to come here to speak with you about the Justice Department’s focus on even-handed enforcement of the law that allows good actors in the digital asset industry to continue to flourish, while also ensuring bad actors who misuse this technology are held responsible,” said Galeotti. Galeotti’s speech follows an April 2025 memo from Deputy Attorney General Todd Blanche titled “Ending Regulation by Prosecution.” Galeotti spoke about the DOJ’s new approach to charges under the unlicensed money transmitting statute, 18 U.S.C. 1960.

Category: Payments Jurisdiction: United States

Summary: On August 21, Christopher Grover Reynolds and Claudette Reynolds were sentenced to federal prison for their participation in a money laundering conspiracy. The Reynolds siblings allegedly helped Mexican drug traffickers collect proceeds from selling fentanyl, methamphetamine, and marijuana in Ohio and launder those funds to Mexico via cryptocurrency. Christopher Reynolds was sentenced to over six years in prison, while Claudette Reynolds was sentenced to two years in prison.

Category: Exchange Jurisdiction: Europe

Summary: On August 20, the European Union published Commission Delegated Regulation (EU) 2025/885, supplementing the Markets in Crypto-Assets Regulation with detailed Regulatory Technical Standards (RTS) on market-abuse prevention. The RTS prescribes internal arrangements, mandatory reporting templates and cross-border supervisory coordination, sharpening surveillance of crypto asset trading.

Category: Exchange Jurisdiction: United States

Summary: On August 19, in an action brought by the CFTC, Judge Valerie Caproni of the U.S. District Court for the Southern District of New York held EminiFX and its founder and CEO, Eddy Alexandre, jointly and severally liable to pay restitution in the amount of over $228 million. According to the CFTC, EminiFX, a crypto and foreign exchange platform, allegedly defrauded tens of thousands of investors, promising high weekly returns through a so-called “Robo-Advisor Assisted Account” that allegedly deployed automated trading strategies, raising more than $262 million in eight months. In 2023, Alexandre was sentenced to nine years in prison in a parallel criminal case brought by DOJ.

Category: DeFi Jurisdiction: United States

Summary: On August 19, Michelle Bowman, Vice Chair for Supervision, delivered a speech at the Wyoming Blockchain Symposium emphasizing the need for a careful and coordinated regulatory approach to stablecoins and other digital assets and highlighting the potential risks stablecoins pose to financial stability, consumer protection, and the broader payments system. Bowman said: “Regulators must recognize the unique features of these new assets and distinguish them from traditional financial instruments or banking products… It is essential that banks and regulators are open to engaging in new technologies and departing from an overly cautious mindset.”

Categories: DeFi, Exchange, Issuance Jurisdiction: United States

Summary: On August 18, the U.S. Department of the Treasury issued a Request for Comment as required by the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act). The GENIUS Act, which was signed into law in July 2025, creates a comprehensive regulatory framework for stablecoins in the United States. The GENIUS Act directs Treasury to seek public comment to identify methods, techniques, and strategies that financial institutions use or have the potential to use to detect illicit activity involving digital assets. Four specific technologies on which Treasury seeks comments are: application program interfaces, artificial intelligence, digital identity verification, and use of blockchain technology and monitoring. Public comments must be received on or before October 17, 2025.

Category: Lending Jurisdiction: United States

Summary: On August 15, the U.S. Federal Reserve Board announced that it will sunset its Novel Activities Supervision Program (the NASP), which was established in 2023 to oversee banks’ involvement in digital assets, distributed ledger technology, and fintech partnerships. The Federal Reserve Board explained that it has strengthened its understanding of those activities, related risks, and risk management practices and that it will integrate that knowledge back into the standard supervisory process. The Federal Reserve Board rescinded its 2023 supervisory letter creating the NASP.

Category: Exchange Jurisdiction: APAC

Summary: On August 15, the Hong Kong Securities and Futures Commission (SFC) issued a circular to elaborate on its expected standards for the safe custody of virtual assets by SFC-licensed virtual asset trading platform operators and their associated entities. The circular sets out the SFC’s expectations on senior management responsibilities, client cold wallet infrastructure and operation, use of third-party wallet solutions, and real-time threat monitoring, among other things. These standards will also form the core expectations for future SFC-licensed virtual asset custodians.

Category: Exchange Jurisdiction: United States

Summary: On August 14, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced new sanctions against the Russia-based virtual currency exchange Garantex and its alleged successor Grinex for facilitating transactions involving illicit actors, including ransomware groups and darknet markets. OFAC designated Garantex for processing over $100 million in transactions linked to illicit finance and Grinex, which was created by Garantex employees to avoid sanctions levied on Garantex. John K. Hurley, the Under Secretary of the Treasury for Terrorism and Financial Intelligence, said that “[d]igital assets play a crucial role in global innovation and economic development, and the United States will not tolerate abuse of this industry to support cybercrime and sanctions evasion. Exploiting cryptocurrency exchanges to launder money and facilitate ransomware attacks not only threatens our national security, but also tarnishes the reputations of legitimate virtual asset service providers.”

Category: Custody Jurisdiction: United States

Summary: On August 13, the DOJ unsealed six warrants in the U.S. District Courts for the Eastern District of Virginia, the Central District of California, and the Northern District of Texas authorizing the seizure of over $2.8 million in cryptocurrency, $70,000 in cash, and a luxury vehicle from Ianis Aleksandrovich Antropenko. Antropenko was indicted in the U.S. District Court for the Northern District of Texas for criminal charges related to computer fraud and abuse and money laundering. As alleged in the unsealed warrants, the cryptocurrency and other assets are proceeds of (or were involved in laundering the proceeds of) ransomware activity.

Categories: DeFi, Payments Jurisdiction: United States

Summary: On August 12, the DOJ announced that Do Kwon, co-founder and CEO of Terraform Labs, pleaded guilty to wire fraud and securities fraud charges in the U.S. District Court for the Southern District of New York. The government alleged that Kwon touted Terraform as a decentralized financial system that leveraged proprietary blockchain technology to offer its own cryptocurrencies (TerraUSD and Luna), payment system, stock market, and savings bank but that its core products did not work as advertised and were manipulated to create the illusion of a functioning and decentralized financial system.

Category: Payments Jurisdiction: United States

Summary: On August 12, the DOJ announced that two Estonian nationals, founders of the cryptocurrency mining service HashFlare, were sentenced in the U.S. District Court for the Western District of Washington for their roles in a $577 million alleged cryptocurrency fraud and money laundering scheme. According to DOJ, the defendants operated fraudulent investment platforms, including HashFlare, that solicited funds from investors worldwide by promising shares of profits generated from mining cryptocurrency and misrepresenting the use of investor funds. The judge sentenced both defendants to time served (about sixteen months’ imprisonment). On August 26, prosecutors filed a notice to appeal the sentence to the Ninth Circuit.

Category: Payments Jurisdiction: United States

Summary: On August 11, the Department of Justice announced coordinated actions against the BlackSuit (Royal) Ransomware group conducted by the Homeland Security Investigations (HSI), the U.S. Secret Service, IRS Criminal Investigation (IRS-CI), the FBI, and various international law enforcement agencies. According to the DOJ press release, the BlackSuit Ransomware group deploys ransomware, extorts victims (including numerous critical infrastructure sectors such as government facilities and public health), and launders proceeds of those activities in cryptocurrency. The coordinated actions conducted by the government included the unsealing of a warrant for the seizure of virtual currency valued at more than $1 billion at the time of the seizure.

Categories: Issuance, Exchange Jurisdiction: Europe

Summary: On August 11, the UK Financial Markets Law Committee (FMLC) published a response to the Financial Conduct Authority (FCA's) consultation on proposed rules and guidance for firms carrying on the regulated activities of issuing qualifying stablecoins and safeguarding qualifying cryptoassets. The response flags material legal uncertainties in the FCA’s proposed stablecoin and cryptoasset custody regime.

Category: Payments Jurisdiction: United States

Summary: On August 7, the New York State Department of Financial Services (NYDFS) announced a settlement requiring Paxos Trust Company (Paxos) to pay a $26.5 million penalty to New York for “failure to conduct sufficient due diligence” of its former partner and “systemic failures in Paxos’s anti-money laundering program.” As part of the settlement, Paxos also agreed to invest $22 million to improve its compliance program and remediate deficiencies pursuant to a plan approved by NYDFS.

Categories: Exchange, Lending Jurisdiction: United States

Summary: On August 7, President Trump signed an executive order titled “Guaranteeing Fair Banking for All Americans,” which mandates a probe into whether banks have discriminated against certain industries, including cryptocurrency companies. The order requires customer onboarding and retention decisions to be made on the basis of “individualized, objective, and risk-based analyses,” mandates the removal of "reputation risk" and similar concepts from regulatory and supervisory materials, and directs agencies to clarify compliance obligations. On August 7, 2025, Gibson Dunn published a client alert discussing the executive order and analyzing its implications on financial institutions.

Categories: Issuance, Exchange Jurisdiction: United States

Summary: On August 7, the SEC and Ripple Labs, Inc., Bradley Garlinghouse, and Christian A. Larsen filed a Joint Stipulation of Dismissal that dismissed the SEC’s appeal and Ripple’s cross-appeal, resolving the SEC’s civil enforcement action against the defendants for allegedly selling unregistered securities. The cross-appeals followed a final judgment by the district court that imposed a $125 million civil penalty against Ripple and an injunction prohibiting Ripple from violating the registration provisions of the Securities Act of 1933. The final judgment will remain in effect.

Category: Payments Jurisdiction: United States

Summary: On August 6, 2025, a jury in the U.S. District Court for the Southern District of New York found Roman Storm, the co-founder of Tornado Cash, guilty of conspiracy to operate an unlicensed money transmitting business. That charge carries a maximum sentence of five years in prison. The jury failed to reach a unanimous verdict on charges of conspiracy to commit money laundering and to violate the International Emergency Economic Powers Act.

Category: Staking Jurisdiction: United States

Summary: On August 5, 2025, the SEC provided guidance noting its position that certain forms of liquid staking fall outside the scope of securities laws. This marks a departure from the agency’s previous enforcement position. The guidance clarifies that receipt tokens representing staked digital assets are not securities when the underlying assets are not securities and the staking activities are “ministerial or administrative” and not driven by entrepreneurial effort.

Category: Staking Jurisdiction: United States

Summary: On August 5, the SEC Division of Corporate Finance issued a statement providing the Staff’s views on the application of federal securities laws to “liquid staking.” Liquid staking is the process of staking digital assets through a software protocol or service provider and receiving a “liquid staking receipt token” to evidence the staker’s ownership of the staked digital assets and any rewards that accrue to them. The SEC’s statement explained that, depending on the facts and circumstances, the liquid staking activities covered in the statement do not involve the offer and sale of securities within the meaning of Section 2(a)(1) of the Securities Act of 1933 or Section 3(a)(10) of the Securities Exchange Act of 1934. Accordingly, participants in liquid staking activities do not need to register with the Commission transactions under the Securities Act or fall within one of the Securities Act’s exemptions from registration in connection with these liquid staking activities.

Categories: Exchange, DeFi Jurisdiction: United States

Summary: On August 1, CFTC Acting Chairman Caroline D. Pham announced that the CFTC will kick off a “crypto sprint” to start implementing President Trump’s Working Group on Digital Asset Markets report (the Report). The report calls for policies, including ensuring access to open public blockchain networks, ensuring fair access to banking services for the crypto industry, providing regulatory clarity, and protecting against the risk of central bank digital currencies (CBDCs) by prohibiting their establishment in the U.S. As part of the crypto sprint, on August 4, the CFTC requested comments on its initiative to enable trading “spot crypto asset contracts” on CFTC-registered futures exchanges by August 18. On August 5, 2025, Gibson Dunn published two relevant client alerts: (1) providing a sequential discussion of the President’s Working Group on Digital Asset Markets’ description of the intersection of digital assets and illicit finance in its Report; and (2) providing a discussion on the Report and other current developments in digital asset regulation related to market infrastructure, the banking system and broader payment activities, and taxation of digital assets. On August 21, 2025, CFTC Acting Chairman Caroline D. Pham announced that the CFTC will begin broader stakeholder engagement by seeking industry feedback and suggestions on all of the recommendations made in the Report, beyond just spot crypto trading. Members of the public may provide written input to the CFTC by October 20, 2025, by submitting a comment on the CFTC website.

Category: Exchange Jurisdiction: APAC

Summary: On August 1, the Commercial Affairs Department (CAD) of the Singapore Police Force, and the Monetary Authority of Singapore (MAS) announced that they were investigating AmazingTech Pte Ltd (ATPL), the operator of the cryptocurrency exchange known as Tokenize Xchange. Tokenize Xchange, which previously operated under a temporary licensing exemption, was required to cease operations in Singapore following the rejection of its license application with the MAS. Following customer complaints about delayed withdrawals, the MAS allegedly found indications that Tokenize Xchange did not have sufficient assets to meet its customers’ claims and that it might not have segregated its customers’ assets from its own assets. On July 31, 2025, a director of ATPL was also charged in court with the offense of fraudulent trading

Category: Tokenization Jurisdiction: APAC

Summary: The Hong Kong government has announced that the Stablecoins Ordinance will take effect August 1, 2025. The Ordinance will introduce a framework for the supervision of stablecoin activities and introduce a licensing regime for regulated stablecoin activities in Hong Kong. The Hong Kong Monetary Authority has also launched two consultations on the detailed regulatory requirements of the stablecoin regime, including the guideline on supervision of licensed stablecoin issuers and anti-money-laundering and counter-financing-of-terrorism requirements for regulated stablecoin activities. Gibson Dunn previously published a client alert on the latest developments.

Categories: Custody, Exchange, Payments Jurisdiction: United States

Summary: On July 31, 2025, SEC Chair Atkins delivered a major policy address at the America First Policy Institute in Washington, D.C., unveiling “Project Crypto.” Project Crypto is a Commission-wide initiative to create “clear and simple rules of the road for crypto asset distributions, custody, and trading.” Among other things, Chair Atkins stated that “most crypto assets are not securities,” and that “it should not be a scarlet letter” for a digital asset “to be deemed a security.” For digital assets that are securities, the Chair has asked SEC staff “to propose purpose-fit disclosures, exemptions, and safe harbors, including for so-called ‘initial coin offerings,’ ‘airdrops,’ and network rewards.” The Chair also announced several other crypto policies and initiatives, including taking steps to increasing consumer choice in how they custody and trade digital assets, improving the horizontal integration of crypto product offerings into “super-apps,” integrating traditional securities markets into on-chain systems, and creating an innovation exemption for novel uses of blockchain technology.

Categories: Exchange, Payments Jurisdiction: United States

Summary: On July 31, 2025, a divided Second Circuit panel overturned the wire fraud and money laundering convictions for Nathaniel Chastain. Chastain was a product manager at OpenSea, a marketplace for non-fungible tokens (NFTs). In May 2023, a jury found Chastain guilty, based on accusations that he allegedly traded on confidential information about which NFTs would be featured on OpenSea’s homepage. The Court reversed Chastain’s conviction, holding that the trial judge erred by incorrectly instructing the jury that the featured NFT information was a property interest covered by the wire fraud statute. The Court held that there was no evidence in the record that the information about which NFTs would be featured had any commercial value to OpenSea. Judge Jose Cabranes dissented in part in a separate opinion.

Categories: Exchange, Issuance, Payments Jurisdiction: United States

Summary: On July 30, 2025, in furtherance of President Trump’s Executive Order 14178 (Strengthening American Leadership in Digital Financial Technology), the President’s Working Group on Digital Asset Markets released a 168-page report outlining recommendations for digital-asset regulation and legislation. Broadly, the report provides a roadmap to try to bring more digital-asset-focused businesses to the United States. The report recommends that various regulatory agencies, including the SEC and CFTC, use their existing authorities to enable the trading of digital assets at the federal level, reduce regulatory gaps, and allow innovative financial products to reach consumers. Other recommendations include proposed legislation by Congress to modernize bank regulation for digital assets, strengthen the role of the U.S. dollar in the digital assets industry, combat illicit finance, and increase predictability in digital-asset taxation.

Categories: Exchange, Payments Jurisdiction: United States

Summary: On July 30, 2025, two founders and developers of Samourai Wallet, a cryptocurrency service that allegedly facilitated non-traceable private crypto transactions, pled guilty in the U.S. District Court for the Southern District of New York to one count each of conspiracy to operate an unlicensed money transmitting business. The defendants are scheduled to be sentenced in early November.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On July 29, 2025, Chief U.S. District Judge Richard Seeborg of the Northern District of California sentenced AML Bitcoin founder and CEO Rowland Marcus Andrade, to seven years in federal prison in connection with a multimillion-dollar cryptocurrency fraud scheme. In March 2025, a jury convicted Andrade of wire fraud and money laundering. The court also ordered a hearing on September 16, 2025, to determine the amount of forfeiture and the amount of restitution owed to victims of Andrade’s crimes.

Category: Issuance Jurisdiction: APAC

Summary: On July 29, the Hong Kong Monetary Authority (HKMA) published (i) the Guideline on Supervision of Licensed Stablecoin Issuers, (ii) the Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (for Licensed Stablecoin Issuers), (iii) the Explanatory Note on Licensing of Stablecoin Issuers, and (iv) the Explanatory Note on Transitional Provisions for Pre-existing Stablecoin Issuers. These were published to implement the regulatory regime for stablecoin issuers under Hong Kong’s Stablecoins Ordinance, effective August 1, 2025, which provides the HKMA with investigatory and enforcement powers as to stablecoins. Parties that are sufficiently prepared to apply for a license and who wish to have their application considered early should submit the application to the HKMA by September 30, 2025.

Categories: Issuance, Payments Jurisdiction: APAC

Summary: On July 23, 2025, the Chief Executive of the Hong Kong Monetary Authority (HKMA) announced that the HKMA will be releasing the ‘Explanatory Note on Licensing of Stablecoin Issuers’ by the end of July, which will outline the HKMA’s arrangements for accepting and processing applications for a stablecoin issuance license. The HKMA will also publish final versions of the ‘Guideline on Supervision of Licensed Stablecoin Issuers’ and ‘Guideline on Anti-Money Laundering and Counter-Financing of Terrorism (For Licensed Stablecoin Issuers)’ to provide interest applicants with additional guidance on the regulatory framework by the end of July.

Categories: Exchange, Payments Jurisdiction: United States

Summary: On July 22, 2025, the U.S. Department of Justice filed a civil forfeiture complaint in the U.S. District Court for the District of Columbia seeking to forfeit approximately $2 million dollars in cryptocurrency allegedly connected to a Gaza-based money transfer business that DOJ alleged was involved in financially supporting the terrorist group Hamas.

Categories: Custody, Payments Jurisdiction: United States

Summary: On July 22, 2025, the DOJ filed a civil forfeiture complaint in the U.S. District Court for the Western District of Washington, seeking the forfeiture of cryptocurrency valued at approximately $7.1 million seized as part of an investigation. According to DOJ, the perpetrators allegedly obtained approximately $97 million in funds by convincing victims to send funds to what was represented as escrow accounts to purchase oil tank storage. The funds were allegedly then moved to different financial institutions, and then used to purchase cryptocurrency. Beyond the civil forfeiture action, Geoffrey K. Auyeung was indicted in August 2024 as a coconspirator.

Categories: Exchange, Issuance, Payments Jurisdiction: United States

Summary: On July 21, 2025, William McNeilly of New Haven, CT pleaded guilty in the U.S. District Court for the District of Connecticut to charges that he allegedly operated an unlicensed money transmitting business, which exchanged more than $1 million in U.S. currency for cryptocurrency on behalf of customers throughout the U.S., knowing some of the funds involved in his illegal business were derived from fraud schemes.

Categories: Custody, Issuance, Payments Jurisdiction: United States

Summary: On July 18, 2025, President Trump signed the GENIUS Act, passed with bipartisan votes in both the House and the Senate, into law. The GENIUS Act requires stablecoins to be fully backed by U.S. dollars or similarly liquid assets, mandate annual audits for issuers with a market capitalization of more than $50 billion, and establish guidelines for foreign issuance. It requires issuers to make monthly, public disclosures of the composition of their reserves. Stablecoin issuers must comply with strict marketing rules to protect consumers from deceptive practices. And issuers are forbidden from making misleading claims that their stablecoins are backed by the U.S. government, federally insured, or legal tender.

Categories: Issuance, Tokenization Jurisdiction: Middle East

Summary: On July 17, 2025, the Dubai Land Department celebrated the success of its Real Estate Tokenization Initiative, marking the issuance of the world’s first Property Token Ownership Certificate following the full sale of the inaugural tokenized project on Prypco Mint, a VARA-licensed platform. The project attracted 224 investors from 44 nationalities, 70% of whom were first-time participants in Dubai’s property market.

Category: Issuance Jurisdiction: United States

Summary: On July 17, 2025, the House passed the Anti-CBDC Act. By its terms, the bill aims to prevent the Federal Reserve from developing or issuing a retail CBDC or a “digital dollar” without explicit congressional authorization. The Act prevents the Federal Reserve from offering products or services directly to individuals or maintaining accounts on their behalf, from issuing a CBDC directly or indirectly to an individual, and from using a CBDC to implement monetary policy.

Categories: Payments, Custody, Exchange, Tokenization Jurisdiction: Europe

Summary: On July 11, 2025, the ESMA issued a set of guidelines setting out criteria for assessing the knowledge and competence of employees of CASPs under MiCA. The guidelines set out requirements on minimum professional qualifications, experience and understanding of crypto-asset volatility, cybersecurity and other risks which are applicable to staff who provide information or advice about crypto-assets or crypto-asset services. The guidelines are set to enter into force six months after the publication of translations into the national languages of EU members states on the ESMA website.

Categories: Custody, Exchange, Payments, Tokenization Jurisdiction: Europe

Summary: On July 11, 2025, the European Securities and Markets Authority (“ESMA”) issued a statement warning that authorized crypto-asset service providers (“CASPs”) offering both products regulated under the Markets in Crypto Assets Regulation (“MiCA”) and other, unregulated products expose investors to significant, often unrecognized, risks. The ESMA notes that investors may wrongly perceive that the regulatory safeguards attached to MiCA-regulated products automatically extend to unregulated offerings. The ESMA disapproves of CASPs engaging in such activities and has provided a detailed “dos and don’ts” checklist setting out its expectations.

Categories: Custody, Exchange, Payments, Tokenization Jurisdiction: United States

Summary: On July 10, 2025, the Senate voted 50–45 to confirm Jonathan Gould, the former OCC chief counsel, as the next Comptroller of the Currency. Gould’s extensive resume, spanning senior roles at the OCC, the Senate Banking Committee, and private industry, drew praise from industry groups and key legislators who emphasized his readiness to “hit the ground running” and safeguard both safety-and-soundness and fair access to financial services. Gould has pledged to depoliticize bank supervision by tailoring oversight to institutions’ risk profiles, curbing “debanking” based on reputational concerns, and ensuring lawful cryptocurrency activities can be conducted safely within the regulated system.

Categories: DeFi, Exchange Jurisdiction: United States

Summary: On July 10, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) formally rescinded the “DeFi broker” reporting rule. Finalized in December 2024, the rule had dramatically expanded the regulatory definition of “broker” to cover decentralized exchanges and other non-custodial service providers, obligating them to gather and furnish user names, addresses and transaction details to the IRS. This year, Congress and the President nullified the rule under the Congressional Review Act (CRA). This rescission implements the CRA legislation.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On July 9, SEC Commissioner Hester Peirce issued a public statement stating that tokenized equities are securities and therefore must comply with existing federal securities laws. Acknowledging the industry’s growing interest in blockchain-based trading of traditional stocks, Peirce emphasized that blockchain technology “does not have magical abilities to transform the nature of the underlying asset.” Peirce’s statement reiterates that issuers and intermediaries distributing tokenized securities must satisfy all disclosure and registration obligations.

Categories: Exchange, Rewards Jurisdiction: United States

Summary: According to press reports on July 5, 2025, the U.S. Secret Service has recovered nearly $400 million in cryptocurrency via seizures and forfeiture orders. This effort has been led by the Global Investigative Operations Center in collaboration with the FBI and U.S. Attorney's offices around the country. The agency has tracked funds from alleged scams, including fake crypto investment platforms, and has also conducted training sessions in over 60 countries to help local law enforcement combat crypto crimes.

Category: Payments Jurisdiction: United States

Summary: On July 2, 2025, the DOJ filed a civil forfeiture complaint in the U.S. District Court for the District of Columbia to recover approximately $40,300 in cryptocurrency that was allegedly stolen through a business email compromise scheme. According to the complaint, the perpetrators allegedly obtained over $250,000 from a donor by impersonating the co-chair of President Trump’s Inaugural Committee. The perpetrators allegedly requested the victim send money to an imposter email account; once the funds were sent, the perpetrators laundered the funds to other addresses.

Category: Custody Jurisdiction: United States

Summary: On July 1, 2025, the Treasury Inspector General for Tax Administration, which oversees the Department of Treasury, released a report criticizing the IRS Criminal Investigation division for not adhering to internal guidelines in seizing and holding cryptocurrency assets between December 2023 and January 2025. The report highlighted failures in following seizure memorandum requirements, which include documenting addresses, dates, and amounts of confiscated cryptocurrency. Recommendations for improvement include familiarizing personnel with guidelines, establishing an inventory system for tracking digital assets, and updating internal procedures.

Category: Payments Jurisdiction: United States

Summary: On June 30, Connecticut Governor Ned Lamont signed House Bill 7082 into law, prohibiting the use of digital assets in state government operations. The legislation specifically bans the state government from “accepting or requiring payment in the form of virtual currency” or “purchasing, holding, investing in or establishing” a crypto reserve. The law also sets requirements for crypto money transmission licensees in Connecticut, with key provisions taking effect on October 1, 2025. This move contrasts with other states exploring the establishment of Bitcoin reserves.

Categories: Custody, Exchange, Issuance, Payments, Tokenization Jurisdiction: APAC

Summary: On June 30, 2025, the Monetary Authority of Singapore (MAS) published its response to an earlier consultation on proposed amendments to AML/CFT Notices and Guidelines which apply to financial institutions such as capital markets intermediaries and digital payment token service providers (FI), and variable capital companies (VCC). The response confirms, among other things, that FIs and VCCs may adopt a risk-based approach in the corroboration of source of wealth where such checks are required. The response also provides further guidance on the timeline for filing suspicious transaction reports and regulatory expectations in relation to the conduct of know-your-customer checks on trusts and legal arrangements.

Categories: Exchange, Issuance, Tokenization Jurisdiction: United States

Summary: On June 30, Ripple Labs (Ripple) CEO stated that Ripple plans to drop the appeal of its landmark case with the SEC, ending the matter after a New York federal judge refused to sign off on a settlement that would have reduced Ripple’s $125 million penalty to $50 million, and lifted an injunction restricting certain XRP token sales. The appeals related to a mixed summary judgement where the court found that sales of XRP tokens to sophisticated investors were unregistered securities transactions, but that secondary sales were not.

Categories: Issuance, Payments Jurisdiction: Europe

Summary: On June 27, 2025, the European Commission adopted Delegated Regulation C(2025)602, introducing regulatory technical standards (RTS) that prescribe the minimum contents of liquidity-management policies and procedures for issuers of asset-referenced and e-money tokens under MiCA. The standards require management of liquidity risk, contingency planning and stress-testing, drawing on the Basel framework, and other relevant frameworks. If approved by the European Council and Parliament, the rules will apply twenty days after publication in the Official Journal of the EU.

Categories: Custody, Exchange Jurisdiction: APAC

Summary: On June 27, 2025 the Financial Services and the Treasury Bureau and the Securities and Futures Commission (SFC) launched a consultation to introduce regulatory regimes for virtual asset (VA) dealing and custodian service providers. The proposals aim to empower the SFC to license and supervise VA dealers and VA custodians, as well as enforce relevant regulations.

Categories: Custody, Issuance, Payments Jurisdiction: United States

Summary: On June 26, the Conference of State Bank Supervisors (CSBS) issued guidance on the treatment of virtual currency when calculating a money-transmitter licensee’s tangible net worth, under the Money Transmission Modernization Act (MTMA). The MTMA is designed to create a consistent set of nationwide standards for tangible net worth (capital) and other requirements applicable to the regulation and supervision of state money transmitters. The advisory guidance is intended to encourage transparency and consistency in implementation of the MTMA. This guidance is the first guidance issued under the MTMA, which according to the guidance has been adopted by 27 States.

Categories: Custody, Issuance, Payments Jurisdiction: Middle East

Summary: On June 25, 2025, the Financial Services Regulatory Authority (“FSRA”) of the Abu Dhabi Global Market implemented amendments to its digital asset framework, following a consultation conducted earlier this year. Changes include a revised process for approving Accepted Virtual Assets (AVAs), updated capital requirements and fees for virtual asset firms, a new product intervention power, and a formal ban on privacy tokens and algorithmic stablecoins.

Category: Crypto ATM Jurisdiction: United States

Summary: On June 25, the California Department of Financial Protection and Innovation (DFPI) announced that Coinme Inc., a crypto kiosk operator, has agreed to pay $300,000 to resolve findings of alleged non-compliance with the state’s Digital Financial Assets Law (DFAL), marking the first enforcement action under the DFAL. According to the DFPI, Coinme violated the DFAL’s transaction limits and failed to include certain disclosures on receipts, as mandated by law. DFAL was enacted in 2023, and was intended to mitigate risks associated with using digital-asset-transaction kiosks.

Categories: Custody, Lending Jurisdiction: United States

Summary: On June 25, the Federal Housing Financing Agency directed Fanne Mae and Freddie Mac to consider accepting a borrower’s crypto holdings as an asset for reserves when assessing risks in single-family home loans, without requiring conversion of crypto assets to U.S. dollars. The potential policy change is intended to encourage banks to expand how they evaluate creditworthiness of homebuyers, as banks have not typically considered crypto holdings until they were sold.

Categories: Issuance, Exchange Jurisdiction: United States

Summary: During a June 25 panel, SEC Commissioner Hester Peirce acknowledged the crypto industry’s interest in in-kind creation and redemption of crypto ETFs, stating that SEC sign off is “certainly on the horizon at some point.” For redemptions of crypto ETFs under the current cash model approach, firms are required to move the cryptocurrency out of storage, sell it immediately for cash, and then give the cash back to the investor. Proponents suggest that in-kind redemption would allow funds to trade more efficiently. Nasdaq filed a From 19b-4 on behalf of BlackRock in January 2025 to pursue in-kind redemption.

Categories: Tokenization, Issuance Jurisdiction: United States

Summary: On June 24, the U.S. Senate Banking Subcommittee on Digital Assets hosted a hearing called “Exploring Bipartisan Legislative Framework for Digital Assets Market Structure.” The panelists urged Congress to pass digital asset legislation soon, and expressed concerns that delays in passing legislation may result in the U.S. ceding authority to legal regimes from other countries. Senators outlined foundational principles, including clear distinctions between digital securities and commodities as well as anti-money laundering safeguards.

Category: Jurisdiction: United States

Summary: On June 24, Judge Seeborg of the Northern District of California denied a motion for a new trial filed by founder and CEO of NAC Foundation Rowland Marcus Andrade. Andrade had previously been convicted at trial of fraud and money laundering related to his allegedly defrauding investors through making false statements about his company’s technology and its business deals.

Categories: Tokenization, Issuance Jurisdiction: United States

Summary: On June 18, the U.S. Department of Justice filed a civil forfeiture complaint in the U.S. District Court for the District of Columbia against more than $225.3 million in cryptocurrency. The complaint alleges that the cryptocurrency addresses holding this crypto were part of a sophisticated blockchain-based money laundering network that executed hundreds of thousands of transactions and was used to conceal the nature, source, control, and ownership of proceeds derived from cryptocurrency investment fraud. According to the complaint, the operators dispersed proceeds across an extensive group of cryptocurrency addresses and accounts on the blockchain to conceal the source of the funds.

Category: Jurisdiction: United States

Summary: On June 18, New York State officials, including the New York Attorney General and Superintendent of the New York State Department of Financial Services announced that a multi-agency, long-term investigation resulted in the disruption of an alleged cryptocurrency investment scam that used social media ads to target Russian-speaking residents of New York and other states. After learning of the investigation, a social media site shut down more than 700 accounts associated with the advertiser promoting the alleged scam, and court orders have led to the seizure of $140,000 worth of cryptocurrency and the freezing of approximately $300,000 worth of cryptocurrency.

Category: Payments Jurisdiction: United States

Summary: Roman Storm, co-founder of Tornado Cash (a mixer that operates on the Ethereum blockchain), is raising funds ahead of his federal criminal trial, which is scheduled to begin on July 14 in the U.S. District Court for the Southern District of New York. In 2023, Storm was charged with conspiracy to commit money laundering, operating an unlicensed money transmitting business, and sanctions violations, for operating Tornado Cash. The Ethereum Foundation, which manages and supports the Ethereum blockchain ecosystem, has made a $500,000 donation to Storm’s defense. In support of Storm’s defense, venture capital firm Paradigm also filed an amicus brief urging the court to adopt jury instructions that state that Storm cannot be convicted unless prosecutors prove Storm knowingly operated a money-transmitting business.

Categories: DeFi, Custody, Exchange Jurisdiction: APAC

Summary: On June 17, a South Korean court acquitted Haru Invest CEO Lee Hyung-soon of fraud charges. The Haru CEO faced fraud allegations when the company abruptly closed user withdrawals in June 2023 and shut down its office. During his court trial last year, Lee was stabbed in the neck four times by someone who claimed that he suffered heavy losses due to Hyung-soon’s actions. The final judgment noted that the executives’ actions were in response to financial pressures rather than a result of fraudulent intent.

Categories: Payments, Tokenization, Custody, Issuance Jurisdiction: United States

Summary: On June 17, in a 68-30 vote, the U.S. Senate passed Guiding and Establishing National Innovation for U.S. Stablecoins (Genius) Act. Led by Senator Bill Hagerty (R-TN), the legislation would establish a regulatory framework for stablecoins in the United States. The bill received bipartisan support, with several Democrats joining most Republicans in supporting the bill. The bill now moves to the House, which the President has urged to pass the bill without “delays” or “add-ons.” The House could vote on the Genius Act at the same as the Clarity Act, the House’s crypto market-structure bill.

Categories: Issuance, Custody, Tokenization Jurisdiction: APAC

Summary: On June 14, the National Assembly of Vietnam approved the Law on Digital Technology Industry, bringing digital assets under regulatory oversight. The legislation, which will take effect on January 1, 2026, recognizes digital assets and lays the groundwork for broader digital innovation across the country. The law also mandates cybersecurity and anti-money laundering safeguards, aligned with international norms.

Category: Jurisdiction: United States

Summary: On June 13, the founder of Gotbit, a crypto-focused hedge fund, was sentenced to 8 months in prison in the District of Massachusetts. He allegedly oversaw a wash-trading scheme, which involved manipulating cryptocurrency markets to create artificial trading volume for multiple cryptocurrency companies.

Categories: Exchange, Issuance, Tokenization Jurisdiction: United States

Summary: On June 13, the SEC announced four senior appointments, including two officials with experience in digital assets. Effective June 17, Jamie Selway assumed the role of Director of the Division of Trading and Markets. Selway was previously a partner at Sophron Advisors. On July 8, Brian T. Daly will take over as Director of the Division of Investment Management. Daly was previously a partner in the investment management practice of Akin Gump Strauss Hauer & Feld LLP.

Category: Exchange Jurisdiction: APAC

Summary: On June 12, 2025, the Hong Kong Securities and Futures Commission (SFC) launched a consultation which proposes to amend the Securities and Futures Ordinance (Cap. 571) and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) to restrict unregulated entities from improperly adopting names that may give the public a false impression that they are regulated entities. This includes restricting unregulated entities from calling themselves a “cryptocurrency exchange” or “virtual asset trading platform” (among others) as that could mislead the public into thinking that such entities are conducting activities regulated by the SFC. The SFC’s proposed amendments would also restrict the use of certain titles that may imply that a business is associated with an established or well-known exchange, virtual asset trading platform, or other similar operation, when it is not in fact so associated.

Categories: Tokenization, Issuance Jurisdiction: APAC

Summary: On June 12, Assistant commissioner Mario Wong Ho-yin of the Customs and Excise Department of Hong Kong announced that customs official would be partnering with academics, regional finance professionals, and law enforcement to counteract money-laundering schemes. This partnership comes amid a rise in alleged money laundering schemes involving crypto in Hong Kong.

Categories: Custody, Exchange, DeFi Jurisdiction: United States

Summary: On June 12, the SEC rescinded a slate of 14 rules that the agency proposed under the Biden Administration, including two related to crypto custody and exchanges. One of the relevant rules was Rule 3b-16, which would have expanded the definition of “exchange” to include decentralized finance protocols and tightened crypto custody standards for investment advisers. The SEC also rescinded a proposed custody rule that would have brought digital assets more explicitly under SEC custody requirements.

Category: Custody Jurisdiction: United States

Summary: On June 10, Connecticut enacted the final text of a bill prohibiting state and local governments in Connecticut from investing in crypto or establishing a crypto reserve. In contrast, on June 21, Texas became the third state, following Arizona and New Hampshire, to pass legislation establishing a statewide strategic Bitcoin reserve, after Texas Governor Greg Abbott signed the bill into law. However, unlike Arizona and New Hampshire, Texas is the first to create a standalone, publicly-funded reserve.

Category: DeFi Jurisdictions: United States, APAC, Middle East

Summary: On June 9, the U.S. Attorney’s Office for the Central District of California announced that five men from various locations, including California, Turkey, and China, pleaded guilty to an alleged conspiracy to launder more than $36.9 million from victims of an international digital-investment-scam conspiracy that was carried out from centers in Cambodia. As part of the alleged conspiracy, co-conspirators residing overseas would contact U.S. victims directly through electronic means, gain the victims’ trust, and then promote fraudulent digital-asset investments to the victims. Afterwards, individuals like the defendants allegedly laundered the proceeds of these crimes.

Categories: Payments, Tokenization, Issuance Jurisdiction: United States

Summary: On June 9, the DOJ unsealed an indictment charging Iurii Gugnin, with various offenses, including wire and bank fraud, sanctions evasion, operation of an unlicensed money transmitting business, failure to file Suspicious Activity Reports, and money laundering. According to the indictment, Gugnin allegedly used his cryptocurrency company Evita to funnel more than $500 million of overseas payments through U.S. banks and cryptocurrency exchanges while hiding the sources and purposes of those transactions, which include sanctioned Russian entities.

Category: Tokenization Jurisdiction: APAC

Summary: On June 9, a member of South Korea’s ruling party introduced the Digital Asset Basic Act, which is intended to provide a regulatory framework for stablecoins. It is aimed at improving transparency and encouraging competition in the crypto sector. Legalizing stablecoins was one of the key promises made by South Korea’s newly elected leader, Lee Jae-myung.

Categories: Custody, Issuance, Payments, Tokenization Jurisdiction: APAC

Summary: On June 6, the Monetary Authority of Singapore (MAS) clarified the applicable scope of its new regulatory framework for Digital Token Service Providers (DTSPs). From June 30, any: (i) individual or partnership providing a Digital Token (DT) service outside of Singapore from a place of business in Singapore; or (ii) Singapore corporation providing a DT service outside Singapore, whether from Singapore or elsewhere will need to be licensed. Key factors which are relevant in determining whether a DT service is being provided “outside Singapore” include the location of the DTSP’s customers and front office. The new DTSP framework is expected to capture an extremely limited number of businesses not already regulated under existing regulatory frameworks applicable to cryptocurrency-related activities.

Categories: Exchange, Issuance Jurisdiction: Europe

Summary: On June 6, the United Kingdom’s Financial Conduct Authority (FCA) proposed to lift the ban on offering crypto exchange traded notes (cETNs) to retail investors. In a statement, the FCA explained that the decision was intended to support the “growth and competitiveness” of the UK crypto industry, rebalancing the regulator’s approach to risk.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On June 5, Circle (issuer of the second-largest stablecoin, USDC), completed its initial public offering (IPO), raising about $1.1 billion. Stablecoin adoption continues to grow, with USDC having a market cap of over $60 billion. Since the IPO, Circle shares have appreciated more than 600%.

Categories: Tokenization, Payments, Issuance Jurisdictions: United States, APAC

Summary: On June 5, the U.S. Department of Justice filed a civil forfeiture complaint in the District of Columbia seeking to forfeit over $7.74 million in cryptocurrency that was allegedly laundered on behalf of North Korea. The complaint asserts that North Korean information-technology workers unlawfully acquired cryptocurrency by bypassing identity verification and engaging in remote work abroad. The workers were paid for their work in cryptocurrency, and they used money-laundering techniques to try to send the funds back to the North Korean government, before it was seized and frozen by law enforcement authorities.

Categories: Exchange, Payments Jurisdiction: United States

Summary: On June 4, the U.S. Attorney’s Office for the Eastern District of Virginia announced the seizure of approximately 145 darknet and traditional internet domains and cryptocurrency funds associated with the “BidenCash” marketplace. The operators of the BidenCash marketplace allegedly use the platform to allow users to buy and sell stolen credit cards and associated personal information. According to the DOJ, the BidenCash marketplace facilitated the trafficking of over 15 million payment card numbers and personally identifiable information, and generated over $17 million in revenue during its operations.

Categories: Custody, Exchange, Issuance, Payments, Tokenization Jurisdiction: APAC

Summary: The Monetary Authority of Singapore (MAS) has confirmed its new rules for crypto service providers that operate “outside Singapore” but with Singapore touchpoints (e.g. supported by a corporation or individuals in Singapore). To determine if a service provider operates “outside Singapore,” factors such as whether the front-office functions (e.g. sales, business development) or customers are located outside Singapore are relevant. In-scope service providers will not benefit from any transitional grandfathering. They must suspend or cease their business by June 30, 2025. The MAS will grant licenses under the new framework only in extremely limited circumstances (as this type of operating model generally gives rise to regulatory concerns, e.g. AML/CFT-related). The MAS has published ongoing requirements (conduct, prudential, governance, risk management etc.) for those service providers that will obtain a license.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On May 29, SEC Commissioner Hester Peirce spoke at the Bitcoin 2025 conference in Las Vegas. Acknowledging that the SEC had dismissed several crypto-related enforcement actions, Commissioner Pierce emphasized that the Commission still has a role in enforcing the law against bad actors in the crypto space. “The goal is to use our enforcement tool for what it was intended to be used for, which is when there are clear rules and people violate them, then we can use our enforcement too.” The Commissioner also stated that “most crypto assets as we see them today are probably not themselves securities,” but that “doesn’t mean that you can’t sell a token that is not itself a security in a transaction that is a securities transaction.”

Categories: Custody, Exchange, Issuance, Payments, Tokenization Jurisdiction: United States

Summary: On May 29, a bipartisan group of House members formally introduced the crypto market-structure bill that would clarify the jurisdictional boundaries of the SEC and CFTC over digital assets. A discussion draft of the legislation had been released earlier in the month. The House Financial Services and Agriculture committees will consider and revise the bill before voting on whether to send the bill to the full chamber. The House Financial Services Committee held a hearing on the bill on June 4.

Categories: Custody, Tokenization Jurisdiction: Europe

Summary: On May 29, UK Reform Party leader and former Brexit campaigner Nigel Farage pledged to introduce legislation to establish a strategic bitcoin reserve if he were to be elected Prime Minister. Speaking at the Bitcoin 2025 conference in Las Vegas, he also pledged to ban crypto debanking and to lower the capital gains tax.

Category: Exchange Jurisdiction: United States

Summary: On May 29, the SEC and Binance filed a joint stipulation dismissing with prejudice the SEC’s lawsuit against the trading platform. The suit had been stayed at the SEC’s request while the agency’s crypto task force considers a new regulatory framework for digital assets. Binance stated that the dismissal “signals a global green light for responsible crypto innovation, boosting confidence from the U.S. to the EU and beyond.” Gibson Dunn represented Binance in this matter.

Category: Jurisdiction: United States

Summary: On May 28, the Department of Labor rescinded its 2022 guidance directing 401(k) plan fiduciaries to exercise “extreme care before they consider adding a cryptocurrency option to a 401(k) plan’s investment menu for plan participants.” In its place, the Department’s new guidance states that “a plan fiduciary’s decision should consider all relevant facts and circumstances.”

Categories: Custody, Issuance, Tokenization Jurisdiction: Europe

Summary: On May 28, the UK Financial Conduct Authority (FCA) published consultation papers CP25/14 and CP25/15, seeking stakeholder feedback on a draft framework that would bring the activities of issuing “qualifying stablecoins” and safeguarding “qualifying cryptoassets” within the regulatory perimeter, and introduce prudential rules for the aforementioned activities. Proposed regulatory measures relating to stablecoin issuance include requirements for full reserve backing, guaranteed par redemption on a T+1 basis, and a prohibition on distributing stablecoin yield to customers. The FCA is further proposing to introduce a new prudential regime to ensure that crypto firms set aside adequate financial resources. The proposed framework—which will mirror the three-pillared approach of minimum capital, liquidity buffers and risk controls used in traditional finance—will set baseline rules applicable across sub-sectors in the crypto industry and prescribe capital and liquidity rules for stablecoin issuers. Interested respondents are invited to provide comments by July 31, 2025.

Categories: Lending, Tokenization Jurisdiction: LATAM

Summary: On May 27, the International Monetary Fund announced that it had reached an agreement with the government of El Salvador to release $120 million of funds as part of a $1.4 billion loan program approved last year. As part of the agreement, the IMF noted that El Salvador agreed not to purchase more Bitcoin. After the announcement, however, El Salvador posted on X that it had purchased additional Bitcoin.

Categories: Lending, Tokenization Jurisdiction: United States

Summary: On May 23, a federal judge in Manhattan overturned a jury verdict for charges of wire fraud, commodities fraud, and commodities manipulation against Avraham Eisenberg. Eisenberg had been convicted in April 2024 of manipulating the price of Mango Markets’ MNGO token in order to artificially inflate the value of his assets on the Mango Markets platform, allowing him to “borrow” money he did not intend to return. The court vacated the commodities fraud and commodities manipulation convictions for lack of venue, and entered a judgment of acquittal for the wire fraud charge due to insufficient evidence by the government that Eisenberg had made false statements. Eisenberg’s separate conviction for possession of child pornography was left in place.

Category: Issuance Jurisdiction: United States

Summary: On May 22, the Department of Justice unsealed an indictment against Qakbot developer Rustam Rafailevich Gallyamov and filed a civil forfeiture action against cryptocurrency tied to Qakbot. The Qakbot malware had allegedly been used to infect thousands of computers, allowing Gallyamov to sell access to those computers to various ransomware attackers. As part of the investigation, the FBI seized approximately $24 million in cryptocurrency generated through Qakbot’s allegedly criminal activity.

Categories: Custody, Payments, Tokenization Jurisdiction: APAC

Summary: Hong Kong’s Legislative Council passed a stablecoin bill for fiat-referenced stablecoins. The bill will require stablecoin issuers to obtain a license from the Hong Kong Monetary Authority and comply with a range of requirements, including proper management of asset reserves, redemption mechanisms, and segregation of client assets. The bill is expected to come into effect this year, with “sufficient time” allowed for the industry to understand the requirements. The bill builds on Hong Kong’s recent expansion of its crypto market, including the introduction of a virtual crypto asset regime for crypto trading platforms in 2023, and the launch of a sandbox for stablecoin issuers in 2024.

Category: Payments Jurisdiction: United States

Summary: On May 21, the Department of Justice and the SEC filed parallel criminal and civil actions against Jeremy Jordan-Jones, CEO of start-up Amalgam Capital Ventures LLC. Jordan-Jones had allegedly misrepresented his business to investors, raising $500,000 on the claim that it had developed a blockchain-based payment processing system, when Amalgam allegedly had not developed the technology. The U.S. Attorney’s Office for the Southern District of New York charged Jordan-Jones with fraud, false statements, and identify theft offenses; in a parallel action, the SEC sued Jordan-Jones under the antifraud provisions of the federal securities laws for making material misrepresentations to investors.

Category: Jurisdiction: United States

Summary: On May 21, CFTC Commissioner Kristin Johnson announced her intent to leave the agency, joining two others—Summer Mersinger, and Christy Goldsmith Romero—who had already announced that they would step down at the end of May. With former Chairman Rostin Behnam having departed earlier this year, when Commissioner Johnson leaves only acting Chair Caroline Pham will remain. Pham has also stated that she plans to leave the agency once President Trump’s nominee, Brian Quintenz, is confirmed. The CFTC has not operated with so few governing members since early 2022.

Category: Tokenization Jurisdiction: United States

Summary: On May 20, the SEC brought an enforcement action under the antifraud provisions of the federal securities laws against New York-based crypto project Unicoin, Inc., and three of its executives, in the U.S. District Court for the Southern District of New York. Unicoin and its executives allegedly made false and misleading statements by offering certificates that purportedly conveyed rights to Unicoin’s tokens and common stock.

Categories: Issuance, Tokenization Jurisdiction: LATAM

Summary: On May 19, Argentinian President Javier Milei and Justice Minister Mariano Cúneo Libarona signed a decree dissolving a task force which was investigating the LIBRA cryptocurrency. LIBRA was originally promoted by Milei via social media as a “private project” to stimulate the Argentine economy. Milei’s promotion of LIBRA caused a scandal when the cryptocurrency reached a market valuation of more than $4.5 billion before soon losing nearly 90% of its value.

Categories: Custody, Exchange, Issuance, Payments, Tokenization Jurisdiction: United States

Summary: On May 19, the Senate invoked cloture on the Guiding and Establishing National Innovation for U.S. Stablecoins (“GENIUS”) Act. The bill is the first comprehensive federal regulatory framework for stablecoins. The bipartisan cloture vote (66-32) limits the amount of further debate before a final vote is taken to approve or reject the bill. There is still an opportunity to propose amendments before the final vote, after which the bill will advance to the House of Representatives.

Category: Payments Jurisdiction: United States

Summary: On May 15, the U.S. Attorney’s Office for the Southern District of New York pared back a charge for conspiracy to operate a money-transmitting business in its criminal case against Tornado Cash developer Roman Storm. Storm was charged in August 2023 with three counts: conspiracy to violate sanctions, conspiracy to commit money laundering, and conspiracy to operate an unlicensed money-transmitting business. The government had argued that the money-transmitting conspiracy could be proved through either evidence that Storm failed to comply with money-transmitting regulations or evidence that he transmitted funds known to be derived from a criminal offense. The government has dropped the former theory but continues to maintain the latter (along with the remaining counts). The decision comes in response to the April 7 memorandum from Deputy Attorney General Todd Blanche, which directed federal prosecutors to avoid “enforcement actions that have the effect of superimposing regulatory frameworks on digital assets.”

Categories: Custody, Exchange Jurisdiction: United States

Summary: On May 15, FINRA and the SEC Division of Trading and Markets withdrew their 2019 Joint Staff Statement on Broker-Dealer Custody of Digital Asset Securities. The Joint Statement had set forth the SEC’s interpretation of the so-called Customer Protection Rule, which effectively prohibited broker-dealers from taking custody of digital assets. The withdrawal was accompanied by new FAQs on broker-dealer responsibility. The FAQs state that broker-dealers can custody digital assets without complying with the Customer Protection Rule or with the requirements of the 2020 Special Purpose Broker-Dealer Statement.

Category: Jurisdiction: United States

Summary: On May 15, a superseding indictment was unsealed in the U.S. District Court for the District of Columbia adding twelve additional defendants to a RICO criminal charge originally brought against two individuals, Malone Lam and Jeandiel Serrano. The case, originally filed in September 2024, alleges a conspiracy to steal over $263 million worth of cryptocurrency, include over $230 million of Bitcoin from one victim in Washington, D.C., and then launder the proceeds. The defendants are charged with RICO conspiracy, conspiracy to commit wire fraud, money laundering, and obstruction of justice.

Categories: Custody, Issuance, Tokenization Jurisdiction: United States

Summary: On May 12, the SEC held a roundtable on tokenization as part of a series of discussions on digital asset regulation. The roundtable, held at the SEC’s headquarters, included panels on the evolution of tokenized capital markets and on the future of tokenization. In his keynote address, SEC Chairman Paul Atkins outlined the Commission’s goals to create clear guidelines for issuance of digital assets, to allow more choice regarding how to custody digital assets, and to allow a wider variety of trades, including “‘pairs trading’ between securities and non-securities.”

Category: Exchange Jurisdiction: Europe

Summary: On May 9, the German Federal Criminal Police Office (BKA) announced that it had seized the server infrastructure of eXch, along with €34 million in Bitcoin, Ether, Litecoin, and Dash. The crypto exchange, which had been operating since 2014, enabled anonymous exchanges of crypto assets without any KYC measures or anti-money laundering protocols. German prosecutors said that the platform advertised this lack of measures on websites and other platforms of “criminal underground economy.” It is estimated that up to $1.9 billion has been moved through the exchange since its inception, in large part from criminal origins. The German authorities also claimed that a portion of the $1.4 billion in crypto stolen from Bybit earlier this year was laundered through eXch.

Categories: Lending, Tokenization Jurisdiction: United States

Summary: On May 8, Alex Mashinsky, the former CEO of the now-defunct crypto lender Celsius, was sentenced to 12 years in prison after he had pleaded guilty to fraud and market manipulation in the U.S. District Court for the Southern District of New York. According to the U.S. Attorney’s Office, Mashinsky defrauded Celsius investors by taking inappropriate risks with their funds, including by propping up the price of Celsius’ crypto-token CEL.

Categories: Custody, Exchange, Lending Jurisdiction: United States

Summary: On May 7, the Office of the Comptroller of the Currency published Interpretive Letter No. 1184, which clarified that national banks and federal savings associations may buy and sell crypto-assets held in custody on a customer’s behalf at the direction of the customer. The agency also stated that national banks can outsource crypto custody and trade execution services to third parties if proper risk-management procedures are in place. The guidance is consistent with prior OCC, Federal Reserve, and FDIC guidance and other actions as they continue to signal increased receptivity to crypto-related activities and digital assets in the banking industry on behalf of clients.

Category: Jurisdiction: United States

Summary: On May 6, Trish Turner, a longtime IRS official, was appointed to lead the agency’s digital-asset unit after the exit of Sulolit Mukherjee and Seth Wilks, who co-led the unit for over a year. Before this new role, Turner served as a senior advisor within this unit responsible for crypto taxation and enforcement.

Categories: Custody, Tokenization Jurisdiction: United States

Summary: On May 6, New Hampshire Governor Kelly Ayotte signed bill HB 302 into law, enabling up to 10% of the State’s general fund to be allocated to both precious metals and digital assets with a market cap exceeding $500 billion – a threshold currently met only by Bitcoin. The State can invest in qualifying digital assets either directly or via an exchange-traded fund, and may self-custody these assets or use a custodian. On May 7, Arizona followed suit and passed its own crypto reserve bill, but Governor Katie Hobbs vetoed it five days later. A similar bill has been adopted by the Texas State Legislature and is awaiting the signature of Governor Greg Abbott. Other States are currently considering adopting similar legislation, while these efforts have been paused in Florida.

Categories: Custody, Exchange, Issuance, Payments, Tokenization Jurisdiction: United States

Summary: On May 5, Republican lawmakers released a discussion draft of a bill that seeks to establish a comprehensive regulatory framework for digital assets. The bill provides for joint rulemaking by the SEC and CFTC, a pathway for digital-asset developers to raise funds under the SEC’s jurisdiction and a process for market participants to register with the CFTC for digital commodity trading. The bill would require digital-asset developers to provide accurate disclosures including relating to their digital asset’s operation, ownership and structure.

Category: Rewards Jurisdiction: United States

Summary: On May 1, the Federal Trade Commission and the State of Nevada filed a complaint against an entity currently operating as IYOVIA and more broadly referred to as “IML.” IML offers educational courses in cryptocurrency trading but allegedly stole over a billion dollars from young investors through fraudulent courses. The company allegedly misrepresented how much both customers and salespeople could make, claiming its salespeople could make up to $750,000 per month, while knowing that just one in five earned more than $500 per month.

Category: Jurisdictions: United States, APAC

Summary: On May 1, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule that would prohibit U.S. financial institutions from opening or maintaining correspondent or payable-through accounts for or on behalf of Cambodia-based Huione Group because it has laundered illicit proceeds from cybercrimes. FinCEN said that Huione Group has been critical for laundering proceeds of cyber heists by the Democratic People’s Republic of Korea and for convertible virtual currency scams conducted by transnational criminal organizations in Southeast Asia.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 24, the Federal Reserve Board announced that it withdrew guidance for banks related to their digital-asset and dollar-tokens activities. The agency rescinded a 2022 supervisory letter requesting state member banks to provide advance notification of digital-asset activities and a 2023 supervisory letter regarding the supervisory nonobjection process for state member bank engagement in dollar-token activities. These actions follow earlier comments from Fed Chair Jerome that the Fed does not intend to limit the bank sector’s interaction with digital assets.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 24, the SEC agreed to dismiss its enforcement action against blockchain platform Dragonchain and founder Joseph J. Roets. The SEC filed a joint stipulation in the U.S. District Court of Western District of Washington, citing the January 2025 launch of the SEC’s Crypto Task Force and its efforts to develop a regulatory framework for digital assets. The case was dismissed on April 25. The lawsuit, filed in August 2022, had alleged that Dragonchain sold unregistered securities via its DRGN tokens.

Category: Jurisdiction: United States

Summary: On April 23, a federal court in the Southern District of New York sentenced Long Island resident Eugene William Austin, Jr. to 18 years in prison after a jury convicted him of fraud-related offenses, in connection with a scheme to defraud cryptocurrency investors. The court also ordered forfeiture of roughly $6 million and imposed restitution in an amount to be determined.

Category: Issuance Jurisdiction: United States

Summary: On April 23, Nova Labs, Inc., the creator of a decentralized wireless network known as the Helium Network, agreed to pay $200,000 to settle an SEC lawsuit filed in January 2025. The suit alleged that Nova Labs falsely claimed client relationships with various prominent businesses to sell preferred stock in a private placement. Nova Labs neither admitted nor denied the SEC’s allegations in its settlement.

Category: Jurisdiction: United States

Summary: On April 22, the SEC and federal prosecutors in the Eastern District of Virginia filed parallel cases against Ramil Palafox, founder of PGI Global, a purported Bitcoin investment platform, alleging that he misappropriated over $57 million of investor funds. The SEC’s complaint and the indictment allege that from January 2020 to October 2021, Palafox sold “membership” packages promising high returns from cryptocurrency investments but spent the money on luxury items instead. The complaint and the indictment further allege that Palafox ran a multilevel-marketing scheme, using remaining funds to pay other investors until the company’s collapse.

Category: Exchange Jurisdiction: United States

Summary: On April 21, the CFTC issued a request for comment on the implications of extending the trading of CFTC-regulated derivatives markets to an effectively 24/7 basis, including the potential effects on trading, clearing and risk management which differ from trading during current market hours. 24/7 trading is already prevalent in digital assets markets. On the same day, the CFTC also requested comment on the characteristics of perpetual derivatives, the implications of their use in trading, clearing and risk management and the risks of such derivatives risks in connection with market integrity, customer protection, or retail trading. Perpetual derivatives are commonly traded on offshore digital asset exchanges.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 18, U.S. District Court Judge Eric R. Komitee of the Eastern District of New York denied former SafeMoon CEO Braden Karony’s motion to dismiss his indictment, stating that a jury should assess his arguments regarding whether the charged conduct is extraterritorial and therefore not subject to U.S. law and whether SafeMoon’s token is a security. Karony faces charges of conspiracy to commit securities fraud, wire fraud, and money laundering. Trial is set for May 6. The indictment alleges that Karony, SafeMoon’s co-founder Kyle Nagy and former CTO Thomas Smith conspired to commit securities and wire fraud and money laundering in defrauding investors through a digital asset called SafeMoon. Former CTO Thomas Smith has pleaded guilty to related charges.

Category: Exchange Jurisdiction: United States

Summary: On April 18, Oregon Attorney General Dan Rayfield filed a lawsuit in state court against Coinbase alleging that the crypto exchange offers unregistered securities under Oregon law. The lawsuit largely parrots the theories the SEC recently abandoned in dismissing its enforcement action against Coinbase. In a blog post, Coinbase stated that “Oregon’s lawsuit, like the SEC’s, is meritless, and Coinbase will do whatever is required to beat it.”

Categories: Issuance, Tokenization Jurisdiction: Middle East

Summary: On April 17, the ADGM Financial Services Regulatory Authority (“FSRA”) initiated an enforcement action against the HAYVN Group, a digital asset-focused financial institution, and its former CEO for regulatory breaches, including unlicensed virtual asset activity. The FSRA cancelled HAYVN ADGM’s license, banned the former CEO from ADGM’s financial sector, and imposed USD $8.85 million in fines across four related parties for misconduct including unlicensed virtual asset activity, AML failures such as not recording all of its client relationships and allowing client transactions to be routed through unregulated accounts, and providing false information to banks and the FSRA.

Category: Exchange Jurisdiction: United States

Summary: On April 17, prime brokerage platform Hidden Road announced it received a broker-dealer license from the Financial Industry Regulatory Authority (FINRA), shortly after Ripple Labs agreed to acquire the firm for $1.25 billion. The license allows Hidden Road to offer FINRA-compliant prime brokerage, clearing, and financing services in fixed income assets.

Category: Lending Jurisdiction: United States

Summary: On April 13, Richard Kim, founder of cryptocurrency casino Zero Edge, was charged in the U.S. District Court in the Southern District of New York with securities fraud and wire fraud for allegedly stealing millions from investors between March 2024 and July 2024. According to the complaint, Kim raised $4.3 million from investors, promising to develop an online casino with on-chain games and a new cryptocurrency called “$RNG”, but instead allegedly used the investor funds for speculative cryptocurrency trades and gambling. He was arrested and released on a $250,000 bond.

Category: DeFi Jurisdiction: United States

Summary: On April 11, President Trump signed into law a resolution under the Congressional Review Act that nullifies a Treasury Department and IRS rule that would have subjected DeFi participants to onerous tax-reporting requirements for digital-asset transactions (the “DeFi Broker Rule”). The resolution not only effectively repeals the DeFi Broker Rule but also will prohibit the U.S. Treasury and the IRS from issuing a new rule that is “substantially the same” as the repealed rule absent new legislation. The resolution does not repeal the IRS’s July 2024 broker rule applicable to custodial digital asset trading platforms.

Categories: Exchange, Issuance, Payments, Tokenization Jurisdiction: United States

Summary: On April 10, Illinois state senators passed out of committee Senate Bill 1797, which requires crypto firms to register with the state and provide disclosures to protect consumers. It also empowers the Illinois Department of Financial and Professional Regulation to set and enforce guidelines for crypto companies. Sen. Mark Walker, one of the bill’s sponsors, emphasized the need for standards to prevent bankruptcy, fraud, and deceptive practices in the crypto industry.

Categories: Exchange, Issuance, Tokenization, Payments Jurisdiction: United States

Summary: On April 10, New York Attorney General Letitia James sent a letter to congressional leaders warning that the lack of strong federal regulations on cryptocurrencies and digital assets increases the risk of fraud, criminal activity, and financial instability. She argued that federal regulations would bolster America’s national security, strengthen its financial markets and protect investors from cryptocurrency scams. James’s letter called for protections including “i) onshoring stablecoins to protect the U.S. dollar and the treasuries market, ii) requiring platforms to only conduct business with anti-money laundering compliant platforms, iii) providing for the registration of issuers and intermediaries to ensure accountability, transparency and basic protections to the public, iv) protecting against conflicts of interest, v) promoting price transparency, vi) requiring platforms and intermediaries to actively identify and prevent fraud and scams, and vii) disallowing digital assets in retirement accounts.”

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 10, the SEC’s Division of Corporation Finance issued a staff statement providing the Division’s views about the application of certain disclosure requirements under the federal securities laws to offerings and registrations of securities in the digital-asset markets. The statement recommends that companies describe their business operations without overly relying on technical jargon and specify the business activity, “such as operating or developing a network or application, and the current stage of development” and how the issuer expects to generate revenue. With respect to risk factors for offerings and registrations of securities in the crypto asset markets, the guidance provides examples such as risks relating to technology and cybersecurity, price volatility, liquidity issues and potential registration requirements under state and federal laws. The statement also emphasizes that it “does not address all material disclosure items, and the disclosure topics addressed … may not be relevant for all issuers.” As is typical, the guidance states that it is nonbinding and does not have Commission-level approval.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 10, the SEC and Ripple Labs asked the U.S. Court of Appeals for the Second Circuit to pause their respective appeals in the agency’s ongoing enforcement action against the company. The Second Circuit granted the motion on April 16, holding the appeal in abeyance and requiring a status report from the SEC within 60 days.

Category: Jurisdiction: United States

Summary: On April 9, Paul Atkins was confirmed as the next Chairman of the SEC. Atkins served as an SEC commissioner under President George W. Bush and previously worked at the Commission during both Republican and Democratic administrations. Atkins founded a financial services consulting firm in 2008, Patomak Global Partners, which has advised clients on regulatory and compliance matters, including issues related to digital assets. Atkins was sworn in on April 21.

Categories: Exchange, Issuance, Tokenization Jurisdiction: United States

Summary: On April 8, CFTC Acting Chairman Caroline D. Pham praised the Blanche Memo, and directed CFTC staff to comply with the President’s executive orders and Administration policy. Consistent with the DOJ’s enforcement priorities, Pham has refocused the CFTC’s enforcement resources on cases involving combatting fraud and manipulation rather than regulating by enforcement. Specifically, Pham has directed CFTC staff not to charge regulatory violations in cases involving digital assets unless there is evidence that the defendant knew of the licensing or registration requirement at issue and willfully violated such requirement.

Category: Jurisdiction: APAC

Summary: On April 8, the MAS published a Consultation Paper seeking feedback on proposed amendments to MAS Notices on anti-money laundering and countering the financing of terrorism to take into account the latest money laundering, terrorism financing and proliferation financing developments. The amendments apply across the financial sector and are relevant to financial institutions including banks, insurers, capital markets intermediaries, payment service providers (including digital payment token or crypto asset service providers). Broadly, the proposed amendments reference the latest revised standards set by the Financial Action Task Force and cover topics ranging from risk assessments to the clarification of regulatory expectations on the filing of suspicious transaction reports.

Categories: Exchange, Issuance, Tokenization Jurisdiction: United States

Summary: On April 7, Deputy Attorney General Todd Blanche issued a memorandum (the “Blanche Memo”) announcing a shift in the Department of Justice’s enforcement priorities concerning digital assets. According to the memo, the DOJ “will no longer pursue litigation or enforcement actions that have the effect of superimposing regulatory frameworks on digital assets while President Trump’s actual regulators do this work outside the punitive criminal justice framework.” Instead, the focus will be on “prosecuting individuals who victimize digital asset investors, or those who use digital assets in furtherance of criminal offenses such as terrorism, narcotics and human trafficking, organized crime, hacking, and cartel and gang financing.” The memo also announced the disbandment of the National Cryptocurrency Enforcement Team.

Category: Staking Jurisdiction: APAC

Summary: On April 7, the SFC revised an existing circular that was originally issued on December 22, 2023 delineating the requirements for authorizing investment funds with exposure to virtual assets of more than 10% of their net asset value for public offerings in Hong Kong. The fund manager must obtain the SFC’s prior approval before it can engage in staking activities for its managed SFC-authorized virtual asset fund, and the staking activities must be conducted through an SFC-licensed VATP or authorized institution, subject to a cap to manage fund liquidity. The fund manager must also ensure that the staking activities are consistent with the fund’s investment objective and strategy.

Category: Staking Jurisdiction: APAC

Summary: On April 7, the Securities and Futures Commission (“SFC”) and the Hong Kong Monetary Authority (“HKMA”) issued circulars to SFC-licensed virtual asset trading platform (“VATP”) operators and authorized institutions to permit the offering of staking services. VATPs must obtain the SFC’s prior approval and agree to be bound by the SFC’s ‘Terms and Conditions for Staking Services’ before offering staking services. Broadly, other requirements to offer staking services include that VATPs must (i) maintain possession or control over all mediums through which clients’ virtual assets may be withdrawn from the staking service, (ii) implement policies, internal controls and operational rules to ensure that staked virtual assets are adequately safeguarded and (iii) manage operational risks and conflicts of interest. VATPs must also exercise skill, care and diligence when selecting a blockchain protocol for their staking service and when selecting its arrangement for participating in the validation process. VATPs must also ensure adequate disclosure of additional staking risks to their clients and obtain their written acknowledgement before providing them with staking services.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 4, the SEC’s Division of Corporation Finance issued guidance stating that the offer and sale of certain reserve-backed dollar stablecoins are not securities transactions. To qualify as a “Covered Stablecoin” under the guidance, the stablecoin’s value must be pegged to the U.S. dollar, and the stablecoin must be backed by dollars or other low-risk, liquid assets and be redeemable one-for-one for U.S. dollars at any time and in unlimited amounts, among other requirements. As is typical, the guidance states that it is nonbinding and does not have Commission-level approval.

Category: Jurisdiction: Middle East

Summary: On April 2, United Arab Emirates-based financial services firm CLS Global FZC LLC was sentenced in Massachusetts federal court for allegedly running a fraudulent “wash trading” scheme. The firm pleaded guilty to conspiracy to commit market manipulation and wire fraud and wire fraud in January. Additionally, CLS Global was ordered to pay approximately $428,059 in fines and seized cryptocurrency, and sentenced to three years of probation during which CLS Global cannot participate in U.S. cryptocurrency markets. CLS Global also entered into a separate agreement with the SEC over related civil claims.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On April 1, the SEC and crypto exchange Gemini asked the district court for a 60-day stay of the regulator’s enforcement action while the parties discuss a potential resolution. The court granted the motion on April 2 and ordered the parties to file a joint status report on May 31. The SEC filed the action against Gemini and Genesis Global Capital, LLC in January 2023 alleging they offered unregistered securities; Genesis later agreed to a consent judgment in connection with bankruptcy proceedings.

Category: Exchange Jurisdiction: United States

Summary: On March 28, the CFTC announced its withdrawal of two staff advisories that imposed extra scrutiny on the clearing and trading of digital-asset derivatives, aiming to align the regulatory treatment of these products with other derivatives under its jurisdiction. The CFTC stressed that the same listing standards and risk-management principles still apply to all derivative products, and that the withdrawal would not affect its oversight of clearing and systemic risk.

Categories: Custody, Issuance, Tokenization, Payments Jurisdiction: United States

Summary: On March 28, the FDIC issued a Financial Institution Letter clarifying that banks may engage in permissible activities without prior FDIC approval, as long as they manage the risks. The FDIC will coordinate with the President’s Working Group on Digital Asset Markets and the other banking agencies to issue further guidance or regulations.

Categories: Payments, Tokenization, Custody, Exchange, Issuance Jurisdiction: APAC

Summary: On March 27, the Monetary Authority of Singapore (“MAS”) published a Consultation Paper seeking feedback on proposed amendments aimed at implementing standards promulgated by the Basel Committee on Banking Supervision (“BCBS”) on prudential treatment and disclosure of crypto asset exposures for banks. Specifically, the MAS has proposed to amend relevant MAS notices relating to capital, liquidity, large exposures and disclosure frameworks for banks to implement the BCBS’ standards on prudential treatment and disclosures for crypto asset exposures for banks.

Category: Exchange Jurisdiction: United States

Summary: On March 27, President Trump granted pardons to four former executives of the BitMEX global cryptocurrency exchange, as well as HDR Global Trading Limited, the entity that owned and operated BitMEX, all of which had pled guilty to violating the Bank Secrecy Act. The former executives, Arthur Hayes, Benjamin Delo, Samuel Reed and Gregory Dwyer, had received criminal sentences of probation and fines of more than $30 million for willfully failing to maintain anti-money laundering and know-your-customer programs. HDR had been sentenced to a $100 million fine in addition to its previous $100 million no-admit no-deny settlements with CFTC and FinCEN due to compliance failures.

Category: Exchange Jurisdiction: United States

Summary: On March 27, Crypto.com announced that it was informed by the SEC that the SEC ended its investigation into the company with no enforcement action. According to Crypto.com, it received a Wells notice from the SEC in August 2024, alleging that the company acted as an “unregistered broker-dealer and securities clearing agency under the federal securities laws.” In October 2024, Crypto.com filed a complaint seeking declaratory and injunctive relief against the SEC.

Categories: Exchange, Issuance Jurisdiction: United States

Summary: On March 25, Ripple Labs CLO Stuart Alderoty announced that the company will pay the SEC a $50 million civil penalty to resolve the agency’s enforcement action, and the agency and company will each drop their appeals of an adverse decision in the district court. The SEC brought the action initially in 2020. Last year, U.S. District Judge Analisa Torres ruled that secondary sales and other distributions of XRP are not securities transactions but ordered Ripple to pay $125 million for failing to register institutional sales of the XRP token, which she held were securities transactions. The SEC and Ripple cross-appealed these decisions to the Second Circuit.

Categories: Issuance, Tokenization Jurisdiction: Middle East

Summary: On March 24, the Abu Dhabi Global Market (“ADGM”) signed a Memorandum of Understanding with decentralized network Chainlink to promote compliant tokenization and enhance blockchain innovation. The partnership will support projects under the ADGM Registration Authority by leveraging Chainlink’s technical expertise in blockchain interoperability and verifiable data solutions. Chainlink’s infrastructure has enabled over $19 trillion in transaction value globally and is trusted by leading financial institutions. Under the Memorandum of Understanding, ADGM and Chainlink will collaborate on regulatory dialogue and host educational initiatives focusing on blockchain, AI and tokenization.

Category: Exchange Jurisdiction: United States

Summary: On March 21, Aleksei Andriunin, a Russian founder of a market-making service company, and that company, Gotbit Consulting LLC, pleaded guilty in Massachusetts federal court. Andriunin and Gotbit both pled guilty to charges of conspiracy to commit market manipulation, and wire fraud, and agreed to forfeit $23 million in cryptocurrency. Andriunin allegedly developed codes to artificially inflate trading volume in order to list cryptocurrency on larger exchanges and has gained tens of millions of dollars through his fraudulent services.

Categories: Custody, Issuance, Tokenization, Payments Jurisdiction: United States

Summary: On March 20, the OCC issued a statement that it will no longer examine national banks for reputational risk and is removing references to reputational risk from its Handbook and guidance issuances. Certain crypto companies have previously argued that examinations focused on reputational risk contributed to banks refusing to open accounts or otherwise work with crypto companies. This action indicates that the OCC may be seeking to ease the compliance path for banks engaging with crypto businesses.

Categories: Issuance, Tokenization, Staking Jurisdiction: United States

Summary: On March 20, the SEC’s Division of Corporation Finance confirmed in a statement that cryptocurrency mining activities, including both self-mining and mining pools, do not involve the offer and sale of securities, and thus do not require registration or exemption under securities laws. Under the previous administration, SEC has declared that proof-of-stake blockchains fall under the regulation of securities laws.

Categories: Exchange, Payments Jurisdiction: United States

Summary: On March 19, the European Securities and Markets Authority (“ESMA”) published the official translations of its guidelines on the conditions and criteria for the qualification of crypto assets as financial instruments (ESMA75453128700-1323) under Article 2(5) of MiCA. The guidelines clarify when MiCA or other rules apply to crypto assets. They are effective starting on May 18, 2025, and relevant authorities are required to update ESMA.

Categories: Issuance, Tokenization Jurisdiction: Europe

Summary: On March 18, HM Treasury and the UK Debt Management Office (“DMO”) released a policy paper detailing their pilot Digital Gilt Instrument (“DIGIT”). DIGIT is a new, short-dated, transferable security that will be held on a Distributed Ledger Technology (“DLT”) platform and issued within the Digital Securities Sandbox, operating independently from the Government’s standard debt issuance processes. The policy paper outlines the initial features of DIGIT and seeks input from financial sector firms to gauge investor demand and design preferences for further development. Additionally, it requests information from potential DLT suppliers to explore available technology options and the scope of services required for DIGIT issuance. Stakeholders are invited to submit their responses by April 13, 2025.

Category: Jurisdiction: United States

Summary: Federal prosecutors have dropped their fraud case against the founder of crypto project BitClout, whom they had accused of defrauding a venture capital firm by misleading investors. According to a joint filing by the SEC and BitClout’s founder Nader Al-Naji, the SEC is also considering dropping a parallel action against Al-Naji. The Department of Justice’s order did not give a reason for the dismissal.

Categories: Tokenization, Issuance Jurisdiction: Middle East

Summary: On March 17, the Dubai Financial Services Authority (“DFSA”) called for expressions of interest to join its new Tokenization Regulatory Sandbox, with a deadline of April 24, 2025. The initiative forms part of the DFSA’s Innovation Testing Licence program and is aimed at firms offering tokenized financial products and services, including equities, bonds, sukuk, and fund units. The sandbox provides a controlled environment for testing tokenized investment solutions, offering a structured path to full regulatory authorization.

Category: Custody Jurisdiction: United States

Summary: During a March 17 speech, the SEC’s Acting Chairman, Mark Uyeda, said that the SEC is considering modifying or eliminating a crypto custody rule proposed by the prior administration that would have required registered investment advisors to custody digital assets with a qualified custodian, among other things. Given the concerns expressed by commenters, Uyeda said, “there may be significant challenges to proceeding with the original proposal.” Uyeda said that he had directed SEC staff to work with the SEC’s new crypto task force to “consider appropriate alternatives.”

Category: Jurisdiction: United States

Summary: On March 13, Thomas John Sfraga was sentenced by Judge Frederic Block of the Eastern District of New York to 45 months in prison and was ordered to pay $1,337,700 in forfeiture, with restitution pending. Allegedly posing as a serial entrepreneur, Sfraga allegedly solicited more than $2 million in investments from at least 17 victims for fake property flips and cryptocurrency ventures, promising returns up to 60% in three months. Sfraga then used such funds for personal expenses and to repay earlier victims.

Categories: Custody, Exchange, Issuance, Payments, Tokenization Jurisdiction: United States

Summary: On March 13, a bipartisan group of senators in the Senate Banking Committee, led by Senator Bill Hagerty (R-Tenn), voted to advance the “GENIUS Act” (Guiding and Establishing National Innovation for US Stablecoins) to the Senate. The Act aims to create a regulatory framework for stablecoins, defining when issuers fall under state or federal oversight. Senator Elizabeth Warren (D-Ma) expressed concern over the bill, cautioning that it could allow tech billionaires like Elon Musk to issue their own currencies to compete with the US dollar.

Categories: Issuance, Tokenization Jurisdiction: United States

Summary: On March 12, Rowland Marcus Andrade, the founder and CEO of NAC Foundation, was convicted at trial of fraud and money laundering in the Northern District of California. By promoting a cryptocurrency, AML Bitcoin, Andrade allegedly defrauded tens of thousands of investors of over $10 million through making false statements about AML Bitcoin’s technology and its business deals. He allegedly diverted over $2 million for personal use and laundered funds through multiple accounts. Andrade’s sentencing is scheduled on July 22. He faces up to 30 years in prison and potential forfeiture of all assets traceable to the crimes.

Category: Crypto ATM Jurisdiction: United States

Summary: On March 12, Nebraska Governor Jim Pillen signed into law legislation requiring kiosk operators to be licensed and make adequate disclosures to customers including warnings about crypto fraud. The law was passed after the U.S. Federal Trade Commission pointed out in a September report that there has been a massive increase in consumer losses due to scams involving Bitcoin ATMs.

Category: DeFi Jurisdiction: United States

Summary: In a significant victory for the crypto industry, Congress has passed a joint resolution under the Congressional Review Act that will repeal a Treasury Department and IRS rule that would have subjected DeFi participants to onerous tax-reporting requirements for digital-asset transactions (DeFi Broker Rule). On March 11, the House voted 292-131 to pass the resolution, which was then passed by the Senate with a 70-28 vote on March 26. Once signed into law by President Trump, the resolution will not only effectively repeal the DeFi Broker Rule, but also will prohibit Treasury and the IRS from issuing a new rule that is “substantially the same” as the repealed rule absent new legislation. The resolution will not repeal the IRS’s July 2024 broker rule applicable to custodial digital asset trading platforms.

Category: Exchange Jurisdictions: United States, Europe

Summary: On March 7, the DOJ announced that in coordination with German and Finnish law enforcement, it has taken down the online infrastructure of Garantex, a cryptocurrency exchange allegedly used to facilitate money laundering for transnational criminal organizations and sanctions violations. The coordinated action seized Garantex’s domain names and servers and froze over $26 million in funds. DOJ alleged that Garantex has processed at least $9 billion in cryptocurrency transactions since April 2019 and was operated by Lithuanian resident Alksej Besciokov and Russian national Aleksandr Mira Sera, who have been indicted for money laundering conspiracy and other charges that carry maximum penalties of 20+ years in prison. According to a subsequent news story, Besciokov was later arrested in India.

Categories: Custody, Issuance, Tokenization, Payments Jurisdiction: United States

Summary: In an Interpretive Letter issued on March 7, the OCC reaffirmed that banks may engage in certain cryptocurrency-related activities, including crypto-asset custody, stablecoin transactions, and participation in independent node verification networks. The Letter removes existing requirements for banks to obtain supervisory nonobjection before engaging in such activities. According to Rodney Hood, the acting Chief of the OCC, the agency intends to align the regulations of novel and traditional bank activities.

Category: Exchange Jurisdiction: APAC

Summary: On March 6, Japan’s ruling Liberal Democratic Party (LDP) proposed reducing the crypto capital-gains tax rate from a maximum of 55% to 20% and is seeking public feedback until March 31. The proposal aims to reclassify cryptocurrencies as “financial products” under a new regulatory framework, which would introduce a separate 20% tax rate similar to securities investments. The LDP’s proposal also includes deferring taxes on crypto-to-crypto swaps until the crypto is exchanged for fiat currency.

Categories: Custody, Exchange, Tokenization, Issuance, Payments Jurisdiction: United States

Summary: On March 6, Senate Banking Chair Tim Scott introduced the Financial Integrity and Regulation Management (FIRM) Act to address concerns about the debanking of certain companies, particularly in the crypto industry. The bill aims to eliminate the use of reputational risk as a component of regulatory supervision, which Scott argues has been misused by federal regulators to carry out political agendas. The bill has passed out of the Senate Banking Committee and will next move to the Senate for a vote.

Category: Custody Jurisdiction: United States

Summary: On March 6, President Trump signed an Executive Order to establish a Strategic Bitcoin Reserve and a U.S. Digital Asset Stockpile. The order aims to position to United States as a leader in digital-asset strategy. The reserve will be funded with Bitcoin finally forfeited in criminal or civil proceedings and will not be sold, akin to a “digital Fort Knox” according to newly appointed “crypto czar,” David Sacks. Texas soon followed suit on March 6 when the Texas Senate passed S.B. 21, which would establish the Texas Strategic Bitcoin Reserve and allow the state to invest public money into digital assets. The bill is waiting to be voted by the House. Similarly, on March 5, New Hampshire’s H.B. 302, which would allow the state to invest up to 5% of state funds into bitcoin and other assets, was passed by the House committee and is pending for a full floor vote.

Category: Crypto ATM Jurisdiction: Europe

Summary: On February 28, the UK Financial Conduct Authority announced that it has secured a four-year sentence for an individual for illegally operating crypto ATMs. The individual allegedly operated crypto ATMs at 28 different locations across the UK, despite being refused an FCA license for his business in 2021 due to concerns over compliance with regulations. This is the first sentence for unregistered crypto-asset activity in the UK.

Digital Assets Hub

Gibson Dunn advises leading participants in the global digital asset economy, including exchanges, issuers, custodians, intermediaries, infrastructure providers, and investors.

Related Capabilities