Digital Assets Recent Updates – June 2025

Client Alert  |  July 8, 2025


We are pleased to provide you with the June edition of Gibson Dunn’s digital assets regular update. This update covers recent legal news regarding all types of digital assets, including cryptocurrencies, stablecoins, CBDCs, and NFTs, as well as other blockchain and Web3 technologies. Thank you for your interest.

ENFORCEMENT ACTIONS

UNITED STATES

  • NY State Officials Break Up Alleged Crypto Scam Targeting Russian Nationals
    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. NY AG Press ReleaseThe Block.
  • Coinme Inc. Fined in First Enforcement Action Under California’s Digital Financial Assets Law
    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. DFPI Press ReleaseLaw360.
  • Ripple to Abandon Appeal After Judge Refuses to Sign Off on Settlement
    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. Law360Reuters.
  • DOJ seizes “BidenCash” Marketplace
    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. DOJ Press ReleaseFortuneCrypto.
  • DOJ Files Civil Forfeiture Complaint in Action Related to North Korea
    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. DOJ Press Release.
  • Founder of Cryptocurrency Payments Company Charged with Evading Sanctions and Export Controls
    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. DOJ Press ReleaseIndictmentCNBCBusiness Insider.
  • Five Men Plead Guilty for Their Roles in a Global Digital-Asset Investment Scam Conspiracy
    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. DOJ Press ReleaseCointelegraph.
  • Gotbit Founder Aleksei Andriunin Sentenced for Wash-Trading Scheme
    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. DOJ Press ReleaseThe BlockReutersBe(in)Crypto.
  • DOJ Files Civil Forfeiture Complaint in Action Related to Alleged Crypto Confidence Scams
    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. DOJ Press Release ComplaintThe Block.
  • Court Denies Motion to Vacate Conviction of Cryptocurrency Founder.
    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. Law360.

INTERNATIONAL

  • South Korean CEO is acquitted of $650 million fraud charges
    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. CoinCentralTech in Asia.

REGULATION AND LEGISLATION

UNITED STATES

  • The U.S. Senate Passes GENIUS Act
    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. Senate Banking Committee Press ReleaseThe BlockTruth Social.
  • Senate Banking Hearing on Crypto Market Structure – Calls for Regulation
    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. Bitcoin MagazineCoinDesk.
  • SEC Withdraws Biden-era Proposed Crypto Rules
    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. CoinTelegraphSEC Rulemaking Activity Page.
  • Conference of State Bank Supervisors Issues Money Transmitter Guidance on Virtual Currency and Capital
    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. CSBS Press Release.
  • States Adopt Differing Approaches to Crypto Strategic Reserves
    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. The BlockConnecticut General Assembly WebsiteCoinDesk.
  • Federal Agency Directs Fannie Mae and Freddie Mac To Evaluate Crypto as Asset for Mortgages
    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. The BlockThe Associated Press.

INTERNATIONAL

  • Hong Kong is Building a Tool to Track Suspected Money Laundering Schemes
    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. CoinTelegraphSouth China Morning Post.
  • Coinbase Receives EU Crypto License Under MiCA Rules
    On June 23, Coinbase secured its Markets in Crypto Assets (MiCA) license from the Luxembourg Commission de Surveillance du Secteur Financier (CSSF), enabling Coinbase to offer its full suite of crypto products to all 27 EU member states. CoinbaseThe Block.
  • Hong Kong Stablecoins Ordinance to Take Effect August 1, 2025
    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. HKMA Gibson Dunn.
  • South Korea Moves to Legalize Stablecoins
    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. BloombergCointelegraph.
  • Hong Kong Securities and Futures Commission Launches Consultation to Further Restrict the Use of Misleading Names
    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. SFC.
  • Vietnam Legalizes Cryptocurrency
    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. CointelegraphThe Investor.
  • Singapore Regulator Clarifies Applicability of New Crypto Regulatory Framework
    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. MAS.
  • UK’s FCA To Lift Ban on Crypto Exchange Traded Notes To Support UK Growth and Competitiveness
    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. FCA Press Release; ReutersCNBC.

SPEAKER’S CORNER

UNITED STATES

  • SEC Commissioner Suggests In-Kind Redemption for Crypto ETFs May Be Approved
    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. The Block.

OTHER NOTABLE NEWS

  • SEC Announces New Hires with Crypto Experience
    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. SEC Press Release Announcing SelwaySEC Press Release Announcing DalyThe Block.
  • Circle Raises $1.1 Billion in IPO
    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%. The BlockCNBC.
  • Ethereum Foundation Donates $500,000 to Tornado Cash Co-Founder Roman Storm’s Defense; Paradigm Also Files Amicus Brief in Support
    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. The BlockX Post by Roman StormCrypto.NewsParadigm Amicus Brief.

The following Gibson Dunn lawyers contributed to this issue: Jason Cabral, Kendall Day, Jeff Steiner, Sara Weed, Sam Raymond, Nick Harper, Apratim Vidyarthi, Nicholas Tok, Maura Carey, Amanda Goetz, and Cody Wong.

FinTech and Digital Assets Group Leaders / Members:

Ashlie Beringer, Palo Alto (+1 650.849.5327, aberinger@gibsondunn.com)

Michael D. Bopp, Washington, D.C. (+1 202.955.8256, mbopp@gibsondunn.com)

Stephanie L. Brooker, Washington, D.C. (+1 202.887.3502, sbrooker@gibsondunn.com)

Jason J. Cabral, New York (+1 212.351.6267, jcabral@gibsondunn.com)

Ella Alves Capone, Washington, D.C. (+1 202.887.3511, ecapone@gibsondunn.com)

M. Kendall Day, Washington, D.C. (+1 202.955.8220, kday@gibsondunn.com)

Sébastien Evrard, Hong Kong (+852 2214 3798, sevrard@gibsondunn.com)

William R. Hallatt, Hong Kong (+852 2214 3836, whallatt@gibsondunn.com)

Nick Harper, Washington, D.C. (+1 202.887.3534, nharper@gibsondunn.com)

Martin A. Hewett, Washington, D.C. (+1 202.955.8207, mhewett@gibsondunn.com)

Sameera Kimatrai, Dubai (+971 4 318 4616, skimatrai@gibsondunn.com)

Michelle M. Kirschner, London (+44 (0)20 7071.4212, mkirschner@gibsondunn.com)

Stewart McDowell, San Francisco (+1 415.393.8322, smcdowell@gibsondunn.com)

Hagen H. Rooke, Singapore (+65 6507 3620, hhrooke@gibsondunn.com)

Mark K. Schonfeld, New York (+1 212.351.2433, mschonfeld@gibsondunn.com)

Orin Snyder, New York (+1 212.351.2400, osnyder@gibsondunn.com)

Ro Spaziani, New York (+1 212.351.6255, rspaziani@gibsondunn.com)

Jeffrey L. Steiner, Washington, D.C. (+1 202.887.3632, jsteiner@gibsondunn.com)

Eric D. Vandevelde, Los Angeles (+1 213.229.7186, evandevelde@gibsondunn.com)

Benjamin Wagner, Palo Alto (+1 650.849.5395, bwagner@gibsondunn.com)

Sara K. Weed, Washington, D.C. (+1 202.955.8507, sweed@gibsondunn.com)

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