By: Judith Rinearson and Kai Zhang
The United Kingdom is quickening the pace on the new crypto regulatory regime. The Financial Conduct Authority (FCA) published three papers in quick succession in May 2025: a discussion on key policy positions (DP25/1) and two consultations on detailed rules (CP25/14 and CP25/15). This blog focuses on CP25/15. Please see our separate blogs on the other proposals by going here and here.
Read MoreBy: Judith Rinearson and Kai Zhang
The United Kingdom is quickening the pace on the new crypto regulatory regime. The Financial Conduct Authority (FCA) published three papers in quick succession in May 2025: a discussion on key policy positions (DP25/1) and two consultations on detailed rules (CP25/14 and CP25/15). This blog focuses on CP25/14. Please see our separate blogs on the other proposals by going here and here.
Read MoreBy: Judith Rinearson and Kai Zhang
The United Kingdom is quickening the pace on the new crypto regulatory regime. The Financial Conduct Authority (FCA) published three papers in quick succession in May 2025: a discussion on key policy positions (DP25/1) and two consultations on detailed rules (CP25/14 and CP25/15). This blog focuses on DP25/1. Please see our separate blogs on the other proposals by going here and here.
Read MoreBy: Judith Rinearson, Jeremy McLaughlin, Jennifer Crowder, and Joshua Durham
Within the past two months, three states have adopted the Money Transmission Modernization Act (MTMA). The governors of Virginia, Mississippi, and most recently Colorado, signed bills that implement the MTMA, and two other states are currently considering similar bills (Alaska and Nebraska).
Read MoreBy: Keri E. Riemer, Richard F. Kerr, and Caroline N. Roethlisberger
On the heels of other guidance issued by the US Securities Exchange Commission’s (SEC) Division of Corporation Finance (Division), the Division released a statement (Statement) on 10 April 2025 addressing its views about, among other things, certain disclosure requirements for certain registration forms under the Securities Act of 1933, including Form S-1, and registration forms under the Securities Exchange Act of 1934, including Form 10. As Form S-1 is used by commodity based exchange-traded products (ETPs), including spot bitcoin and ether ETPs, the Division’s guidance will impact such ETPs and others that follow a similar registration path.
Read MoreBy: Christopher Valente, Scott Gelbman, and Joshua Durham
Artificial intelligence (AI) remains top of mind for lawmakers and regulators, who continue to grapple with new legislative proposals, as well as a changing regulatory regime designed to prepare the US government to interact with AI-related issues, while also positioning the US to be a leader in AI innovation. In line with 15 USC Ch. 119 and Executive Order 14110, two more bipartisan House bills were just introduced to further the government’s response to AI.
Read MoreBy: Jeremy M. McLaughlin and Joshua L. Durham
Good news for the cryptocurrency industry. On 29 September 2024, California Governor Gavin Newsom approved Assembly Bill 1934, which extends the time within which digital assets companies must obtain a license to engage in digital financial asset business activity under the Digital Financial Assets Law (DFAL). Entities now have until July 2026 to obtain licensure, which is a year later than originally planned.
Read MoreBy: Jay Lee and Natalie Chow
The Securities and Futures Commission of Hong Kong (SFC) will now allow tokenized authorized investment products to be offered to retail investors. Recognizing the growing interest in the tokenization of investment products in Hong Kong, on 2 November 2023, the SFC issued a circular outlining the public offering scheme and requirements of tokenized authorized investment products under the Securities and Futures Ordinance for primary dealings. However, secondary trading of such tokenized investment products is not allowed yet.
Read MoreBy John ReVeal and Jeremy McLaughlin
Earned Wage Access (or EWA) programs are popular programs that allow employees to access their salary or wages that have already been earned, prior to the scheduled payroll date. Many argue that these beneficial programs are not truly “loans” because employees are accessing their own money without paying the high fees charged by payday lenders. However, some state regulators disagree, making EWA programs more difficult to access, depending on what state in which the employee lives.
Read MoreBy Drew Hinkes, Eden Rohrer, and Josh Durham
On 28 August 2023, in its first enforcement action for securities registration violations brought against an issuer of NFTs, the SEC settled with media and entertainment company, Impact Theory, LLC (Impact).
The settlement order included findings that from 13 October 2021 to 6 December 2021, Impact sold non-fungible tokens called Founder’s Keys (KeyNFTs) raising approximately US$30 million. Broadly interpreting Howey, the SEC found that the NFTs were sold in investment contracts, based on the company’s public statements about the expected rise in value of the NFTs and its use of profits from sales to develop the company.
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