Blockchain – FinTech and Blockchain Law Watch

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

Sep 04 2025

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:

Issue and redeem payment stablecoins;
Manage reserves;
Custody payment stablecoins, reserves, or private keys of payment stablecoins; and
Engage in activities that “directly support” the above listed activities.

Australia: Crypto in the Courts – ASIC v Finder Update

Sep 02 2025

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.

United Kingdom: Crypto Regulation: Prudential Requirements

Jul 02 2025

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.

United Kingdom: Crypto Regulation: Stablecoin

Jun 30 2025

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.

United Kingdom: Crypto Regulation: Regulated Activities

Jun 27 2025

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.

Congress Unveils Highly Anticipated Cryptocurrency Market Structure Legislation

May 30 2025

By: Vivian K. Bridges, Joshua L. Durham, and Ryan T. Carney

On 29 May 2025 the House Financial Services Committee (HFSC) and the House Agriculture Committee (Ag) unveiled their highly anticipated cryptocurrency market structure legislation.

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

Mar 17 2025

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.

First JPEX Judgement by a Hong Kong Court in Favor of Customers

Nov 13 2024

By: Jay Lee, Natalie Chow, and Alvin Lam

On 29 October 2024, the Hong Kong District Court issued the judgment of the first legal action (Chan Wing Yan and Another v. JP-EX Crypto Asset Platform Ltd and Others [2024] HKDC 1628) against JPEX, which the Hong Kong Securities and Futures Commission has identified as an unlicensed virtual asset trading platform (VATP).

Banking Regulators’ Growing Concerns over Bank-Fintech Partnerships

Aug 28 2024

By: Jeremy M. McLaughlin, Grant F. Butler, Andrew C. Glass, and Joshua L. Durham

The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) have jointly issued a request for information (RFI) seeking input on the nature, risks, and implications of bank-fintech partnerships. Accompanying the RFI, the agencies issued a joint statement on banks’ arrangements with third parties to deliver bank deposit products and services (Joint Statement). We will be hosting a webinar on this topic on 10 September (register here), and comments to the RFI are due 30 September.

EU/Luxembourg Update: New Blockchain/ DLT Pilot Regime for Financial Instruments Becomes Effective on March 23

Mar 07 2023

By Dr. Jan Boeing and Maxime Barthez[1],

Luxembourg and the EU have taken an important step forward in the area of blockchain and Distributed Ledger Technology (“DLT”). With a view to removing regulatory hurdles to the issuance, trading and post-trading of many financial instruments for which an EU regulatory framework already exists (such as the regulation of transferable securities, units in collective investment undertakings and derivatives under MiFIR, MiFID II and CSDR[2]), the EU has put in place the DLT Pilot Regime through Regulation (EU) 2022/858 of 30 May 2022. The new DLT Pilot Regime applies (with certain limitations) to all (traditional) financial instruments within the meaning of MiFID II[3] that are issued, recorded, transferred and stored using blockchain or distributed ledger technology (“DLT Financial Instruments”).

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