Blockchain – FinTech and Blockchain Law Watch

From E-Commerce to A-Commerce: The Dawn of Agentic AI Payments

Oct 02 2025

By: 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.”

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.

Tag:Blockchain