Category:FinTech Industry & Regulation

1
New FinCEN FAQs Clarify Certain SAR Filing Requirements
2
Will Payment Stablecoins Mean the End of State Money Transmitter Licensing?
3
The Global Stablecoin: Stablecoin Regulatory Framework in Singapore 
4
Australia: Crypto in the Courts – ASIC v Finder Update
5
Australia: Changes Ahead for Australia’s Payments Sector: The RBA Proposes to Ban Card Surcharging
6
United Kingdom: Crypto Regulation: Prudential Requirements
7
United Kingdom: Crypto Regulation: Stablecoin
8
United Kingdom: Crypto Regulation: Regulated Activities
9
United States: The Continuing Shift to Modern Money Transmission Laws
10
FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

New FinCEN FAQs Clarify Certain SAR Filing Requirements

By: 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.

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Will Payment Stablecoins Mean the End of State Money Transmitter Licensing?

By: 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:

  1. Issue and redeem payment stablecoins;
  2. Manage reserves;
  3. Custody payment stablecoins, reserves, or private keys of payment stablecoins; and
  4. Engage in activities that “directly support” the above listed activities.
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The Global Stablecoin: Stablecoin Regulatory Framework in Singapore 

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.

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Australia: Crypto in the Courts – ASIC v Finder Update

By: 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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United Kingdom: Crypto Regulation: Prudential Requirements

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.

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United Kingdom: Crypto Regulation: Stablecoin

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 CP25/14. Please see our separate blogs on the other proposals by going here and here.

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United Kingdom: Crypto Regulation: Regulated Activities

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 DP25/1. Please see our separate blogs on the other proposals by going here and here.

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United States: The Continuing Shift to Modern Money Transmission Laws

By: 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).

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FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

By: John ReVeal, Jeremy M. McLaughlin, Jennifer L. Crowder, and Linda C. Odom

On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency transaction reports (CTRs) for currency transactions of more than US$200 but not more than US$10,000. The regular CTR filing requirement for transactions of more than US$10,000 remains in place, but the GTO effectively reduces the threshold for such filings.

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