On May 20, the U.S. Senate voted 66-32 to move forward with the Guardrails and Enforcement for Neutral Issuers of United States Stablecoins (GENIUS) Act (the “Act”), pushing the stablecoin bill past a major procedural hurdle. The vote sets the stage for full Senate debate and potential passage of the Act as early as next week.Continue Reading Senate Advances Stablecoin Bill
On May 7, the OCC issued Interpretive Letter 1184, reaffirming that national banks and federal savings associations may provide cryptocurrency custody and execution services, including through sub-custodians. The OCC confirmed that these activities are permissible under existing banking authority so long as banks comply with applicable law and engage in safe and sound practices.Continue Reading OCC Confirms Banks’ Authority to Offer Crypto Custody and Execution Services
On April 4, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance issued a statement clarifying that reserve-backed U.S. dollar stablecoins are not securities, at least under current law and circumstances. The nonbinding guidance marks the latest effort by SEC staff to articulate the boundaries of the agency’s jurisdiction in an evolving crypto regulatory landscape.Continue Reading Digital Dollars, Not Investments: SEC Staff Weighs in on Stablecoins
On April 7, in a significant policy shift, the U.S. Department of Justice (DOJ) announced via the release of a memorandum that it will no longer pursue criminal enforcement actions that effectively impose regulatory frameworks on digital asset companies.Continue Reading DOJ Narrows Crypto Enforcement to Individuals
On April 4, the California Department of Financial Protection and Innovation (DFPI) issued proposed regulations under the Digital Financial Assets Law (DFAL). The proposal provides clarification on DFAL’s licensing framework and identifies when digital asset activity may qualify for exemptions under California’s Money Transmission Act.Continue Reading California DFPI Proposes Digital Asset Licensing Rule
On April 1, the Conference of State Bank Supervisors (CSBS) submitted a letter to the House Financial Services Committee expressing concerns with an introduced draft of H.R. 2392—the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025 (the “Act”)—which purports to establish a comprehensive regulatory framework for payment stablecoins in the U.S. In the letter, CSBS expresses support for the development of a national framework for payment stablecoin issuers (PSIs), while warning that the current draft would unnecessarily preempt state regulatory authority and introduce risks to consumer protection and financial stability.Continue Reading CSBS Flags Key Risks in Draft Stablecoin Legislation
On March 24, Kentucky enacted House Bill 701, establishing a statutory framework to support blockchain-based activity and clarifying the treatment of digital assets under state law. The legislation defines key terms, permits the use of digital assets in commerce, and amends sections of Kentucky’s securities and financial services laws to improve regulatory clarity around crypto-based activities.Continue Reading Kentucky Enacts New Law Establishing Legal Framework for Blockchain and Digital Assets
On March 28, the FDIC issued updated guidance clarifying the process for FDIC-supervised institutions to engage in crypto-related activities. The guidance rescinds and replaces prior instructions issued in 2022 and makes clear that banks no longer need to seek prior FDIC approval before participating in permissible crypto activities.Continue Reading FDIC Updates Crypto Guidance, Removes Pre-Approval Requirement for Banks
Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve, released alongside a White House Briefing, the U.S. government has taken its most formal step yet toward integrating digital assets into national economic and security policy. The order outlines a broader strategy to manage and expand the federal government’s holdings of Bitcoin and other designated cryptocurrencies through the creation of a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile.Continue Reading From Seizures to Strategy: The U.S. Government’s Move Toward a National Crypto Reserve
On March 18, Acting Comptroller of the Currency Rodney Hood reiterated the OCC’s commitment to ensuring fair access to banking services, including for cryptocurrency firms. Speaking at a retail banking industry conference, Hood stated that the OCC would not tolerate so-called “debanking” without individualized risk assessments. He emphasized that banks must evaluate businesses—including those in the crypto sector—based on objective criteria rather than categorical exclusions. Continue Reading OCC Signals Shift on Crypto and Debanking Under Acting Comptroller Hood
On March 7, the OCC issued Interpretive Letter 1183 and an accompanying statement affirming prior guidance regarding whether national banks and federal savings associations may engage in cryptocurrency-related activities, including (i) providing custody services for depositors’ crypto assets, (ii) holding stablecoin “reserves,” (iii) facilitating stablecoin payments, and (iv) performing payment verification activities on blockchain networks. Importantly, the letter also rescinded the OCC’s Interpretive Letter 1179, which required banks to obtain written supervisory non-objection before engaging in these cryptocurrency activities.Continue Reading OCC Clarifies Banks’ Role in Cryptocurrency Activities