At the Crossroads of Law, Innovation and Commerce
By: 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.
Read MoreBy: Jeremy M. McLaughlin and Joshua L. Durham
On 30 July 2025, the President’s Working Group on Digital Asset Markets published its long-awaited report, entitled “Strengthening American Leadership in Digital Financial Technology” (the Report). The Report introduces actionable directives to the prudential banking regulators to further stablecoin policies, both domestically and internationally, including directives on implementing the GENIUS Act.
Read MoreBy: Cheryl L. Isaac and Clifford C. Histed
The “Strengthening American Leadership in Digital Financial Technology” Report, published in July 2025 by the President’s Working Group on Digital Asset Markets (the PWG), includes comprehensive recommendations for immediate action by the Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC). Notably, the PWG is pushing these regulators to rely on their existing rulemaking and exemptive authority–without waiting for Congress to act – to enable the trading of digital assets and “ensure that American businesses can compete internationally.”
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