At the Crossroads of Law, Innovation and Commerce
By: Daniel Knight, Simon Kiburg and Joshua Dries
On 31 March 2026, the Reserve Bank of Australia (RBA) published its conclusions paper titled Merchant Card Payments Costs and Surcharging.
Read MoreBy: Thoreau A. Bartmann, Lance C. Dial, and Sarah V. Riddell
On 17 March 2026, the SEC and CFTC issued a joint interpretive release establishing a formal taxonomy for crypto assets and when such assets are securities under federal law, which is a critical analytical point in determining if regulations apply. While the release is an interpretation of existing laws, and not a final rulemaking, it is a major step toward a durable crypto regulatory regime.
Read MoreBy: Jeremy McLaughlin and Joshua Durham
The California Department of Financial Protection and Innovation (DFPI) recently issued an important industry reminder regarding implementation of the California Digital Financial Assets Law (DFAL). The DFPI noted that it will begin accepting applications today, 9 March 2026, through the Nationwide Multistate Licensing System (NMLS).
Read MoreBy: John ReVeal, Jeremy M. McLaughlin, and Joshua L. Durham
On 13 February 2026, the Financial Crimes Enforcement Network (FinCEN) issued Order FIN-2026-R001 (the Order), granting exceptive relief from FinCEN’s requirement that covered financial institutions identify the beneficial owners of their legal entity customers.
Read MoreBy Daniel Knight, Ben Kneebush and Madison Jeffreys
The Australian Securities and Investments Commission (ASIC) published its long-awaited updates to Information Sheet (INFO 225). This represents the result of ASIC’s consultation process on the existing document (which we have discussed here).
Read MoreBy: John ReVeal and Linda Odom
On 9 October 2025, FinCEN issued Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements (FAQs). They address four specific issues that have needed clarification with respect to suspicious activity report (SAR) filings.
Read MoreBy: Judith Rinearson, Linda Odom, and Joshua L. Durham
Google’s recent announcement of the Agent Payments Protocol (AP2) raises a range of fascinating legal questions. The concept behind AP2 is to have a payment system that allows consumers to instruct AI empowered agents to search for and make purchases on that consumer’s behalf, using “intent mandates” and “cart mandates” that can provide “a non-repudiable audit trail” to establish “authorization and authenticity, providing a clear foundation for accountability.”
Read MoreBy: Judith Rinearson, Jennifer L. Crowder, and Joshua L. Durham
The GENIUS Act (Act) allows “permitted payment stablecoin issuers”—which term includes nonbanks that are either Federal qualified payment stablecoin issuers (FQPSI) (regulated by the OCC) or State qualified payment stablecoin issuers (SQPSI) (regulated by their qualifying state)—to:
By: Lucas Nicolet-Serra, Edward Bennett, and Judith Rinearson
With the passage of the GENIUS Act in the US, there has been an increased focus on how different countries have approached Stablecoin regulation. This blog examines stablecoin regulation in Singapore.
Read MoreBy: Daniel Knight, Ben Kneebush and Thais Fernandes
The Federal Court of Appeal has dismissed ASIC’s appeal and upheld the primary judge’s decision that Finder Wallet’s (Finder) product “Finder Earn” was not a “debenture” and they did not have to hold an Australian Financial Services License (AFSL). ASIC is still considering the implications of this decision and have not yet indicated whether they will seek to appeal to the High Court of Australia.
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