RIADeFiPublished by Ketju Research
Regulation

RIA digital-asset regulatory change ledger

Which authority changed what, for whom, on what date, and what an advisor must do next.

170 published entriesJSON ledger

Educational analysis for financial professionals. Not legal, tax, compliance, or investment advice. Verify current primary sources and consult qualified counsel before implementation.

How to read the ledger

Binding actions, proposals, guidance, enforcement, and political signals are labeled separately. A speech is not a rule. A bill is not a law. Every entry begins with the primary document and records unresolved questions rather than converting a headline into permission.

Official signal · nonbinding Chair of the U.S. Securities and Exchange Commission

SEC Chair directs staff to develop conditional crypto-custody proposal

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

SEC Chair Paul Atkins said he asked staff to develop a proposal clarifying crypto-asset custody for investment advisers and regulated funds. He stated his preferred direction would permit adviser self-custody and use of state trust companies under appropriate conditions. These remarks are the Chair's views and signal prospective rulemaking; they are not a Commission proposal, rule, or presently available custody permission.

Who it affects
  • Investment advisers managing client crypto assets
  • Registered funds and their advisers evaluating crypto-asset custody
  • State trust companies providing digital-asset custody
  • Compliance personnel assessing custody arrangements for assets without an available qualified third-party custodian
What remains unresolved
  • Whether and when the Commission will publish a proposal
  • The conditions that would govern adviser self-custody
  • How any proposal would define eligible state trust companies and address qualified-custodian requirements
  • Whether a future Commission majority will adopt the Chair's preferred approach
Advisor workflow implications
  • Do not treat the speech as authorization to self-custody client crypto assets or use any particular state trust company
  • Inventory crypto-custody arrangements and identify controls that could be affected by a future proposal
  • Monitor the SEC rulemaking docket for operative text, proposed conditions, and transition provisions
Version 1 · published
Proposal · not in effect U.S. Congress

House bill proposes comprehensive digital-asset tax reforms

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

H.R. 10357, the Digital Asset Tax Certainty Act, was introduced in the House and referred to the Committee on Ways and Means. The bill proposes extensive amendments to the Internal Revenue Code governing digital-asset transaction fees, stablecoin transactions, accounting methods, lending, trading, charitable contributions, anti-abuse rules, mining and staking income, investment trusts engaged in staking, broker requirements, and a voluntary disclosure program. It is proposed legislation and has no present legal effect.

Who it affects
  • Taxpayers holding or transacting in digital assets
  • Investment advisers addressing digital-asset tax consequences with clients
  • Digital-asset brokers, dealers, traders, miners, stakers, and lending participants
  • Funds and trusts engaged in digital-asset staking
What remains unresolved
  • Whether either chamber will advance or amend the bill
  • Which proposed effective dates would remain in enacted legislation
  • How Treasury and the IRS would implement provisions requiring regulations or other guidance
Advisor workflow implications
  • Track the bill without treating its proposed tax rules as current law
  • Identify client tax, recordkeeping, staking, lending, and charitable-giving workflows that could require revision if legislation is enacted
  • Avoid communicating proposed exclusions, safe harbors, or accounting methods as presently available
Version 1 · published
Proposal · not in effect Han Wooram, petitioner

Petitioner asks SEC to require verifiable digital-asset reserve disclosures

This item records a proposal. It does not by itself change applicable law.

What changed

A petitioner submitted a rulemaking petition asking the SEC to require public reporting companies with material digital-asset reserves and spot digital-asset ETPs to provide periodic, independent, publicly verifiable evidence of reserve existence and control, together with related custody and governance disclosures. The petition does not represent Commission action, proposed SEC rules, or a present disclosure obligation.

Who it affects
  • Sponsors of spot digital-asset exchange-traded products if the requested rules are proposed and adopted
  • Public reporting companies holding material digital-asset reserves if the requested rules are proposed and adopted
  • Investment advisers conducting diligence on digital-asset ETPs or reserve-holding issuers
What remains unresolved
  • Whether the SEC will act on the petition
  • What issuers, ETPs, assets, and materiality thresholds any agency proposal would cover
  • What verification methods, assurance standards, custody disclosures, and reporting frequency the SEC might consider
Advisor workflow implications
  • Treat the petition as a private request rather than an SEC position or current disclosure requirement
  • Monitor for an SEC response or formal rulemaking before changing compliance representations
  • Consider whether current ETP and issuer diligence captures reserve existence, control, encumbrances, custody arrangements, and reconciliation limitations
Version 1 · published
Official signal · nonbinding Commodity Futures Trading Commission · QCX LLC d/b/a Polymarket US

Polymarket US self-certifies a cryptocurrency-launch event-contract class

This item records a policy signal. It does not by itself change applicable law.

Primary documents
What changed

Polymarket US submitted a September 11 class self-certification for dollar-settled contracts on cryptocurrency launches, targeting listing no earlier than September 15. The class builds on a MetaMask-launch contract and uses live token-price publication to determine qualifying launches. This is an exchange filing, not a Commission approval or evidence that trading has begun.

Who it affects
  • Advisers and commodity-interest professionals evaluating token-launch event exposure
  • Clients with employment, ownership, or family connections to token issuers and launch-data providers
What remains unresolved
  • Actual listing date and availability through client intermediaries
  • Application of source substitutions and settlement-review discretion
  • The filing-page September 10 date differs from the signed September 11 submission
Advisor workflow implications
  • Review settlement-source discretion, full-loss exposure, and launch definitions before product approval.
  • Screen relevant issuer, data-provider, exchange, ownership, and family relationships against trading restrictions.
  • Explain that the contract provides event exposure and does not establish token ownership or validate the token's legal status.
Version 1 · published
Guidance Financial Crimes Enforcement Network

FinCEN identifies digital-asset patterns in Iran-related whistleblower bulletin

Primary documents
What changed

FinCEN issued an Iran-related whistleblower bulletin identifying digital-asset patterns that may indicate sanctions evasion or terrorist financing. Examples include payments involving Iranian exchanges or fronts, unusual corporate digital-asset payments, nested exchanges, and aggregation of small payments from many wallets. The bulletin solicits tips through the existing whistleblower program; it does not create a new sanctions designation or reporting obligation.

Who it affects
  • Digital-asset exchanges, custodians, and intermediaries reviewing Iran-related exposure
  • Advisers reviewing client digital-asset transfers and service-provider controls
  • Individuals with information about potential covered violations
What remains unresolved
  • Whether a particular transaction pattern reflects prohibited activity rather than legitimate conduct
  • Whether an individual tip satisfies statutory and regulatory award requirements
Advisor workflow implications
  • Compare relevant exchange, counterparty, and wallet-monitoring controls with the bulletin's digital-asset examples.
  • Escalate contextual indicators for review without treating an indicator alone as proof of a violation.
  • Preserve transaction and counterparty records and distinguish whistleblower tips from separately applicable reporting duties.
Version 1 · published
Agency order Office of Foreign Assets Control · U.S. Department of the Treasury

OFAC designates Xinbi Guarantee and lists associated TRX addresses

Primary documents
What changed

On September 9, OFAC designated Xinbi Guarantee, Anwen Technology, and SafeW Technology under E.O. 13581, as amended, and listed Xinbi-associated TRX addresses. Treasury connects Anwen to the XinbiPay/NewPay cryptocurrency wallet. Covered property is blocked, with reporting and transaction restrictions subject to applicable authorizations and exemptions. The separately labeled administrative corrections do not impose new sanctions.

Who it affects
  • U.S. advisers, custodians, exchanges, and wallet providers with relevant exposure
  • Clients whose holdings or transaction histories involve the designated network
What remains unresolved
  • Attribution of unlisted wallets and application of ownership rules to affiliates
  • Whether particular exposure requires blocking, reporting, or licensed treatment
Advisor workflow implications
  • Refresh name and wallet screening and review relevant client transaction histories.
  • Check counterparties for designated-person ownership and escalate potential matches.
  • Preserve attribution evidence; a historical wallet connection alone does not establish that every connected asset is blocked.
Version 1 · published · effective 2026-09-09
Proposal · not in effect U.S. Congress

House bill proposes cryptocurrency discovery and audit requirements for federal agencies

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

Representatives Darrell Issa and Lance Gooden introduced H.R. 10317, referred to House Judiciary, to require federal agencies to scan lawfully acquired electronic evidence for cryptocurrency keys, secure discovered assets, and conduct annual digital-asset audits. The bill would require an interagency directive within 180 days after enactment and technical standards for discovery, access controls, evidence integrity, and custody-system logs. It expressly preserves existing limits on searches and seizures and existing legal protections. The bill has not changed current obligations.

Who it affects
  • Federal agencies holding electronic evidence or digital assets
  • Digital-asset custodians and forensic providers supporting federal investigations or recovery
  • Advisers assisting clients whose digital assets or wallet evidence enter federal custody
What remains unresolved
  • Whether Congress will advance, amend, or enact the bill
  • The technical standards and interagency procedures that would follow enactment
  • How agencies would implement discovery and custody controls while preserving existing search limits and legal protections
Advisor workflow implications
  • Track the bill where client recovery or investigation matters involve digital assets in federal custody.
  • Identify wallet ownership, transaction history, and custody records relevant to affected client matters without treating the proposal as a new disclosure or key-delivery obligation.
  • Review any eventual custody and evidence standards with counsel and relevant service providers before changing procedures.
Version 1 · published
Agency order U.S. Securities and Exchange Commission · Nasdaq Texas, LLC

SEC extends broader crypto ETP generic listing standards to Nasdaq Texas

What changed

The SEC's September 3 order, published September 9, approves Nasdaq Texas's amended Rule 5711(d). Qualifying commodity trust ETPs may use active management and hold a combined basket of up to 15% in digital commodities and securities that do not meet the ordinary generic eligibility criteria, with derivatives measured at gross notional value for the limitation. Sponsors must monitor the qualifying threshold daily, and active strategies face additional information-control and trading-halt safeguards. This extends standards previously approved at other exchanges to Nasdaq Texas; it does not approve every product or determine suitability.

Who it affects
  • Sponsors seeking Nasdaq Texas listings for crypto trust ETPs
  • Advisers evaluating actively managed or diversified crypto ETPs
  • Broker-dealers and service providers supporting those listings
What remains unresolved
  • Which products will list under the amended Nasdaq Texas standards
  • How individual products will implement basket monitoring, valuation, liquidity, custody, and information controls
  • Whether later legislation will require amendments to the exchange's digital-commodity definition
Advisor workflow implications
  • Include Nasdaq Texas in tracking of venues offering the expanded generic listing pathway.
  • Review actual holdings, derivative exposure, management discretion, and liquidity rather than assuming generic listing implies a fully conforming passive portfolio.
  • Check product disclosures and sponsor controls for the 15% basket and information-related trading halts before completing product diligence.
Previous interpretation

The published July 29 Cboe BZX approval described the 15% basket and active-management expansion while leaving matching approvals at other exchanges unresolved. The September 3 order confirms matching standards for Nasdaq Texas.

Version 3 · published
Guidance Financial Crimes Enforcement Network

FinCEN issues digital-asset scam-center indicators and reporting instructions

What changed

FinCEN issued FIN-2026-Alert005, supplementing its 2023 digital-asset investment scam alert with scam-center laundering indicators and specific reporting instructions. It requests FIN-2026-SCAMCENTERS in SAR field 2 and the narrative, and Scam Centers under field 34(z), Fraud-Other. An accompanying analysis identifies approximately $12.7 billion in suspected financial activity across 33,904 BSA reports filed from September 8, 2023 through December 31, 2025. That figure is not a measure of proven losses or unique transactions. The alert provides guidance and reminders under existing requirements.

Who it affects
  • Banks, broker-dealers, MSBs, and other covered financial institutions encountering suspected scam proceeds
  • Advisers assisting clients liquidating investments or transferring assets to purported crypto investments
What remains unresolved
  • Whether particular transfers or counterparties are connected to scam activity
  • Whether transferred funds can be recovered; reported activity does not establish liability or recoverability
Advisor workflow implications
  • Review unusual investment liquidations and crypto-transfer requests for scam indicators and escalate concerns through established procedures
  • Preserve wallet, transaction, recipient, and communication records for investigation
  • Covered SAR filers should incorporate the alert's reporting instructions; advisers should coordinate with relevant custodians without assuming new filing duties
Version 1 · published
Official signal · nonbinding CFTC Director of International Affairs and Senior Markets Advisor Mel Gunewardena

CFTC international-affairs director flags cross-border oversight gaps in on-chain markets

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Mel Gunewardena called for supervisory arrangements that address rapid cross-border transmission of risk through tokenized assets, stablecoin settlement, smart contracts, and continuous derivatives markets. He said the CFTC is reviewing the architecture through which foreign markets and institutions access the United States and the arrangements supporting that access. The remarks identify early notification, real-time coordination, and clear crisis responsibilities as priorities. They express the speaker's views and do not adopt Commission policy, alter access rights, or establish new obligations.

Who it affects
  • Foreign derivatives venues and intermediaries serving U.S. participants
  • Advisers and commodity-interest professionals evaluating offshore on-chain derivatives and tokenized collateral
What remains unresolved
  • Which access arrangements the review will change, if any
  • Whether formal proposals, orders, or supervisory agreements will follow
  • The scope and timing of any resulting requirements
Advisor workflow implications
  • Monitor formal outputs affecting access to foreign on-chain venues
  • Include continuous-market incident coordination, collateral dependencies, and cross-border escalation arrangements in relevant venue diligence
  • Keep existing authorization and custody assessments separate from this nonbinding signal
Version 1 · published
Proposal · not in effect Financial Industry Regulatory Authority · U.S. Securities and Exchange Commission

FINRA proposes fraud holds expressly covering customer crypto assets

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The SEC published FINRA's proposal to expressly include crypto assets, such as payment stablecoins held by member firms, within Rule 2165 and proposed Rule 2166 protections. Proposed Rule 2166 would offer an optional safe harbor for delays of up to ten business days when a firm reasonably suspects fraud targeting an adult customer, subject to safeguards including customer notification within two business days. Rule 2165 amendments would permit three additional conditional 30-business-day extensions beyond the existing 55-day framework. The proposal also modifies trusted-contact procedures. SEC approval and a subsequent FINRA effective-date announcement remain pending.

Who it affects
  • FINRA member firms holding customer crypto assets or payment stablecoins
  • Advisers coordinating suspected-fraud responses with clients' broker-dealers
What remains unresolved
  • Whether the SEC will approve or modify the proposal
  • The eventual effective date and firms' operational treatment of crypto-asset disbursements
  • Interaction with applicable state law and contractual hold rights
Advisor workflow implications
  • Map crypto and stablecoin withdrawal escalation procedures to the proposed safeguards for possible implementation after approval
  • Coordinate customer-contact, evidence-preservation, and hold-release procedures with carrying brokers
  • Do not treat the proposal as present authority to hold client assets or permission to offer crypto custody
Version 1 · published
Proposal · not in effect U.S. Securities and Exchange Commission · Cboe EDGA Exchange, Inc. · Cboe BZX Exchange, Inc. · Cboe EDGX Exchange, Inc. · Cboe BYX Exchange, Inc.

Cboe equities exchanges extend Trading Platform data fees to tokenized and decentralized venues

This item records a proposal. It does not by itself change applicable law.

Primary documents
What changed

Cboe EDGA, BZX, EDGX, and BYX filed immediately effective fee-schedule amendments expanding “Trading Platform” beyond exchanges, ATSs, and ECNs to include functionally similar order-matching venues or decentralized platforms, expressly including blockchain-based or tokenized environments. The classification subjects qualifying venues to each exchange's applicable non-display depth-data fees; the filings remain proposed SRO rule changes subject to SEC review and possible suspension.

Who it affects
  • Operators of decentralized or tokenized order-matching venues using Cboe equities depth data for non-display purposes
  • Broker-dealers and other market participants operating tokenized-securities execution platforms
  • Advisers conducting operational and cost diligence on tokenized-securities trading arrangements
What remains unresolved
  • How each exchange will determine whether a decentralized or tokenized arrangement performs sufficiently similar order-matching functions to qualify as a Trading Platform
  • Whether the SEC will suspend the immediately effective filings and institute proceedings
  • How the classification will apply when platform operation or market-data use is distributed among multiple protocol participants or service providers
Advisor workflow implications
  • Review tokenized-securities venue diligence for reliance on Cboe depth data and identify whether the amended Trading Platform classification changes disclosed market-data costs or vendor dependencies
  • Ask affiliated broker-dealers and execution vendors how they assign responsibility for exchange-data licenses and fees in decentralized or tokenized arrangements
  • Treat the filings as immediately effective SRO fee changes subject to continuing SEC review, not as a broader SEC determination about the legal status of decentralized platforms or tokenized securities
Version 1 · published · effective 2026-09-01
Final rule Office of the Comptroller of the Currency · Federal Deposit Insurance Corporation

OCC and FDIC finalize narrower supervisory standards that cover stablecoin-law violations

Primary document
What changed

Effective November 2, 2026, the OCC and FDIC will use a nationwide definition of unsafe or unsound practice requiring conduct contrary to prudent operation that has caused, or is likely to cause, material financial harm or material risk to the Deposit Insurance Fund. The agencies may issue an MRA for conduct meeting a related financial-risk standard or for an actual violation of banking or banking-related law; lesser violations may be directed for remediation without an MRA, and supervisory observations remain informal. The rule requires tailoring to an institution’s risks and reliance on objective facts and sound reasoning. The preamble expressly identifies the GENIUS Act as a newly adopted banking-related law that the agencies must be able to implement and examine.

Who it affects
  • OCC-supervised national banks, federal savings associations, and federal branches or agencies conducting stablecoin, crypto-custody, or other digital-asset activities
  • FDIC-supervised insured state nonmember banks, insured state-licensed foreign branches, and insured state savings associations conducting covered digital-asset activities
  • Investment advisers and funds diligencing supervised banks as digital-asset custodians, stablecoin counterparties, or payment providers
What remains unresolved
  • How OCC and FDIC examiners will apply the material-harm and Deposit Insurance Fund risk thresholds to stablecoin issuance, reserve management, crypto custody, and related operational risks
  • When a GENIUS Act or other digital-asset compliance failure will be treated as an MRA-level violation rather than an other violation requiring remediation
  • How differences between OCC, FDIC, and other regulators’ supervisory frameworks will affect multi-regulator digital-asset banking arrangements
Advisor workflow implications
  • Update bank-custodian and stablecoin-counterparty diligence to account for the November 2 supervisory framework and ask how covered institutions classify and remediate digital-asset findings
  • Do not treat the absence of an MRA as evidence that a bank has no digital-asset compliance weakness, because lesser violations and supervisory observations may follow different channels
  • Reassess escalation and business-continuity procedures where an advisory workflow depends on a supervised bank’s stablecoin, custody, settlement, or payment services
Version 1 · published · effective 2026-11-02
Final rule U.S. Securities and Exchange Commission · Commodity Futures Trading Commission

SEC and CFTC delay Form PF digital-asset reporting amendments to July 2027

Primary documents
What changed

The SEC and CFTC jointly moved the compliance date for the February 2024 Form PF amendments from October 1, 2026, to July 1, 2027. Those amendments add reporting of hedge funds’ digital-asset investment strategies and exposures and exclude digital assets from cash-equivalent reporting. Affected advisers may continue filing the pre-amendment Form PF during the extension while the agencies consider April 2026 proposals that could modify or eliminate portions of the 2024 requirements. The extension rule’s effective date depends on Federal Register publication and was not specified in the retrieved release.

Who it affects
  • SEC-registered investment advisers filing Form PF for hedge funds with digital-asset strategies or exposures
  • Dual SEC-registered advisers and CFTC-registered commodity pool operators or commodity trading advisers subject to Form PF
  • Private-fund compliance, data, operations, and reporting teams implementing digital-asset exposure classifications
What remains unresolved
  • When the extension rule’s effective date will be established through Federal Register publication
  • Whether the agencies will retain, revise, or eliminate the 2024 digital-asset strategy and exposure fields through the pending 2026 rulemaking
  • What transition period and technical specifications will apply if the agencies finalize further Form PF amendments before July 1, 2027
Advisor workflow implications
  • Move the implementation milestone for the 2024 digital-asset fields to July 1, 2027, while preserving completed data-mapping and control work that may remain necessary
  • Continue using the currently permitted pre-2024 Form PF version unless another applicable requirement changes
  • Track the pending 2026 amendments before committing additional resources to fields the agencies may modify or eliminate
Version 1 · published
Agency order Office of Foreign Assets Control · U.S. Department of the Treasury

OFAC extends Iran sanctions to the digital-asset sector and lists associated wallets

What changed

Effective August 24, 2026, OFAC determined that section 1(a)(i) of Executive Order 13902 applies to the digital-asset sector of the Iranian economy, along with four other newly identified sectors. A person later determined to operate in one of those sectors may be sanctioned under the order. In the accompanying SDN update, OFAC also listed multiple XBT, ETH, TRX, and USDT addresses associated with newly designated persons. The sector determination expands OFAC’s designation authority; it does not automatically designate every participant in Iran’s digital-asset sector.

Who it affects
  • U.S. investment advisers, funds, custodians, exchanges, and wallet providers screening digital-asset exposure
  • Digital-asset businesses and counterparties evaluating activity connected to Iran’s digital-asset sector
  • Non-U.S. financial institutions and other persons exposed to Executive Order 13902 sanctions risk
  • Clients or counterparties whose transaction history touches the newly listed blockchain addresses
What remains unresolved
  • How OFAC will define the boundaries of the Iranian digital-asset sector for future designation decisions
  • Which additional exchanges, wallet operators, service providers, or other persons OFAC will determine operate in that sector
  • Whether OFAC will identify additional blockchain addresses or affiliates connected to the newly designated persons
  • How indirect ownership, control, and address attribution should be evaluated for unlisted counterparties
Advisor workflow implications
  • Update sanctions-screening data for the newly listed XBT, ETH, TRX, and USDT addresses and rescreen relevant holdings, counterparties, and transaction history
  • Add the Iranian digital-asset-sector determination to exchange, custodian, protocol, and counterparty diligence without treating all Iranian digital-asset activity as automatically designated
  • Escalate potential name, ownership, control, or wallet matches for sanctions review and preserve the data and reasoning supporting disposition decisions
  • Review client communications and compliance procedures for accurate treatment of designation authority, blocking obligations, and secondary-sanctions risk
Version 1 · published · effective 2026-08-24
Proposal · not in effect U.S. Securities and Exchange Commission

ARK seeks SEC relief for a tokenized interval-fund share class

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The SEC published notice of ARK Venture Fund and ARK Investment Management’s application to amend and supersede earlier multi-class relief. The requested order would permit covered interval funds to add a Tokenized Class whose ownership is recorded using distributed-ledger technology and whose shares may trade on registered ATSs, other quotation media, or through peer-to-peer transfers between approved wallets. Proposed conditions include class-specific expense allocation, disclosure that secondary transactions may occur away from NAV, and AML, KYC, and sanctions reviews before a wallet may hold the tokenized shares. The Commission has not granted the application.

Who it affects
  • ARK Venture Fund and other eligible interval funds advised by ARK or qualifying affiliates
  • Investment advisers evaluating tokenized registered-fund shares for client accounts
  • Broker-dealers, ATS operators, transfer agents, tokenization agents, custodians, and wallet-service providers supporting the proposed class
What remains unresolved
  • Whether the SEC will order a hearing or grant the requested exemptive order
  • Which ATSs, quotation media, blockchain systems, wallets, and service providers would support the Tokenized Class
  • How custody, transfer-agent records, wallet ownership verification, sanctions screening, valuation, liquidity, and transaction reconciliation would operate in practice
Advisor workflow implications
  • Treat the notice as a pending application, not permission to recommend, custody, or trade the proposed tokenized shares
  • If the order is granted and shares are offered, add wallet approval, transfer restrictions, secondary-market pricing, gas fees, liquidity, custody, reconciliation, and service-provider controls to product diligence
  • Confirm that client communications distinguish fund-issued shares at NAV from secondary ATS or peer-to-peer transactions that may occur above or below NAV
Version 1 · published
Official signal · nonbinding Chairman of the Commodity Futures Trading Commission

CFTC Chair directs staff to explore crypto-market and on-chain protocol rules

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

CFTC Chairman Michael Selig said he directed staff to explore rules that could let current registrants and non-registrant crypto exchanges seek designation as a type of designated contract market for leveraged or margined crypto-asset trading under purpose-built oversight. He also directed staff to engage with on-chain finance protocol developers on compliant U.S. pathways. The remarks are the Chairman's nonbinding policy signal, not a Commission rule, registration, exemption, or authorization.

Who it affects
  • Crypto exchanges considering CFTC-regulated leveraged or margined trading
  • Existing CFTC registrants evaluating crypto-market activity
  • Developers of on-chain finance protocols
  • Advisers and commodity-interest professionals evaluating regulated crypto-market access
What remains unresolved
  • Whether Congress will enact the referenced market-structure legislation
  • Whether and when the CFTC will propose rules using existing authority
  • The eligibility, custody, customer-protection, surveillance, and protocol conditions any framework would contain
  • Whether the Commission and courts would agree with the Chairman's view of existing statutory authority
Advisor workflow implications
  • Track resulting rulemaking and staff engagement as a change in policy direction, not current permission for a venue or protocol
  • Continue existing venue-status, custody, leverage, counterparty, and disclosure diligence until operative rules or relief exist
  • Reassess product-access procedures if a formal CFTC crypto-market designation is proposed
Version 1 · published
Proposal · not in effect U.S. Securities and Exchange Commission

SEC proposes a $123 million UST investor distribution plan

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The SEC published a proposed plan for distributing the Tai Mo Shan Fair Fund, comprising approximately $123.1 million plus earnings less expenses, to compensate investors for calculated losses on TerraUSD acquired from May 23, 2021 through May 8, 2022. The notice opens a 30-day comment opportunity; the Commission has not yet approved the plan or established final distribution procedures.

Who it affects
  • Investors who acquired UST during the proposed May 23, 2021 through May 8, 2022 eligibility period
  • Advisers serving clients with potential UST-related recovery claims
What remains unresolved
  • Whether the Commission will approve or modify the proposed plan
  • Final eligibility, loss-calculation, claims, and distribution procedures
Advisor workflow implications
  • Identify potentially affected client accounts without representing that a client is eligible for payment
  • Preserve acquisition, disposition, wallet, exchange, and custody records that may be needed under a final plan
  • Monitor the SEC proceeding for plan approval and final claim instructions
Version 1 · published
Official signal · nonbinding Office of the Comptroller of the Currency

OCC projects a November final rule for supervised payment-stablecoin issuers

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Comptroller Jonathan Gould stated that the OCC expects to issue its final GENIUS Act rule by November 2026. He also reported that 23 of 40 recent national-bank charter applications include some form of digital-asset activity and described stablecoin integration as increasingly ordinary in the OCC's applicant pipeline. The remarks are an official timing and supervisory signal; they do not adopt or make the pending rule effective.

Who it affects
  • National banks and federal savings associations evaluating payment-stablecoin activity
  • Nonbank applicants seeking OCC-supervised payment-stablecoin issuer status or bank charters
  • Advisers, custodians, and clients evaluating OCC-supervised stablecoin structures
What remains unresolved
  • Whether the OCC will meet the stated November target
  • The final eligibility, licensing, reserve, capital, liquidity, redemption, governance, reporting, enforcement, and transition provisions
  • How the final OCC rule will coordinate with Treasury and other regulators' GENIUS Act rules
Advisor workflow implications
  • Track the OCC rulemaking for a final release rather than treating the November target as an effective date
  • For proposed OCC-supervised stablecoin exposure, distinguish pending applicants from approved issuers and document the limits of current authorization
  • Prepare to reassess issuer due diligence, reserve custody, redemption, disclosures, and counterparty controls when final text is issued
Previous interpretation

The OCC's March 2 proposal remained pending without an agency-stated month for issuance of the final rule.

Version 2 · published
Final rule Chicago Mercantile Exchange Inc. · Commodity Futures Trading Commission

CME certifies standard and micro Bitcoin and Ether futures offsets

Primary documents
What changed

CME certified amendments adding Bitcoin, Micro Bitcoin, Ether, and Micro Ether futures to Rule 855's table for offsetting positions in different-sized contracts. The table uses a 50-to-1 relationship for Micro Bitcoin and Bitcoin futures and a 500-to-1 relationship for Micro Ether and Ether futures, with reciprocal ratios of 0.02 and 0.002. CME scheduled effectiveness for September 13, 2026, for trade date September 14, and set position-transfer fees of $0.60 per contract side for Bitcoin offsets and $0.10 per contract side for Ether offsets, subject to the CFTC's certification-review authority.

Who it affects
  • FCMs carrying opposite standard and micro Bitcoin or Ether futures positions
  • CTAs, CPOs, advisers, and clients using CME Bitcoin or Ether futures
What remains unresolved
  • Whether the CFTC will notify CME of review or otherwise stay the certified amendment before its scheduled effective date
  • How individual FCMs will operationalize and make the offset process available to customers
Advisor workflow implications
  • Confirm each executing and carrying broker's implementation date, eligibility process, and customer treatment for Rule 855 offsets
  • Update margin, fee, position-transfer, and reconciliation procedures for portfolios using both standard and micro crypto futures
  • Do not assume an offset is available until the carrying FCM confirms operational support
Version 1 · published · effective 2026-09-13
August 2026 · 15 entries
Proposal · not in effect The Nasdaq Stock Market LLC · U.S. Securities and Exchange Commission

Nasdaq makes a premium liquidity-provider program available to qualifying crypto ETPs

This item records a proposal. It does not by itself change applicable law.

What changed

Nasdaq’s immediately effective SRO filing adds an optional $50,000 Premier Annual Listing Fee and a Quality Liquidity Provider program for qualifying low-volume ETPs, including eligible commodity-based and commodity-futures trust shares used for digital-asset products. Participating issuers may select one qualifying market maker subject to enhanced quoting, depth, and auction metrics; Nasdaq will fund incentives from general revenues and publish program-participation information. The filing became effective August 18, 2026, and Nasdaq designated implementation for September 1, 2026.

Who it affects
  • Issuers of qualifying Nasdaq-listed digital-asset ETPs considering the Premier Annual Listing Fee
  • Nasdaq market makers seeking Quality Liquidity Provider assignments
  • Investment advisers and clients evaluating liquidity and execution quality in lower-volume crypto ETPs
What remains unresolved
  • Which digital-asset ETP issuers will elect the premium tier and which market makers Nasdaq will assign
  • Whether the program measurably improves spreads, depth, and auction performance for participating crypto ETPs
  • Whether the SEC will suspend the immediately effective filing during the statutory 60-day review period
Advisor workflow implications
  • Add QLP participation, assigned market maker, program entry or exit, and applicable performance metrics to digital-asset ETP liquidity diligence
  • Monitor Nasdaq’s required public disclosures and realized spreads and depth rather than assuming participation guarantees better execution
  • Distinguish the immediately effective market-quality program from SEC approval or endorsement of any underlying digital-asset ETP
Version 1 · published · effective 2026-08-18
Enforcement Commodity Futures Trading Commission · U.S. District Court for the Southern District of New York

Federal court enters supplemental CFTC sanctions against former FTX and Alameda executives

Primary documents
What changed

The U.S. District Court for the Southern District of New York entered supplemental consent orders resolving the CFTC's enforcement actions against former Alameda CEO Caroline Ellison and FTX and Alameda co-founder Gary Wang. The orders require continued cooperation, impose five-year trading bans on both defendants, and impose registration bans of ten years for Ellison and eight years for Wang, measured from their December 2022 initial consent orders. The CFTC is not presently seeking restitution, disgorgement, or civil penalties from them, citing their cooperation and related criminal forfeiture.

Who it affects
  • Caroline Ellison and Gary Wang
  • CFTC registrants and trading venues responsible for enforcing the ordered bans
  • Advisers and clients monitoring recoveries, claims, or residual exposure connected to FTX and Alameda
What remains unresolved
  • Any future relief the court or CFTC may consider if cooperation obligations are not satisfied
  • How remaining civil, criminal, bankruptcy, and customer-recovery proceedings involving FTX and Alameda will conclude
  • The practical recovery available to affected customers and investors
Advisor workflow implications
  • Update FTX and Alameda matter files to distinguish these final supplemental sanctions from unresolved bankruptcy and recovery proceedings
  • Screen relevant registration and market-access workflows for the ordered bans
  • Describe the absence of present monetary relief against Ellison and Wang accurately without implying that other defendants, claims, or recovery processes are resolved
Version 1 · published
Proposal · not in effect U.S. Securities and Exchange Commission

SEC proposes tailored crypto-asset offering exemptions and an investment-contract safe harbor

This item records a proposal. It does not by itself change applicable law.

Primary documents
What changed

The SEC proposed Regulation Crypto Assets for certain investment contracts involving crypto assets. A startup exemption would permit up to $5 million of offerings during a four-year period, and a fundraising exemption would permit up to $75 million during each 12-month period, subject to tailored disclosures and other conditions. The proposal also includes a conditional safe harbor under which a non-security crypto asset would no longer be treated as subject to an investment contract after the issuer permanently ends promised essential managerial efforts and satisfies specified conditions. Antifraud and antimanipulation provisions would continue to apply. The proposal is not effective.

Who it affects
  • Crypto-asset issuers and network developers seeking U.S. capital
  • Investment advisers, private funds, and clients evaluating exempt crypto offerings
  • Broker-dealers, custodians, platforms, and compliance teams supporting covered offerings or secondary activity
What remains unresolved
  • The final eligibility, disclosure, reporting, certification, offering-limit, and safe-harbor conditions
  • How the proposal will interact with the SEC's March 2026 crypto interpretation and future federal market-structure legislation
  • Whether and when the SEC will adopt a final rule and what transition treatment it will provide
Advisor workflow implications
  • Do not treat the proposed exemptions or safe harbor as currently available
  • Map private-offering, issuer-diligence, custody, valuation, conflicts, transfer-restriction, and client-disclosure procedures that would need revision if adopted
  • Distinguish the status of the crypto asset from the status of any related investment contract when reviewing offerings and client communications
Previous interpretation

The SEC agenda identified an anticipated July 2026 NPRM on crypto-asset offers, exemptions, and safe harbors, but no proposed rule had yet been issued.

Version 2 · published
Proposal · not in effect U.S. Department of the Treasury

Treasury proposes GENIUS Act rules for payment-stablecoin issuance and U.S. distribution

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

Treasury proposed regulations implementing section 3 of the GENIUS Act. The proposal would interpret the prohibition on U.S. payment-stablecoin issuance by persons other than permitted issuers and address when exchanges, custodians, transfer services, and other digital-asset service providers may offer or make stablecoins available in the United States. It also addresses foreign-issued stablecoins, technological compliance with lawful orders, territorial scope, evasion, and related definitions. Comments are due October 19, 2026; the proposal is not effective law.

Who it affects
  • Payment-stablecoin issuers and applicants for permitted-issuer status
  • Digital-asset exchanges, custodians, transfer services, and other covered service providers
  • Banks, advisers, funds, and clients relying on U.S. or foreign payment stablecoins
What remains unresolved
  • The definitions, territorial tests, exceptions, transition provisions, and compliance dates Treasury will adopt
  • How service providers will verify issuer status and foreign issuers' technological compliance capabilities
  • How the final rule will interact with regulator-specific GENIUS Act rules, reciprocal arrangements, sanctions, AML, and state regimes
Advisor workflow implications
  • Inventory stablecoins used in client, custody, collateral, payment, and treasury-management workflows and identify each issuer's expected regulatory pathway
  • Assess whether exchanges, custodians, and other providers can restrict unsupported stablecoins and document issuer-status checks
  • Do not treat the proposal as currently effective or assume that a foreign stablecoin will remain available in the United States
Previous interpretation

Treasury's September 2025 ANPRM sought broad GENIUS Act implementation input without proposed regulatory text for section 3's issuance, offer, and sale restrictions.

Version 2 · published
Proposal · not in effect U.S. Securities and Exchange Commission · Cboe BZX Exchange, Inc.

Cboe BZX proposes 3x bitcoin- and ether-futures ETFs

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

Cboe BZX filed a proposed rule change to list VS Trust funds seeking three times the daily performance of bitcoin and ether, alongside four non-digital commodities. The proposed funds would obtain exposure primarily through first- or second-month futures and hold cash or cash equivalents as collateral, with specified alternatives when benchmark futures are unavailable. The SEC published the filing for comment; it has not approved the products.

Who it affects
  • Investment advisers evaluating leveraged bitcoin- or ether-futures ETPs
  • Broker-dealers recommending or facilitating transactions in the proposed shares
  • Funds and managed accounts considering short-horizon leveraged digital-asset exposure
What remains unresolved
  • Whether the SEC will approve, disapprove, or institute proceedings on SR-CboeBZX-2026-065
  • The final prospectus disclosures, fees, launch dates, and trading liquidity of the proposed funds
  • How daily leverage, compounding, futures availability, margin, and position limits would perform during stressed crypto markets
Advisor workflow implications
  • Do not treat the proposed bitcoin and ether funds as approved or available products
  • Prepare product-review criteria for daily-reset leverage, compounding, futures basis, collateral, liquidity, volatility, and client holding period
  • Review whether existing options, derivatives, concentrated-position, and complex-product controls would cover the proposed shares
Version 1 · published
Agency order U.S. Securities and Exchange Commission · Nasdaq ISE, LLC

SEC approves expanded weekly expirations for qualifying ISE ETF options, including IBIT

Primary document
What changed

The SEC approved Nasdaq ISE's expansion of its Short Term Option Series Program. Qualifying ETF options may receive up to two additional Tuesday and Thursday expirations under existing Tier 1 criteria and up to two additional Monday and Wednesday expirations under new Tier 2 criteria. The order identifies the iShares Bitcoin Trust ETF as a Tier 1 qualifying security based on the reviewed data, although ongoing eligibility remains subject to the rule's quarterly criteria.

Who it affects
  • Broker-dealers and options market participants trading qualifying ETF options on Nasdaq ISE
  • Investment advisers using IBIT options for exposure, hedging, or risk management
  • Funds and managed accounts considering shorter-dated bitcoin ETP options
What remains unresolved
  • Which products will continue to satisfy the quarterly qualifying criteria
  • How liquidity, strike proliferation, volatility, and assignment risk will develop for the additional expirations
  • Whether other digital-asset ETP options will qualify as their assets and trading volumes change
Advisor workflow implications
  • Update approved-product and options-inventory reviews for any newly listed IBIT expirations
  • Reassess liquidity, spread, gamma, assignment, rollover, and client-disclosure controls for shorter-dated bitcoin ETP options
  • Confirm that expanded exchange eligibility does not replace account-level suitability, fiduciary, concentration, or derivatives-risk review
Version 1 · published
Enforcement Commodity Futures Trading Commission

CFTC alleges a $397 million Goliath crypto liquidity-pool fraud

What changed

The CFTC filed a federal civil complaint alleging that Goliath Ventures and Christopher Delgado fraudulently obtained at least $397 million from approximately 1,611 customers by claiming that customer funds and crypto assets would be deployed to liquidity pools on decentralized exchanges, including pools involving bitcoin and ether. The complaint alleges that defendants deployed no customer funds as represented, used new contributions to make Ponzi payments and pay recruiters, fabricated account statements and audit reports, and misappropriated funds. These are allegations, not adjudicated findings; the CFTC seeks injunctions, restitution, disgorgement, civil penalties, and trading and registration bans.

Who it affects
  • Customers who contributed money or crypto assets to Goliath Ventures
  • Advisers whose clients have direct or indirect exposure to Goliath Ventures or similar purported DeFi liquidity-pool arrangements
  • Compliance and due-diligence teams assessing privately offered digital-asset strategies
What remains unresolved
  • Whether the federal court will find Goliath Ventures or Delgado liable for the CFTC's allegations
  • The amount and availability of restitution, disgorgement, and civil penalties
  • How customer claims will be coordinated with Goliath's bankruptcy and related criminal and SEC proceedings
Advisor workflow implications
  • Identify client accounts, private-fund positions, referrals, or wallet transfers connected to Goliath and preserve relevant records
  • For comparable DeFi strategies, verify claimed on-chain deployments, wallet control, liquidity-pool positions, withdrawal mechanics, and counterparties rather than relying solely on account statements or audit-style assurances
  • Describe the CFTC allegations and pending procedural posture accurately in client communications without treating the complaint as an adjudicated finding
Version 1 · published
Proposal · not in effect U.S. Securities and Exchange Commission · Nasdaq ISE, LLC

Nasdaq ISE proposes broader options-listing criteria for digital-commodity trusts

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

Nasdaq ISE proposed aligning its options-listing criteria with Nasdaq's revised standards for Commodity-Based Trust Shares. The proposal would use the narrower term 'digital commodity,' maintain a $700 million average daily market-value test for each commodity, and allow up to 15% of trust NAV to consist of digital commodities that do not underlie derivatives traded on a market covered by the specified surveillance-sharing arrangement. The SEC has not approved the proposal.

Who it affects
  • Broker-dealers and options market participants
  • Investment advisers evaluating options on digital-commodity trusts
  • Funds and managed accounts using digital-asset ETP options for exposure or hedging
  • Sponsors of Commodity-Based Trust Shares
What remains unresolved
  • Whether the SEC will approve, disapprove, or institute proceedings on SR-ISE-2026-42
  • Which additional Commodity-Based Trust options would become eligible if the proposal is approved
  • How advisers and intermediaries will assess liquidity and surveillance risks attributable to the permitted 15% portfolio component
Advisor workflow implications
  • Update product-review templates to distinguish the proposed ISE options criteria from the listing standards for the underlying trust shares
  • Assess liquidity, concentration, surveillance, valuation, and options-risk disclosures for any newly eligible products
  • Do not represent expanded product eligibility as approved while the SRO filing remains pending
Version 1 · published
Agency order Financial Crimes Enforcement Network

FinCEN renews outbound-transfer reporting order for two Minnesota counties

Primary documents
What changed

FinCEN renewed a Geographic Targeting Order requiring covered banks and money transmitters with a branch, subsidiary, or office in Hennepin or Ramsey County, Minnesota to report specified outbound funds transfers of $3,000 or more. The order requires added originator, beneficiary, government-funds, and transfer-method data, expressly including convertible virtual currency transmissions; monthly filing, five-year retention, supervision, and agent-notification duties apply. The renewed order is effective August 11, 2026 through February 6, 2027.

Who it affects
  • Banks with a branch, subsidiary, or office in Hennepin or Ramsey County, Minnesota
  • Money transmitters and their agents in the covered counties
  • Compliance, operations, and payment-data vendors supporting covered outbound transfers
What remains unresolved
  • Whether FinCEN will renew or expand the order after February 6, 2027
  • How covered firms will validate government-benefit source information and identify international beneficiary institutions
  • How firms will operationalize convertible-virtual-currency and hawala-related data fields across agents and systems
Advisor workflow implications
  • Determine whether any affiliated business or payment service used in a covered workflow is itself a covered bank or money transmitter; the order does not directly impose a new duty on an RIA solely because it advises a client
  • Coordinate with affected custodians or payment providers on holds, information requests, record retention, and client communications for covered outbound transfers
Version 1 · published · effective 2026-08-11
Agency order Office of Foreign Assets Control · U.S. Department of the Treasury

OFAC designates Iranian crypto exchanges and associated wallet addresses

Primary documents
What changed

OFAC added Aban Tether Exchange, the Shelbit exchange network, Crypto Home, NFT Home, Siavash Kayvanpour, and related persons and entities to the SDN List under Iran and counterterrorism authorities. The list update identifies multiple XBT, ETH, TRX, BNB, and SOL addresses and amended Iran-related FAQ 1257. Property and interests in property of blocked persons in the United States or within U.S.-person possession or control are blocked and reportable, and OFAC’s 50-percent ownership rule continues to apply.

Who it affects
  • U.S. investment advisers, funds, custodians, exchanges, and wallet providers screening digital-asset exposure
  • U.S. persons and non-U.S. firms with U.S. sanctions touchpoints
  • Clients or counterparties transacting with the named exchanges, entities, persons, or wallet addresses
What remains unresolved
  • Whether OFAC will identify additional addresses or affiliates associated with the designated exchange networks
  • How indirect ownership and control links affect unlisted counterparties
  • The application of secondary-sanctions authorities to particular non-U.S. transactions
Advisor workflow implications
  • Update sanctions-screening data for the named parties, aliases, and listed wallet addresses and rescreen relevant holdings and transaction history
  • Escalate potential matches for blocking, reporting, counterparty, and legal review without assuming that address-only screening captures all covered property
Version 1 · published · effective 2026-08-07
Proposal · not in effect Commodity Futures Trading Commission

CFTC conflicts and affiliations proposal reaches the Federal Register

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The CFTC’s Conflicts and Affiliations proposal, approved July 30, 2026, was published in the Federal Register on August 6, 2026, opening a comment period that closes October 5, 2026. The proposal would impose SRO and DSRO financial oversight requirements for futures commission merchants, require FCMs to disclose affiliate relationships with SEFs, DCMs, and DCOs, and add conflict-of-interest requirements and impartiality safeguards for registered entities affiliated with FCMs or principal trading firms, including limits on shared staff, technology, office space, and non-public information. Vertically integrated crypto exchange, broker, and clearinghouse structures are the central fact pattern. Nothing is operative yet.

Who it affects
  • Vertically integrated digital-asset market operators holding FCM, DCM, SEF, or DCO registrations
  • Advisers routing client derivatives exposure through affiliated crypto market structures
What remains unresolved
  • Final scope of the affiliate safeguards and any changes after comments
  • Adoption timing
Advisor workflow implications
  • Track the comment file; if adopted, affiliate diligence on integrated crypto venues becomes a checkable regulatory standard rather than a voluntary disclosure
Version 1 · published
Official signal · nonbinding U.S. Department of the Treasury

U.S. and UK regulators report on stablecoin and digital-asset workstreams

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The U.S.-UK Financial Regulatory Working Group published a joint statement on August 4, 2026 after its summer meeting, with participants including Treasury, the Federal Reserve, the OCC, the SEC, and UK counterparts. U.S. authorities updated on GENIUS Act stablecoin implementation and digital-asset market structure work; the statement references the Transatlantic Taskforce for Markets of the Future July 14 recommendations, a U.S.-UK joint statement on stablecoins, tokenization priorities, and the G20 cross-border payments roadmap, with the next meeting planned for early 2027. The statement is an official signal of direction and coordination; it changes no obligation.

Who it affects
  • Stablecoin issuers and banks tracking GENIUS implementation sequencing
  • Advisers monitoring cross-border treatment of stablecoins and tokenized assets
What remains unresolved
  • Which GENIUS implementing rules advance next and on what timeline
Advisor workflow implications
  • No action required; useful context for the pace and direction of stablecoin rulemaking already tracked in this ledger
Version 1 · published
Agency order Federal Deposit Insurance Corporation

FDIC approves deposit insurance for a digital-asset-focused de novo national bank

Primary document
What changed

On August 4, 2026 the FDIC approved the deposit insurance application of Augustus National Bank, N.A., a newly chartered national bank headquartered in Dallas that plans to serve digital-asset firms, AI and technology companies, high-net-worth individuals, and international financial institutions with deposit, lending, virtual-currency, payment, and treasury services, and to issue a stablecoin through a subsidiary if approved under the GENIUS Act. The approval is conditional and lapses if the bank does not open within twelve months. It is a concrete precedent for federally insured banks built around digital-asset clients under the post-GENIUS framework.

Who it affects
  • Digital-asset firms seeking insured banking relationships
  • Advisers evaluating bank custody and cash management options for clients with digital-asset exposure
What remains unresolved
  • Whether the bank opens within the twelve-month condition
  • Terms of any GENIUS Act approval for the planned stablecoin subsidiary
Advisor workflow implications
  • Watch for the bank’s opening and product terms; an insured, crypto-focused national bank changes the custody and cash-management options available to digital-asset clients
Version 1 · published
Enforcement U.S. Securities and Exchange Commission

SEC settles crypto wash-trading claims against market maker Gotbit

Primary document
What changed

On August 3, 2026 the SEC announced a proposed final consent judgment against Gotbit Consulting LLC, a crypto market maker, settling 2024 claims that it wash traded a crypto asset offered and sold as an investment contract. The proposed judgment, filed July 28, 2026 and subject to court approval, would enjoin Gotbit under Securities Act Section 17(a)(1) and (3), Exchange Act Sections 9(a)(2) and 10(b) with Rule 10b-5(a) and (c), and bar it from participating in any securities issuance, purchase, offer, or sale. The SEC voluntarily dismissed its claims against individual defendant Fedor Kedrov; Gotbit separately pleaded guilty in a parallel criminal case. The settlement is without admissions. The action continues the SEC’s treatment of the manipulated crypto asset as subject to an investment contract analysis.

Who it affects
  • Token issuers and trading firms that engage market makers
  • Advisers assessing market integrity of tokens held or considered for client exposure
What remains unresolved
  • Court approval of the proposed judgment
  • Whether similar wash-trading actions follow against other market makers from the same 2024 sweep
Advisor workflow implications
  • Include market-maker manipulation history in diligence on thinly traded tokens; wash-traded volume can misstate liquidity available to clients
Version 1 · published
Agency order U.S. Securities and Exchange Commission

SEC grants review of the Nasdaq PHLX bitcoin index options approval

Primary document
What changed

The Commission granted a petition for review of the order, issued on an accelerated basis by delegated authority and modified by Amendment No. 1, approving Nasdaq PHLX’s proposal to list and trade Nasdaq Bitcoin Index Options, and scheduled the filing of statements in support or opposition. The order was published August 3, 2026. The delegated approval is now before the full Commission, which ordinarily stays its effect pending decision; this is not a merits ruling. The underlying approval had been published May 28, 2026.

Who it affects
  • Exchanges and market makers preparing to list or quote the bitcoin index options
  • Advisers evaluating listed bitcoin index options for client hedging or exposure
What remains unresolved
  • Whether the Commission affirms, modifies, or sets aside the approval, and on what timeline
Advisor workflow implications
  • Treat the product’s availability as unsettled until the Commission acts; note the review in any due diligence on listed crypto derivatives
Version 1 · published
July 2026 · 9 entries
Agency order U.S. Securities and Exchange Commission and Financial Industry Regulatory Authority

SEC approves FINRA underwriting and private-placement filing amendments

Primary document
What changed

The SEC approved FINRA amendments to Rule 5110 that revise valuation and exclusions for specified underwriting compensation, including qualifying debt-for-equity exchanges, DPP and unlisted-REIT capital investments, non-convertible preferred securities, and tail fees. The amendments also expand Rule 5123’s private-placement filing exemption to specified $5 million entities and family offices added to the SEC accredited-investor definition.

Who it affects
  • Broker-dealers participating in public offerings or private placements
  • issuers
  • unlisted REITs and DPPs
  • family offices
  • investment advisers diligencing private offerings
What remains unresolved
  • FINRA’s announced effective date and firm-specific implementation questions
Advisor workflow implications
  • Update underwriting-compensation valuation, exemption, filing, offering-document, accredited-investor, private-placement supervision, and due-diligence procedures when FINRA announces effectiveness.
Version 1 · published
Official signal · nonbinding Commissioner, U.S. Securities and Exchange Commission

SEC Commissioner flags unresolved securities-law issues for crypto vault and lending strategies

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Commissioner Peirce identified securities, investment-company, note, and adviser questions raised by crypto vault and lending strategies and invited engagement; the statement does not bind the Commission.

Who it affects
  • Advisers, protocols, sponsors, and clients using crypto vault or lending strategies
What remains unresolved
  • How the Commission or staff will classify particular strategies and intermediaries
Advisor workflow implications
  • Map strategy economics, managerial efforts, pooling, custody, and compensation before drawing status conclusions.
Version 1 · published
Official signal · nonbinding U.S. Department of the Treasury · HM Treasury

U.S.-UK taskforce recommends cross-border capital-markets and digital-asset alignment

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The bilateral taskforce issued recommendations on cross-border capital raising, supervisory cooperation, tokenized financial activity, continuing industry engagement, and stablecoin market connectivity.

Who it affects
  • Cross-border issuers, asset managers, tokenization platforms, stablecoin firms, investment advisers, and clients
What remains unresolved
  • Which recommendations regulators will implement and on what timetable
Advisor workflow implications
  • Track mutual-recognition, offering, supervision, tokenization, and stablecoin developments; treat the recommendations as nonbinding agenda signals.
Version 1 · published
Official signal · nonbinding Securities and Exchange Commission · Office of Information and Regulatory Affairs

SEC agenda reschedules crypto market-structure amendments

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The SEC agenda continues planned Exchange Act amendments for crypto-asset trading on alternative trading systems and national securities exchanges, moving the anticipated NPRM from April to July 2026.

Who it affects
  • Investment advisers and compliance teams
  • fund sponsors and asset managers
  • regulated intermediaries within the described rulemaking perimeter
What remains unresolved
  • Whether and when the agency will publish an NPRM
  • The proposal text, scope, exemptions, transition period, and final outcome
Advisor workflow implications
  • Track RIN 3235-AN49 and the Federal Register; preserve current controls because Unified Agenda entries are nonbinding planning signals.
Previous interpretation

Prior agenda entry: Proposed Rule Stage; timetable NPRM 04/00/2026.

Version 1 · published
Official signal · nonbinding Internal Revenue Service · Office of Information and Regulatory Affairs

IRS agenda schedules CARF digital-transaction broker reporting

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The July 2026 agenda schedules an NPRM on U.S. broker digital-transaction reporting under the Crypto-Asset Reporting Framework. No matching proposal appeared by July 31.

Who it affects
  • Investment advisers and compliance teams
  • fund sponsors and asset managers
  • regulated intermediaries within the described rulemaking perimeter
What remains unresolved
  • Whether and when the agency will publish an NPRM
  • The proposal text, scope, exemptions, transition period, and final outcome
Advisor workflow implications
  • Track RIN 1545-BQ82 and the Federal Register; preserve current controls because Unified Agenda entries are nonbinding planning signals.
Previous interpretation

Prior agenda entry: Proposed Rule Stage; timetable NPRM 05/00/2026.

Version 1 · published
Official signal · nonbinding Internal Revenue Service · Office of Information and Regulatory Affairs

IRS agenda reschedules digital-asset cash-equivalent reporting rules

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The July 2026 agenda schedules a November 2026 NPRM on reporting digital assets exceeding $10,000 received in a trade or business. The agenda is a planning signal and does not itself activate a new reporting workflow.

Who it affects
  • Investment advisers and compliance teams
  • fund sponsors and asset managers
  • regulated intermediaries within the described rulemaking perimeter
What remains unresolved
  • Whether and when the agency will publish an NPRM
  • The proposal text, scope, exemptions, transition period, and final outcome
Advisor workflow implications
  • Track RIN 1545-BQ45 and the Federal Register; preserve current controls because Unified Agenda entries are nonbinding planning signals.
Previous interpretation

Prior agenda entry: Proposed Rule Stage; timetable NPRM 05/00/2026.

Version 1 · published
Official signal · nonbinding Securities and Exchange Commission · Office of Information and Regulatory Affairs

SEC agenda reschedules adviser and fund custody modernization

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The SEC agenda continues planned Advisers Act and Investment Company Act custody modernization, including crypto assets, and moves the anticipated NPRM from April to October 2026. This is distinct from the withdrawn 2023 safeguarding proposal.

Who it affects
  • Investment advisers and compliance teams
  • fund sponsors and asset managers
  • regulated intermediaries within the described rulemaking perimeter
What remains unresolved
  • Whether and when the agency will publish an NPRM
  • The proposal text, scope, exemptions, transition period, and final outcome
Advisor workflow implications
  • Track RIN 3235-AN46 and the Federal Register; preserve current controls because Unified Agenda entries are nonbinding planning signals.
Previous interpretation

Prior agenda entry: Proposed Rule Stage; timetable NPRM 04/00/2026.

Version 1 · published
Official signal · nonbinding Commodity Futures Trading Commission · Office of Information and Regulatory Affairs

CFTC agenda adds blockchain and digital-asset rulemaking

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The July 2026 Unified Agenda first lists a CFTC proposal to amend regulations for blockchain-based trading systems and digital assets, with an anticipated July 2026 NPRM. No matching proposal appeared in the audited Federal Register window.

Who it affects
  • Investment advisers and compliance teams
  • fund sponsors and asset managers
  • regulated intermediaries within the described rulemaking perimeter
What remains unresolved
  • Whether and when the agency will publish an NPRM
  • The proposal text, scope, exemptions, transition period, and final outcome
Advisor workflow implications
  • Track RIN 3038-AF66 and the Federal Register; preserve current controls because Unified Agenda entries are nonbinding planning signals.
Version 1 · published
Official signal · nonbinding Securities and Exchange Commission · Office of Information and Regulatory Affairs

SEC agenda reschedules broker-dealer crypto financial-responsibility rules

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The SEC agenda continues planned amendments to broker-dealer net-capital, customer-protection, financial-responsibility, recordkeeping, and reporting rules for crypto assets, moving the anticipated NPRM from April to July 2026.

Who it affects
  • Investment advisers and compliance teams
  • fund sponsors and asset managers
  • regulated intermediaries within the described rulemaking perimeter
What remains unresolved
  • Whether and when the agency will publish an NPRM
  • The proposal text, scope, exemptions, transition period, and final outcome
Advisor workflow implications
  • Track RIN 3235-AN48 and the Federal Register; preserve current controls because Unified Agenda entries are nonbinding planning signals.
Previous interpretation

Prior agenda entry: Proposed Rule Stage; timetable NPRM 04/00/2026.

Version 1 · published
June 2026 · 15 entries
Final rule California Department of Financial Protection and Innovation

California finalizes Digital Financial Assets Law licensing regulations

Primary documents
What changed

California finalized regulations implementing DFAL licensing applications and requirements and a Money Transmission Act exemption. Covered businesses serving California residents generally had to be licensed or have a complete application pending by July 1, 2026.

Who it affects
  • Crypto exchanges, custodians, transfer providers, issuers, kiosks, investment advisers, and California clients
What remains unresolved
  • Licensing outcomes, examination practice, stablecoin approvals, and future interpretive guidance
Advisor workflow implications
  • Verify licensing or exemption status and update platform diligence for custody, reserves, disclosures, records, complaints, cybersecurity, financial condition, and California customer coverage.
Version 1 · published
Proposal · not in effect Treasury Department · Comptroller of the Currency

OCC proposes AML and sanctions risk-management standards for supervised stablecoin issuers

This item records a proposal. It does not by itself change applicable law.

What changed

The OCC, coordinating with FinCEN and OFAC, proposed BSA and sanctions compliance risk-management standards for stablecoin issuers under its GENIUS Act jurisdiction.

Who it affects
  • National banks and other OCC-supervised permitted payment stablecoin issuers
What remains unresolved
  • How the final OCC standards will coordinate with the cross-agency stablecoin rules
Advisor workflow implications
  • In issuer diligence, distinguish OCC-specific governance and risk-management expectations from other regulators’ proposals.
Version 1 · published
Proposal · not in effect Financial Crimes Enforcement Network

FinCEN severs Huione Group and proposes covering successor entities

This item records a proposal. It does not by itself change applicable law.

Primary documents
What changed

FinCEN finalized a Section 311 special measure prohibiting covered institutions from providing direct or indirect correspondent-account access to Huione Group, then proposed expanding the definition to H-Pay Service PLC and any successor entity to prevent evasion.

Who it affects
  • Banks, broker-dealers, money services businesses, digital-asset firms, investment advisers, and clients
What remains unresolved
  • Final scope of the successor amendment and additional evasion entities
Advisor workflow implications
  • Block direct and indirect Huione access under the operative final rule and strengthen name, ownership, successor, nested-account, wallet, and payment-flow detection.
Version 1 · published
Proposal · not in effect Treasury Department · Financial Crimes Enforcement Network

Federal agencies propose customer-identification programs for permitted stablecoin issuers

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

FinCEN and the federal prudential regulators jointly proposed requiring permitted payment stablecoin issuers to maintain effective customer identification programs under the GENIUS Act and BSA.

Who it affects
  • Permitted payment stablecoin issuers, intermediaries, and advisers assessing issuer controls
What remains unresolved
  • The final identification, verification, recordkeeping, and reliance requirements
Advisor workflow implications
  • Evaluate whether stablecoin counterparties are preparing for the proposed CIP framework.
Version 1 · published
Proposal · not in effect U.S. Securities and Exchange Commission · Commodity Futures Trading Commission

SEC and CFTC seek comment on harmonizing derivatives product definitions

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The SEC and CFTC jointly opened a request for comment on updating and harmonizing swaps, security-based swaps, mixed swaps, exclusions, novel products, jurisdictional lines, and alternative compliance. The request creates no current exemption or definitional change.

Who it affects
  • Swap and security-based swap market participants
  • Advisers, funds, dealers, venues, clearinghouses, CTAs, CPOs, and clients using novel derivatives
What remains unresolved
  • Whether the agencies will propose rules or interpretations
  • Treatment of mixed, event-based, crypto-linked, and other emerging products
Advisor workflow implications
  • Inventory products whose classification or reporting depends on Title VII definitions
  • Monitor the docket and preserve current compliance treatment until an operative action is adopted
Previous interpretation

The agencies administered existing Title VII definitions without this new joint harmonization review.

Version 1 · published
Proposal · not in effect Securities and Exchange Commission

SEC proposes rescinding the NMS trade-through and locked-market provisions

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The SEC proposed rescinding Regulation NMS’s trade-through rule for NMS stocks, the prohibition on locking and crossing quotations, associated definitions, and related provisions.

Who it affects
  • Broker-dealers, exchanges, ATSs, investment advisers, funds, and clients trading NMS stocks
What remains unresolved
  • Whether the Commission will adopt rescission and how execution and routing practices would change
Advisor workflow implications
  • Assess potential effects on order routing, execution-quality review, policies, disclosures, and vendor systems.
Version 1 · published
Official signal · nonbinding Commodity Futures Trading Commission

CFTC seeks input on innovation and competition for fintech firms

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The CFTC requested information on regulatory barriers and opportunities affecting fintech innovation and competition.

Who it affects
  • Fintech firms, CFTC registrants, commodity pools, CTAs, investment advisers, and clients
What remains unresolved
  • Whether responses will lead to rules, exemptions, guidance, or pilot programs
Advisor workflow implications
  • Treat the request as agenda-setting and identify potential operational or product impacts for comment and planning.
Version 1 · published
Guidance CFTC Division of Market Oversight

CFTC staff permits temporary conversion of existing contracts into true digital-commodity perpetual futures

Primary document
What changed

CFTC staff provided temporary no-action relief allowing designated contract markets to remove expiration dates from certain existing digital-commodity perpetual-style futures while open interest existed, subject to participant notice, exit rights, risk disclosures, limited amendments, and Part 40 filings. The relief expired June 30, 2026.

Who it affects
  • DCMs, FCMs, clearing members, CTAs, CPOs, advisers, and open-position holders
What remains unresolved
  • Longer-term Commission treatment of contract conversions
  • Market, funding, liquidation, margin, and disclosure performance after conversion
Advisor workflow implications
  • Identify whether client positions were amended and whether consent, exit, disclosure, and risk controls were satisfied
  • Do not rely on expired no-action relief for later conversions
Previous interpretation

Existing perpetual-style contracts with expiration dates could not be converted with open interest under this temporary staff path.

Version 1 · published · effective 2026-06-30
Proposal · not in effect New York State Department of Financial Services

NYDFS proposes a GENIUS-aligned stablecoin regulation

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

NYDFS proposed codifying and expanding its dollar-backed stablecoin framework to align with GENIUS Act certification requirements, including custodian concentration limits and formal risk-management programs.

Who it affects
  • New York-licensed stablecoin issuers, reserve custodians, investment advisers, and clients
What remains unresolved
  • Final text, federal certification, effective date, and one-year transition details
Advisor workflow implications
  • Map existing reserve, redemption, audit, custody-concentration, internal-control, affiliate, and service-provider arrangements to the proposal without treating it as final.
Version 1 · published
Proposal · not in effect Federal Deposit Insurance Corporation

FDIC proposes AML and sanctions standards for supervised stablecoin issuers

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The FDIC proposed BSA/AML and sanctions-compliance standards for FDIC-supervised permitted payment-stablecoin issuers under the GENIUS Act.

Who it affects
  • FDIC-supervised stablecoin issuers, banks, compliance vendors, investment advisers, and clients
What remains unresolved
  • Final program standards and coordination with FinCEN, OFAC, and other prudential regulators
Advisor workflow implications
  • Map proposed governance, risk assessment, customer and transaction controls, sanctions screening, testing, reporting, and recordkeeping to issuer diligence.
Version 1 · published
Guidance U.S. Commodity Futures Trading Commission

CFTC staff grants time-limited dormancy relief to Cboe Digital Exchange

What changed

CFTC market-oversight staff granted Cboe Digital Exchange time-limited no-action relief from specified registered-entity dormancy framework provisions.

Who it affects
  • Cboe Digital, its participants, and advisers monitoring regulated digital-asset venues
What remains unresolved
  • Whether the venue resumes activity and whether relief is extended or generalized
Advisor workflow implications
  • Treat the letter as venue-specific and monitor Cboe Digital’s operating status.
Version 1 · published
Enforcement U.S. Department of the Treasury, Office of Foreign Assets Control

OFAC designates Nobitex and associated Iranian digital-asset exchanges

Primary document
What changed

OFAC designated Nobitex, other Iranian digital-asset exchanges, and associated leaders for terror finance, sanctions evasion, ransomware-linked activity, and support for Iran’s financial sector.

Who it affects
  • Digital-asset exchanges, custodians, stablecoin issuers, investment advisers, compliance vendors, and clients
What remains unresolved
  • Additional associated wallets, persons, licenses, and enforcement actions
Advisor workflow implications
  • Refresh sanctions data and controls for exchange attribution, nested services, stablecoin flows, beneficial owners, geolocation, and blocked-property reporting.
Version 1 · published
Official signal · nonbinding New York State Department of Financial Services · European Banking Authority

NYDFS and EBA establish cross-border stablecoin supervisory cooperation

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

NYDFS and the European Banking Authority signed an MOU for confidential-information exchange, risk identification, and supervisory cooperation concerning stablecoin activities of supervised entities.

Who it affects
  • Cross-border stablecoin issuers, regulated custodians and distributors, investment advisers, and clients
What remains unresolved
  • How the authorities will use the MOU in examinations, licensing, and enforcement
Advisor workflow implications
  • Expect greater cross-border information sharing and align issuer, reserve, redemption, and distribution diligence across U.S. and EU regimes.
Version 1 · published
Proposal · not in effect United States Congress

CLARITY Act advances to the Senate legislative calendar

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

After House passage on July 17, 2025 and Senate Banking Committee consideration, H.R. 3633 was placed on the Senate Legislative Calendar on June 1, 2026. It remains pending and changes no current adviser obligation by itself.

Who it affects
  • Digital-asset issuers, protocols, exchanges, brokers, and dealers if legislation is ultimately enacted
  • Advisers classifying assets, venues, and intermediaries
  • Clients using markets that could fall within the proposed SEC-CFTC framework
What remains unresolved
  • Whether and when the Senate will vote on the bill or amend its text
  • The content of any final enacted legislation and implementing rules
  • Transition treatment for existing assets, platforms, and enforcement matters
Advisor workflow implications
  • Track the bill as a legislative proposal rather than current law
  • Do not revise present classifications or compliance procedures solely because of House passage
  • Maintain a change map for workflows that would require reassessment if enacted
Previous interpretation

Federal digital-asset market structure remained governed by existing securities and commodities statutes, agency interpretations, enforcement, and judicial decisions without this proposed allocation enacted.

Version 1 · published
Enforcement Texas State Securities Board

Texas halts an alleged fraudulent tokenized-real-estate offering

Primary document
What changed

Texas issued an emergency cease-and-desist order alleging unregistered and fraudulent offers of tokenized real-estate investments through websites, social media, webinars, and a multilevel marketing network.

Who it affects
  • Tokenized-real-estate issuers, promoters, investment advisers, platforms, and Texas investors
What remains unresolved
  • The respondents’ defenses and final adjudication; allegations are not findings after trial
Advisor workflow implications
  • Treat tokenization as technology rather than an exemption and verify securities registration, intermediary licensing, asset backing, valuation, distributions, conflicts, and marketing claims.
Version 1 · published
May 2026 · 7 entries
Guidance CFTC Division of Clearing and Risk · CFTC Division of Market Oversight · CFTC Market Participants Division

CFTC staff sets expectations for 24/7 trading, clearing, and settlement

Primary document
What changed

CFTC staff issued an advisory on operational, financial-resource, risk-management, surveillance, resilience, staffing, maintenance, customer-protection, and coordination obligations for continuous markets. It does not reduce existing Commodity Exchange Act or Commission requirements.

Who it affects
  • DCMs, SEFs, DCOs, FCMs, clearing members, CTAs, CPOs, and clients
  • Advisers allocating to continuously traded crypto derivatives
What remains unresolved
  • Firm implementation, maintenance windows, liquidity, weekend margining, and cross-market dependencies
  • Whether additional Commission rules will follow
Advisor workflow implications
  • Diligence weekend liquidity, staffing, margin calls, outages, price sources, kill switches, clearing, and client communication
  • Align portfolio monitoring and incident escalation with the venue’s actual operating schedule
Previous interpretation

Registered entities relied on general obligations without this consolidated staff advisory for continuous-market operations.

Version 1 · published
Agency order Commodity Futures Trading Commission

CFTC approves a bitcoin perpetual contract as a futures contract and issues a listing policy

Primary documents
What changed

The CFTC approved a bitcoin-referencing perpetual contract for listing by a designated contract market as a futures contract and issued a policy favoring case-by-case Commission review for other perpetual contract asset classes. The action creates a regulated product precedent, not blanket approval for all perpetuals or venues.

Who it affects
  • DCMs, FCMs, clearing organizations, CTAs, CPOs, advisers, and derivatives clients
What remains unresolved
  • Product launch, liquidity, margin, funding, surveillance, custody, and customer-protection performance
  • Commission review standards for other digital assets and contract designs
Advisor workflow implications
  • Treat perpetual futures as regulated derivatives with leverage, margin, liquidation, funding, and venue risks
  • Verify the exact contract approval, client eligibility, FCM access, disclosures, and portfolio risk controls
Previous interpretation

U.S. regulated venues lacked this Commission-approved true bitcoin perpetual futures precedent and accompanying policy statement.

Version 1 · published
Guidance U.S. Commodity Futures Trading Commission

CFTC staff classifies specified foreign crypto perpetuals and permits conditional margin transfers

What changed

CFTC staff interpreted specified Deribit perpetuals as foreign futures and granted conditional relief for FCM transfers of customer digital commodities and payment stablecoins to a foreign broker as margin under a right of reuse.

Who it affects
  • FCMs, foreign brokers, advisers, and U.S. customers accessing foreign crypto derivatives
What remains unresolved
  • How narrowly the interpretation applies beyond the described contracts and arrangement
Advisor workflow implications
  • Review product classification, foreign-futures access, custody, reuse, disclosure, and counterparty controls before relying on the letter.
Version 1 · published
Official signal · nonbinding President of the United States · Federal financial regulators

Executive Order 14405 directs regulators to reduce barriers for fintech and digital-asset firms

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The President directed federal financial regulators to review rules, guidance, supervision, and application processes for innovation barriers and requested a Federal Reserve review of payment-account access for covered nonbanks and uninsured institutions. The order sets process and policy direction but does not grant any firm a charter, master account, license, or exemption.

Who it affects
  • Federal financial regulators
  • Fintech and digital-asset firms, banks, payment providers, advisers, and custodians
What remains unresolved
  • Agency review results, implementing actions, and Federal Reserve conclusions
  • Legal and risk conditions for any expanded payment-system access
Advisor workflow implications
  • Track agency follow-through rather than changing counterparties based on the order alone
  • Continue verifying licensure, account access, custody, settlement, insurance, and operational resilience of each provider
Previous interpretation

No comparable current executive order required this cross-regulator fintech review and payment-access evaluation.

Version 1 · published
Guidance U.S. Commodity Futures Trading Commission

CFTC replaces its enforcement cooperation policy with a defined path to declination

Primary documents
What changed

The CFTC Division of Enforcement replaced all prior cooperation advisories, including the February 2025 matrix-based self-reporting, cooperation and remediation policy. The May 2026 policy describes a potential declination path, absent aggravating circumstances, for voluntary self-reporting, full cooperation, timely remediation, and full restitution or disgorgement, and specifies cooperation credit when declination is unavailable.

Who it affects
  • CFTC registrants and registered entities
  • Commodity pool operators, commodity trading advisors, futures commission merchants and swap firms
  • Investment advisers and funds with CFTC-regulated affiliates or activity
  • Counsel handling internal investigations and CFTC disclosures
What remains unresolved
  • How the Division will apply aggravating circumstances and cooperation-credit levels in individual matters
  • How referrals and parallel agency or criminal investigations will affect declination decisions
Advisor workflow implications
  • Replace references to the 2025 matrix and referral framework with Staff Advisory 26-15; require counsel-led analysis before self-reporting and preserve evidence of timing, cooperation, remediation, restitution and disgorgement.
Previous interpretation

The February 2025 advisory used a first-ever mitigation-credit matrix, supplemented in April 2025 by operating-division referral criteria. Staff Advisory 26-15 expressly superseded prior cooperation advisories in May 2026.

Version 1 · published · effective 2026-05-19
Enforcement California Department of Financial Protection and Innovation

California crypto-kiosk enforcement wave culminates in Hermes Bitcoin shutdown

Primary documents
What changed

A sequence of DFPI orders applied California’s Digital Financial Assets Law and consumer-protection law to crypto-kiosk operators for excessive charges, transactions above the $1,000 daily limit, deficient receipts and disclosures, insufficient identifying information, and related safeguards. The later Hermes Bitcoin settlement required the operator to cease California activity and surrender its kiosk registration, while other orders imposed penalties and restitution.

Who it affects
  • Digital financial asset transaction kiosk operators in California
  • Crypto businesses and vendors supporting kiosk compliance
  • Consumers using cash-to-crypto kiosks
  • Advisers discussing kiosk access or fraud risks with clients
What remains unresolved
  • Whether DFPI will bring additional DFAL kiosk cases or extend the theories to other digital-financial-asset business models
  • How licensing implementation and federal AML expectations will interact with California kiosk requirements
Advisor workflow implications
  • Treat kiosk transaction limits, total charges, receipts, identity controls, scam warnings, refunds and licensure as active enforcement priorities; advisers should flag irreversible-payment and scam risks when clients propose using crypto kiosks.
Version 1 · published · effective 2026-05-18
Official signal · nonbinding Board of Governors of the Federal Reserve System

Federal Reserve Governor Cook addresses tokenization and financial-system risks

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Governor Lisa Cook discussed tokenization’s potential benefits and its operational, liquidity, leverage, interconnectedness, and financial-stability risks.

Who it affects
  • Banks, tokenization platforms, asset managers, investment advisers, and clients
What remains unresolved
  • How tokenized markets will scale and what additional safeguards regulators may require
Advisor workflow implications
  • Incorporate the identified risk channels into product, platform, custody, liquidity, and counterparty diligence.
Version 1 · published
April 2026 · 9 entries
Official signal · nonbinding Public Company Accounting Oversight Board

PCAOB board member flags crypto audit risks and evidence questions

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

A PCAOB board member used an official crypto roundtable to solicit input on how digital assets affect audit risk, evidence, and execution, continuing the Board-level signal that crypto remains an inspection and standard-setting concern.

Who it affects
  • Public-company and broker-dealer auditors
  • issuers holding digital assets
  • audit committees
  • investment advisers conducting issuer and custodian diligence
What remains unresolved
  • Whether the PCAOB will issue new standards, staff guidance, inspection priorities, or enforcement expectations
Advisor workflow implications
  • Preserve audit-quality, ownership, valuation, evidence, fraud, and control questions in digital-asset counterparty and issuer diligence while monitoring for binding follow-on action.
Version 1 · published
Proposal · not in effect Financial Accounting Standards Board

FASB advances accounting project for crypto transfers and wrapped tokens

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

FASB began deliberations on a proposed accounting-standard update, tentatively voting to expand Subtopic 350-60 to certain wrapped and receipt tokens and to illustrate separate disclosure of significant wrapped-token holdings; derecognition guidance for crypto transfer arrangements remains under development.

Who it affects
  • Public and private companies holding or transferring crypto assets
  • accountants
  • auditors
  • investment advisers evaluating issuer financial statements
What remains unresolved
  • The proposed text, comment period, final scope, transition, effective date, and future derecognition decisions
Advisor workflow implications
  • Track the exposure draft and avoid treating tentative Board decisions as GAAP; identify issuers and advisory businesses whose accounting, disclosures, controls, or valuations may change.
Version 1 · published
Proposal · not in effect Financial Accounting Standards Board

FASB prepares proposal on digital assets as cash equivalents

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

FASB completed initial deliberations and directed staff to draft a proposed Accounting Standards Update clarifying when certain digital assets may be classified as cash equivalents and adding related disclosures and illustrative examples.

Who it affects
  • Entities holding stablecoins or similar digital assets
  • accountants
  • auditors
  • investment advisers evaluating liquidity and financial statements
What remains unresolved
  • Exposure-draft wording, which assets will qualify, comment feedback, final requirements, transition, and effective date
Advisor workflow implications
  • Keep stablecoin and digital-asset liquidity classifications under review and distinguish tentative FASB decisions from current GAAP.
Version 1 · published
Guidance SEC Division of Trading and Markets

SEC staff provides a conditional broker-registration path for self-custodial crypto interfaces

What changed

Trading and Markets staff provided a conditional no-objection framework for specified software interfaces that help users prepare and route self-custodial crypto-asset securities transactions. The framework requires objective routing, constrained compensation, venue diligence, conflict controls, disclosures, cybersecurity and data protections, and expires after five years absent intervening action.

Who it affects
  • Providers of self-custodial wallets and DeFi user interfaces
  • Advisers integrating or recommending onchain transaction tools
  • Trading venues and distributed-ledger systems
What remains unresolved
  • Commission-level rulemaking, facts outside the covered interface model, and treatment of non-security assets
  • How advisory discretion, solicitation, defaults, fees, and affiliated protocols affect the analysis
Advisor workflow implications
  • Compare any client interface against every stated condition before relying on the staff position
  • Review routing neutrality, defaults, fees, venue onboarding, conflicts, cybersecurity, MEV, privacy, disclosures, and the adviser’s separate fiduciary duties
Previous interpretation

Interface providers faced substantial broker-registration uncertainty without this detailed conditional staff framework.

Version 1 · published
Proposal · not in effect Treasury Department · Foreign Assets Control Office · Financial Crimes Enforcement Network

FinCEN and OFAC propose GENIUS Act AML and sanctions programs for stablecoin issuers

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

FinCEN and OFAC jointly proposed treating permitted payment stablecoin issuers as financial institutions under the BSA and requiring risk-based AML/CFT and sanctions compliance programs.

Who it affects
  • Permitted payment stablecoin issuers and advisers diligencing issuers or stablecoins
What remains unresolved
  • The final program standards, effective date, and interaction with prudential-regulator rules
Advisor workflow implications
  • Add the proposal to issuer and stablecoin due-diligence frameworks, but distinguish it from current obligations.
Version 1 · published
Proposal · not in effect Federal Deposit Insurance Corporation

FDIC proposes GENIUS Act standards and reserve treatment for supervised stablecoin issuers

This item records a proposal. It does not by itself change applicable law.

What changed

The FDIC proposed approval and operating standards for FDIC-supervised permitted payment stablecoin issuers, treatment of reserve deposits, and tokenized-deposit distinctions, then separately proposed BSA and sanctions standards.

Who it affects
  • FDIC-supervised banks, their stablecoin subsidiaries, and advisers evaluating their products
What remains unresolved
  • The final approval, reserve, capital, liquidity, and compliance standards
Advisor workflow implications
  • Track issuer authorization and reserve representations in product and counterparty diligence.
Version 1 · published
Guidance U.S. Department of the Treasury

Treasury opens cyber-threat information sharing to eligible digital-asset firms

Primary document
What changed

Treasury launched an OCCIP initiative providing eligible U.S. digital-asset firms and industry organizations timely cyber-threat information used by traditional financial institutions.

Who it affects
  • Digital-asset firms, custodians, exchanges, investment advisers, cyber vendors, and clients
What remains unresolved
  • Eligibility, participation terms, coverage, and measurable adoption
Advisor workflow implications
  • Ask material digital-asset counterparties whether they participate and how threat intelligence feeds detection, incident response, vendor risk, and client communications.
Version 1 · published
Proposal · not in effect Financial Crimes Enforcement Network

FinCEN proposes risk-based AML/CFT program reform

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

FinCEN proposed superseding its 2024 AML-program proposal with a framework emphasizing effective, reasonably designed, risk-based programs; distinguishing design from implementation deficiencies; clarifying testing and audit roles; and formalizing consultation on major supervisory actions.

Who it affects
  • Banks, broker-dealers, MSBs, mutual funds, futures firms, insurers, and other BSA-covered institutions
What remains unresolved
  • Final program standards, regulator-specific implementation, and transition timing
Advisor workflow implications
  • Compare current risk assessment, governance, testing, resource allocation, issue classification, and regulator-engagement processes with the proposal while retaining operative rules.
Version 1 · published
Proposal · not in effect U.S. Department of the Treasury

Treasury proposes principles for certifying state stablecoin regimes

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

Treasury proposed broad principles for deciding when a state payment-stablecoin regulatory regime is substantially similar to the federal GENIUS Act framework.

Who it affects
  • State-chartered stablecoin issuers, state regulators, custodians, investment advisers, and clients
What remains unresolved
  • Final certification standards, application process, and treatment of existing state regimes
Advisor workflow implications
  • Compare state issuer oversight, reserves, redemption, governance, examination, enforcement, and transition provisions with the proposed federal similarity criteria.
Version 1 · published
March 2026 · 9 entries
Proposal · not in effect Labor Department · Employee Benefits Security Administration

DOL proposes an ERISA prudence safe harbor for plan options with alternative assets

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

DOL proposed clarifying ERISA prudence duties and a safe harbor for selecting designated investment alternatives, including asset-allocation funds containing alternative assets, in response to Executive Order 14330.

Who it affects
  • ERISA plan fiduciaries, retirement-plan advisers, asset managers, and participants
What remains unresolved
  • Whether the safe harbor will be adopted and what conditions will survive
Advisor workflow implications
  • Evaluate plan-investment diligence and documentation against the proposal without treating it as current law.
Version 1 · published
Official signal · nonbinding Board of Governors of the Federal Reserve System

Federal Reserve Governor Barr flags stablecoin implementation priorities

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Governor Michael Barr gave official remarks on stablecoin oversight and implementation considerations following enactment of the federal framework.

Who it affects
  • Stablecoin issuers, banks, payment firms, investment advisers, and clients
What remains unresolved
  • Final interagency rules, supervisory expectations, and market structure
Advisor workflow implications
  • Track implementation priorities while awaiting binding rules and final supervisory standards.
Version 1 · published
Enforcement Texas State Securities Board

Texas resolves securities allegations against Voyager Digital entities

Primary document
What changed

Texas entered a consent order resolving allegations that Voyager entities offered unregistered crypto-related securities, acted without required dealer or agent registration, and made misleading statements concerning the Voyager Earn Program.

Who it affects
  • Crypto lending and brokerage platforms, investment advisers, promoters, and Texas investors
What remains unresolved
  • Claims, distributions, and obligations arising through bankruptcy or other jurisdictions
Advisor workflow implications
  • Confirm state securities and intermediary registration, product characterization, yield-program disclosures, custody, insolvency, and promotional representations.
Version 1 · published
Guidance CFTC Market Participants Division · CFTC Division of Clearing and Risk

CFTC staff publishes FAQs for registrant crypto and blockchain activities

What changed

CFTC staff published implementation FAQs addressing registered-entity and registrant use of crypto assets and blockchain technology, with particular focus on tokenized collateral and digital-asset margin. The FAQs clarify staff positions but do not expand statutory authority or make every digital asset eligible collateral.

Who it affects
  • FCMs, DCOs, clearing members, CTAs, CPOs, and derivatives customers
  • Advisers using tokenized or digital-asset collateral arrangements
What remains unresolved
  • Firm-specific interpretations and future Commission rulemaking
  • Operational treatment across custodians, chains, and insolvency regimes
Advisor workflow implications
  • Incorporate the FAQs into derivatives-counterparty and collateral reviews
  • Verify eligibility, valuation, haircuts, segregation, custody, settlement, liquidity, and default procedures for the exact arrangement
Previous interpretation

Letters 25-39 and 26-05 supplied the core staff positions without the later implementation answers.

Version 1 · published
Guidance U.S. Commodity Futures Trading Commission

CFTC staff grants conditional registration relief for self-custodial wallet software

What changed

CFTC market-participant staff granted a conditional no-action position from introducing-broker and associated-person registration for a self-custodial wallet software provider facilitating trading with registered intermediaries and markets.

Who it affects
  • Wallet providers, FCMs, IBs, DCMs, and advisers assessing self-custodial trading tools
What remains unresolved
  • The limits of the conditions and whether comparable providers will receive relief
Advisor workflow implications
  • Verify that any relied-on arrangement fits the letter’s facts and conditions.
Version 1 · published
Guidance U.S. Securities and Exchange Commission · Commodity Futures Trading Commission

SEC issues Commission-level interpretation for crypto-asset status and transactions

Primary document
What changed

The Commission issued an effective interpretive release describing its treatment of specified crypto-asset categories and transactions, while the CFTC stated how it would administer the Commodity Exchange Act consistently with that interpretation.

Who it affects
  • Advisers classifying crypto assets and transaction structures
  • Crypto-asset issuers, protocols, intermediaries, and platforms
  • Clients holding or transacting in assets addressed by the interpretation
What remains unresolved
  • Application to instruments and arrangements whose facts do not fit the release's categories
  • The effect of later legislation, rulemaking, enforcement, and judicial decisions
  • How state-law, tax, custody, and other federal requirements apply independently
Advisor workflow implications
  • Revisit asset-status memoranda against the Commission-level taxonomy and transaction analysis
  • Separate the asset itself from an investment-contract transaction or wrapper
  • Record factual assumptions rather than extending the interpretation to unaddressed products
Previous interpretation

Earlier Ketju materials treated asset status as highly fact-specific and relied primarily on judicial decisions, enforcement positions, and staff-level statements rather than a Commission-level crypto taxonomy.

Version 1 · published · effective 2026-03-23
Official signal · nonbinding U.S. Securities and Exchange Commission · Commodity Futures Trading Commission

SEC and CFTC sign a formal regulatory-harmonization memorandum

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The SEC and CFTC formalized coordination and information-sharing processes for overlapping regulatory interests, including crypto assets, dual registrants, trading venues, derivatives, funds, data, examinations, and enforcement. The MOU governs agency cooperation and does not itself change a registrant’s substantive obligations.

Who it affects
  • SEC and CFTC registrants and dually regulated firms
  • Advisers, funds, broker-dealers, FCMs, exchanges, clearinghouses, and market infrastructure providers
What remains unresolved
  • Which joint rules, relief, examinations, or data programs will follow
  • How the agencies will resolve asset- and product-specific jurisdiction
Advisor workflow implications
  • Expect more coordinated requests and harmonized initiatives
  • Continue complying with each applicable regime until an operative joint or agency action changes it
Previous interpretation

Agency cooperation existed through statements and events without this new comprehensive formal MOU.

Version 1 · published · effective 2026-03-11
Proposal · not in effect Internal Revenue Service · U.S. Department of the Treasury

Treasury and IRS propose an alternative electronic-delivery process for Form 1099-DA

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

Treasury and the IRS proposed an alternative process for brokers to furnish Form 1099-DA electronically without the existing affirmative-consent and withdrawal framework, subject to enhanced electronic notice and access safeguards. The proposal is not effective until finalized.

Who it affects
  • Digital-asset brokers
  • Advisers coordinating client tax-document workflows
  • Clients receiving Form 1099-DA
What remains unresolved
  • Final rule text, effective date, delivery safeguards, and broker adoption
  • Treatment of consolidated statements and clients without reliable electronic access
Advisor workflow implications
  • Monitor rather than implement the proposed process as final
  • Maintain client education and record-reconciliation plans independent of delivery method
Previous interpretation

Brokers generally needed affirmative consent under existing electronic-furnishing rules or had to provide paper statements.

Version 1 · published
Guidance Board of Governors of the Federal Reserve System · Federal Deposit Insurance Corporation · Office of the Comptroller of the Currency

Banking agencies clarify capital treatment of tokenized securities

Primary document
What changed

The federal banking agencies clarified that tokenization does not by itself change the regulatory-capital treatment of a security; banks must analyze the underlying exposure and applicable capital rules while managing tokenization-specific risks.

Who it affects
  • Banks holding or servicing tokenized securities, investment advisers, funds, broker-dealers, and clients
What remains unresolved
  • Application to particular token structures, settlement arrangements, and operational-risk profiles
Advisor workflow implications
  • Do not assume tokenization changes an instrument’s prudential classification; document underlying exposure, custody, settlement, technology, and counterparty risks.
Version 1 · published
February 2026 · 2 entries
Guidance SEC Division of Trading and Markets

SEC trading staff expands crypto and distributed-ledger FAQs for intermediaries

What changed

Trading and Markets staff published crypto and distributed-ledger FAQs in May 2025, expanded them in December 2025, and added a payment-stablecoin net-capital position on February 19, 2026. The current FAQs address broker-dealer possession and control, capital haircuts, SIPC limits, non-security asset records and insolvency treatment, transfer-agent registration and DLT records, ATS and exchange pairs trading, clearance, settlement, and crypto ETP activity. They remain staff views without legal force.

Who it affects
  • Broker-dealers and transfer agents supporting advisory clients
  • Advisers diligencing crypto ETP, custody, execution, and settlement providers
What remains unresolved
  • Future FAQ revisions or Commission rulemaking
  • Application of the staff positions to particular assets, control arrangements, insolvency facts, transfer-agent functions, and intermediary structures
  • The treatment of payment stablecoins once GENIUS Act implementing rules become effective
Advisor workflow implications
  • Use the current FAQ version in broker-dealer, custodian, transfer-agent, ATS, crypto ETP, SIPC, stablecoin-capital, recordkeeping, and insolvency diligence while distinguishing staff views from binding Commission rules.
Previous interpretation

The earlier draft reflected the initial May 2025 FAQ publication and noted later expansion, but did not capture the February 2026 payment-stablecoin net-capital addition.

Version 1 · published
Guidance CFTC Market Participants Division

CFTC staff permits conditional use of specified digital assets as FCM margin collateral

Primary document
What changed

CFTC staff provided a conditional no-action position for FCMs accepting specified payment stablecoins and other non-security digital assets as margin collateral and recognizing their value for identified capital and segregation calculations. The reissued letter expands the payment-stablecoin issuer definition to include a qualifying national trust bank.

Who it affects
  • FCMs, derivatives customers, clearing members, CTAs, and CPOs
  • Advisers using crypto collateral for futures and options accounts
What remains unresolved
  • FCM adoption, eligible-asset lists, haircuts, custody, segregation, and liquidation practices
  • Durability of staff relief and interaction with future Commission rules
Advisor workflow implications
  • Diligence FCM eligibility criteria, concentration limits, haircuts, custody, segregation, liquidation, and stablecoin redemption
  • Explain that collateral acceptance does not establish investment suitability or eliminate volatility and operational risk
Previous interpretation

The earlier Letter 25-40 did not expressly include a national trust bank within the specified payment-stablecoin issuer definition.

Version 1 · published
January 2026 · 3 entries
Official signal · nonbinding SEC Divisions of Corporation Finance, Investment Management, and Trading and Markets

SEC staff distinguishes issuer-sponsored, custodial, and synthetic tokenized securities

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Three SEC divisions published a joint staff taxonomy separating issuer-sponsored tokenization from third-party custodial and synthetic structures. The statement expressly has no legal force and creates no new obligations.

Who it affects
  • Advisers evaluating tokenized securities and tokenized funds
  • Platforms and custodians representing securities onchain
  • Clients offered third-party tokens linked to securities
What remains unresolved
  • Legal characterization of specific products outside the statement's assumptions
  • State commercial-law treatment, perfection, custody, and transfer mechanics
  • Whether a particular synthetic structure is a security-based swap or another security
Advisor workflow implications
  • Identify whether tokenization is issuer-sponsored or performed by an unaffiliated third party
  • Verify whether the client owns the referenced security, a security entitlement, or only synthetic exposure
  • Do not cite the staff statement as Commission approval or a safe harbor
Previous interpretation

Ketju's existing framework required looking beneath the token wrapper but did not use this three-part SEC staff taxonomy.

Version 1 · published
Enforcement California Department of Financial Protection and Innovation

California fines Nexo $500,000 over unlicensed crypto-backed lending

Primary document
What changed

The DFPI consent order requires Nexo Capital to pay a $500,000 administrative penalty after findings that it made thousands of California consumer and commercial loans without a California Financing Law license and without required ability-to-repay underwriting. It also requires remaining California customer funds to be transferred to a licensed U.S. affiliate.

Who it affects
  • Crypto lenders serving California residents
  • Platforms and advisers referring clients to crypto-backed credit products
  • California consumers with assets or loans at offshore digital-asset firms
What remains unresolved
  • How California will apply its lending and consumer-protection laws to other crypto-collateralized products
  • Whether customer transfers to the licensed affiliate produce additional restrictions or remediation
Advisor workflow implications
  • Confirm lender licensing, jurisdictional availability, underwriting and disclosures before recommending or linking to crypto-backed borrowing; identify offshore-provider and affiliate-transfer risk in diligence and client communications.
Version 1 · published · effective 2026-01-14
Proposal · not in effect Securities and Exchange Commission

SEC proposes higher small-entity thresholds for advisers and investment companies

This item records a proposal. It does not by itself change applicable law.

What changed

The SEC proposed increasing asset-based thresholds that define small investment advisers and investment companies for Regulatory Flexibility Act analysis, adding periodic inflation adjustments, and amending Form ADV and the continuing hardship exemption rule.

Who it affects
  • Smaller registered investment advisers and investment companies
What remains unresolved
  • Whether the proposal will be adopted and the final thresholds and Form ADV changes
Advisor workflow implications
  • Track the proposal but do not treat RFA small-entity status or filing procedures as changed.
Version 1 · published
December 2025 · 11 entries
Guidance National Futures Association

NFA adds filings for FCMs accepting digital assets as margin collateral

Primary document
What changed

NFA announced new filing obligations for futures commission merchants that accept non-securities digital assets as margin collateral.

Who it affects
  • FCMs, derivatives customers, commodity pools, CTAs, investment advisers, and clients posting digital-asset collateral
What remains unresolved
  • Firm implementation practices and any later amendments as CFTC collateral relief evolves
Advisor workflow implications
  • Confirm FCM filing status and integrate digital-collateral eligibility, valuation, custody, liquidity, and disclosure controls into diligence.
Version 1 · published
Proposal · not in effect Federal Deposit Insurance Corporation

FDIC proposes approval procedures for bank-subsidiary stablecoin issuance

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The FDIC proposed application and approval procedures for FDIC-supervised banks and savings associations seeking to issue payment stablecoins through subsidiaries under the GENIUS Act.

Who it affects
  • FDIC-supervised institutions, stablecoin subsidiaries, reserve custodians, investment advisers, and clients
What remains unresolved
  • Final approval criteria, timing, conditions, and interaction with later prudential standards
Advisor workflow implications
  • Map proposed application, governance, capital, liquidity, reserve, operational, and supervisory requirements when diligencing bank-issued stablecoins.
Version 1 · published
Guidance SEC Division of Trading and Markets

SEC trading staff states conditions for broker-dealer possession of crypto-asset securities

What changed

Trading and Markets staff described a conditional path for broker-dealers to deem themselves in physical possession of customer crypto-asset securities, including network assessment, private-key controls, incident planning, transfer capability, and wind-down arrangements. The Division also expanded its FAQs on custody, trading, and settlement; both are staff views rather than Commission rules.

Who it affects
  • Broker-dealers carrying crypto-asset securities
  • Advisers and clients relying on broker-dealer custody or tokenized-security trading
What remains unresolved
  • Commission amendments to Rule 15c3-3 and treatment of non-security crypto assets
  • How FINRA will examine implementations and approve material business changes
Advisor workflow implications
  • Require evidence of network assessment, exclusive key control, fork and airdrop procedures, lawful freeze capability, incident response, and wind-down transfer planning
  • Distinguish possession, control-location, and qualified-custodian analyses across the adviser and broker-dealer regimes
Previous interpretation

The 2020 special-purpose broker-dealer framework and earlier FAQs supplied a narrower and less integrated custody path.

Version 1 · published
Enforcement U.S. Department of the Treasury, Office of Foreign Assets Control

OFAC settles sanctions violations with Exodus Movement

Primary document
What changed

OFAC announced a settlement with Exodus Movement concerning apparent sanctions violations associated with its digital-asset products and services.

Who it affects
  • Digital-asset wallet and software providers, investment advisers, and clients using self-hosted wallet tools
What remains unresolved
  • Application of the settlement’s compliance expectations to differing wallet and software architectures
Advisor workflow implications
  • Assess sanctions-risk controls, location screening, blocked-jurisdiction access, escalation, and vendor or software-provider diligence.
Version 1 · published
Guidance Commodity Futures Trading Commission

CFTC withdraws its retail digital-asset commodity-transaction guidance

Primary document
What changed

The CFTC withdrew its 2020 interpretive guidance on actual delivery for retail commodity transactions involving certain digital assets, removing that guidance as the Commission reconsidered its approach.

Who it affects
  • Digital-asset platforms, intermediaries, advisers, and retail clients
What remains unresolved
  • What replacement interpretation or rule, if any, the CFTC will adopt
Advisor workflow implications
  • Do not rely solely on the withdrawn guidance when evaluating leveraged retail digital-asset arrangements.
Version 1 · published
Official signal · nonbinding Financial Stability Oversight Council

FSOC’s 2025 annual report sets digital-finance monitoring priorities

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

FSOC’s annual report recommended monitoring GENIUS Act implementation and related Treasury-market effects while expanding cyber information sharing, exercises, third-party oversight coordination, and quantum-resilience work.

Who it affects
  • Financial institutions, stablecoin issuers, asset managers, investment advisers, critical service providers, and clients
What remains unresolved
  • How member agencies will translate the recommendations into supervision or rulemaking
Advisor workflow implications
  • Treat the report as a systemic-risk agenda signal and incorporate reserve-market, cyber, third-party, and operational-resilience dependencies into diligence.
Version 1 · published
Guidance SEC Division of Trading and Markets

SEC trading staff grants conditional no-action relief for DTC tokenization services pilot

Primary document
What changed

Trading and Markets staff provided conditional no-action relief for DTC to develop and launch a limited voluntary tokenization service for eligible security entitlements held by DTC participants. The pilot is subject to asset, participant, blockchain, control, reporting, and time limits and does not broadly approve third-party tokenization models.

Who it affects
  • DTC participants, broker-dealers, custodians, transfer agents, and issuers
  • Advisers evaluating tokenized securities and settlement providers
What remains unresolved
  • Pilot adoption, eligible assets and chains, interoperability, finality, and legal treatment
  • Whether the Commission will adopt durable rules available beyond DTC
Advisor workflow implications
  • Distinguish a DTC-recorded tokenized entitlement from direct issuer-record ownership or synthetic exposure
  • Diligence rights, records, wallet controls, transfer restrictions, settlement, corporate actions, and recovery procedures
Previous interpretation

DTC did not have this staff relief for a live tokenized-entitlement service on supported blockchains.

Version 1 · published
Enforcement Financial Crimes Enforcement Network

FinCEN penalizes Paxful for willful BSA failures

Primary document
What changed

FinCEN assessed a $3.5 million penalty after Paxful admitted willful failures to register as an MSB, maintain an effective AML program, and file SARs while facilitating more than $500 million in suspicious activity involving illicit actors and high-risk jurisdictions.

Who it affects
  • Peer-to-peer trading platforms, MSBs, investment advisers diligencing venues, and clients
What remains unresolved
  • Continuing remediation and related actions by partner agencies
Advisor workflow implications
  • Benchmark platform diligence against registration, risk assessment, sanctions geography, transaction monitoring, SAR backlogs, governance, and remediation expectations.
Version 1 · published
Guidance Financial Industry Regulatory Authority

FINRA’s 2026 oversight report updates crypto supervision and communications findings

Primary document
What changed

FINRA updated its annual examination and compliance observations for member firms with crypto-asset activity, emphasizing supervision, public communications, due diligence, AML, associated-person activity, recordkeeping, and accurate statements about FINRA or SIPC protections. The report describes existing obligations and findings rather than creating a new rule.

Who it affects
  • FINRA member firms and registered representatives
  • Dual registrants and advisers routing clients through member firms
What remains unresolved
  • Firm-specific exam findings and future targeted reviews
  • How evolving federal crypto rules will alter member obligations
Advisor workflow implications
  • Map dual-registrant crypto activities to FINRA supervision and communications controls
  • Review client materials for unsupported safety, approval, insurance, or SIPC claims and document product due diligence
Previous interpretation

The 2025 report supplied the prior annual snapshot before the 2026 examination observations and references.

Version 1 · published
Guidance CFTC Market Participants Division · CFTC Division of Clearing and Risk

CFTC staff issues guidance for tokenized assets used as derivatives collateral

Primary document
What changed

CFTC staff stated that distributed-ledger tokenization does not by itself change whether an asset is eligible regulatory collateral and set out legal, custody, settlement, valuation, liquidity, operational, cybersecurity, governance, and segregation considerations. The guidance does not make an otherwise ineligible asset eligible.

Who it affects
  • DCOs, FCMs, clearing members, swap dealers, CTAs, CPOs, and derivatives customers
  • Advisers using tokenized Treasury, money-market, or other collateral arrangements
What remains unresolved
  • Acceptable control models, haircuts, settlement finality, and cross-regime treatment
  • Institution-specific approval and implementation requirements
Advisor workflow implications
  • Add tokenization-specific controls to collateral and counterparty diligence
  • Verify underlying eligibility, legal rights, custody, segregation, transfer, valuation, liquidity, technology, and default-management mechanics
Previous interpretation

The CFTC framework addressed eligible collateral but lacked this consolidated staff guidance for tokenized representations.

Version 1 · published
Official signal · nonbinding U.S. Commodity Futures Trading Commission

CFTC announces listed spot crypto trading on federally regulated exchanges

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

CFTC leadership announced the launch of listed spot crypto products on U.S. federally regulated designated contract markets under the agency’s crypto initiative.

Who it affects
  • Advisers, clients, DCMs, FCMs, custodians, and spot crypto trading providers
What remains unresolved
  • The precise regulatory framework, product set, intermediary protections, and future Commission action
Advisor workflow implications
  • Verify each venue and product’s legal structure, custody, execution, and customer-protection terms rather than treating the announcement as a blanket approval.
Version 1 · published
November 2025 · 3 entries
Guidance Office of the Comptroller of the Currency

OCC permits banks to hold limited crypto as principal for network fees and testing

Primary document
What changed

The OCC confirmed that national banks may hold limited amounts of crypto assets on balance sheet to pay blockchain network fees for permissible activities and to test permissible platforms. The authority is incidental and bounded by reasonably foreseeable operational need, safe-and-sound practices, and applicable law.

Who it affects
  • National banks operating crypto custody or settlement services
  • Advisers evaluating bank onchain execution and custody capabilities
What remains unresolved
  • Bank-specific limits, accounting, controls, and supported networks
  • How banks will address volatility, forks, sanctions, and operational incidents
Advisor workflow implications
  • Confirm how a bank sources, safeguards, values, and accounts for fee assets
  • Do not characterize limited incidental holdings as broad bank authority to speculate in crypto assets
Previous interpretation

Bank authority to hold crypto as principal for gas fees and platform testing had not been expressly confirmed in this form.

Version 1 · published
Official signal · nonbinding Chair of the U.S. Securities and Exchange Commission

SEC Chairman previews a Howey-based token taxonomy under Project Crypto

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Chairman Atkins outlined his intended token taxonomy and a view that a non-security crypto asset may be sold subject to an investment contract that can later terminate. The remarks forecast Commission work but are the Chairman’s views and did not themselves alter federal securities law.

Who it affects
  • Advisers classifying crypto assets and transactions
  • Issuers, funds, trading venues, custodians, broker-dealers, and clients
What remains unresolved
  • Commission adoption, precise definitions, transition rules, and reliance standards
  • Interaction with legislation and judicial precedent
Advisor workflow implications
  • Use the taxonomy as a watch item until an operative Commission action issues
  • Maintain transaction-specific analysis rather than assigning permanent status based only on token labels
Previous interpretation

Project Crypto had announced classification work but the Chair had not publicly detailed this taxonomy and termination theory.

Version 1 · published
Official signal · nonbinding Board of Governors of the Federal Reserve System

Federal Reserve Governor Miran addresses stablecoins and monetary policy

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Governor Stephen Miran discussed how stablecoin growth could affect dollar demand, Treasury markets, banking, and monetary policy transmission.

Who it affects
  • Stablecoin issuers and users, banks, asset managers, investment advisers, and clients
What remains unresolved
  • The scale and direction of stablecoin adoption and resulting market effects
Advisor workflow implications
  • Monitor reserve-asset concentration, liquidity, and interest-rate transmission as contextual—not binding—risk signals.
Version 1 · published
October 2025 · 3 entries
Court decision United States Court of Appeals for the Tenth Circuit

Tenth Circuit affirms Federal Reserve discretion to deny Custodia a master account

Primary document
What changed

A divided Tenth Circuit affirmed judgment against crypto-focused Custodia Bank, holding that federal law did not impose a nondiscretionary duty requiring the Kansas City Fed to provide a master account and that the Board’s denial did not supply the relief Custodia sought. The decision leaves regional Reserve Banks substantial gatekeeping discretion over direct payment-system access.

Who it affects
  • State-chartered banks seeking Federal Reserve master accounts
  • Crypto custodians and banks dependent on payment-system access
  • Advisers diligencing banking and settlement partners
What remains unresolved
  • Whether Supreme Court review or legislation will alter master-account access standards
  • How Reserve Banks will apply risk-based discretion to other novel-charter applicants
Advisor workflow implications
  • Treat direct Federal Reserve access as a discretionary counterparty dependency, not an entitlement; diligence fallback correspondent banking, liquidity, settlement and concentration risks for digital-asset providers.
Version 1 · published · effective 2025-10-31
Official signal · nonbinding Board of Governors of the Federal Reserve System

Federal Reserve Governor Barr discusses stablecoin risks and implementation

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Governor Michael Barr identified policy and implementation issues for payment stablecoins, including runs, reserves, redemption, interoperability, and effects on banking and payments.

Who it affects
  • Stablecoin issuers, banks, payment firms, investment advisers, and clients
What remains unresolved
  • How agencies will implement the statutory stablecoin framework
Advisor workflow implications
  • Track the speech as an implementation signal; do not treat individual views as operative requirements.
Version 1 · published
Final rule National Futures Association

NFA broadens Compliance Rule 2-51 and repeals its earlier virtual-currency interpretive notice

Primary documents
What changed

NFA amended Rule 2-51 and repealed the older virtual-currency interpretive notice, updating the operative member standard for covered digital-asset commodity activities. The rule applies to NFA members and associates within its defined product nexus and includes antifraud, communications, record, supervision, and commercial-honor requirements.

Who it affects
  • NFA members and associated persons involved with covered digital-asset commodities
  • CTAs, CPOs, FCMs, introducing brokers, and advisers using those firms
What remains unresolved
  • Application to evolving products and member business models
  • How NFA examinations and enforcement will interpret the amended scope
Advisor workflow implications
  • Update NFA-member and futures-counterparty diligence for Rule 2-51 controls
  • Review digital-asset communications, supervision, books and records, and role allocation across RIA and commodity-interest activities
Previous interpretation

Members relied on the narrower prior Rule 2-51 text together with Interpretive Notice 9073.

Version 1 · published · effective 2025-12-03
September 2025 · 5 entries
Guidance SEC Division of Investment Management

SEC investment-management staff permits conditional use of state trust companies for crypto custody

Primary document
What changed

Investment Management staff provided conditional no-action relief allowing registered advisers and regulated funds to treat certain state-chartered trust companies as permissible bank custodians for crypto assets and related cash. The relief depends on due inquiry, written agreements, segregation, financial and control reporting, risk disclosure, and a best-interest determination.

Who it affects
  • SEC-registered investment advisers with custody of client crypto assets
  • Registered funds and business development companies
  • State trust companies and advisory clients
What remains unresolved
  • Commission rulemaking on adviser and fund custody
  • How advisers will evidence state-law status, control quality, solvency, segregation, and continued eligibility
Advisor workflow implications
  • Build a documented annual due-inquiry and best-interest process before relying on the relief
  • Obtain and review governing law, audited financials or control reports, segregation, rehypothecation, insurance, key-control, incident, insolvency, and termination terms
Previous interpretation

Advisers and funds faced substantial uncertainty over whether a state trust company qualified as a bank for the covered crypto custody provisions.

Version 1 · published
Guidance New York State Department of Financial Services

NYDFS updates virtual-currency custody and insolvency guidance

Primary document
What changed

NYDFS superseded its 2023 custody guidance with more specific requirements for acceptable subcustodians, subcustody agreements, permissible use of customer assets, disclosure, and preservation of customers’ beneficial interests in insolvency.

Who it affects
  • New York virtual-currency custodians, subcustodians, investment advisers, funds, and clients
What remains unresolved
  • How DFS will apply the updated expectations to individual custody chains and insolvency structures
Advisor workflow implications
  • Reassess segregation, title, rehypothecation, subcustodian eligibility, contracts, disclosures, books and records, and insolvency opinions.
Version 1 · published
Enforcement U.S. Department of the Treasury, Office of Foreign Assets Control

OFAC settles sanctions violations with ShapeShift

Primary document
What changed

OFAC announced a $750,000 settlement with ShapeShift for apparent sanctions violations involving its digital-asset exchange services.

Who it affects
  • Digital-asset exchanges, investment advisers diligencing trading venues, and clients
What remains unresolved
  • How firms will translate the settlement factors to decentralized or non-custodial interfaces
Advisor workflow implications
  • Test sanctions screening, IP and geolocation controls, escalation, historical lookbacks, and platform-counterparty representations.
Version 1 · published
Guidance New York State Department of Financial Services

NYDFS extends blockchain-analytics guidance to banking organizations

Primary document
What changed

NYDFS told regulated banking organizations engaged in or exposed to virtual-currency activity to consider blockchain analytics for wallet screening, funds verification, transaction monitoring, third-party diligence, and product-risk assessment.

Who it affects
  • New York-regulated banking organizations, virtual-asset counterparties, investment advisers, and clients
What remains unresolved
  • The controls and analytics coverage DFS will expect for particular risk profiles
Advisor workflow implications
  • Incorporate analytics capability, coverage, data quality, escalation, and vendor governance into bank and digital-asset counterparty diligence.
Version 1 · published
Official signal · nonbinding SEC Division of Trading and Markets · CFTC Division of Market Oversight · CFTC Division of Clearing and Risk

SEC and CFTC staff state that registered exchanges are not barred from certain spot crypto trading

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

SEC and CFTC staff jointly stated that registered exchanges are not categorically prohibited from facilitating trading of certain spot crypto commodity products. The statement invites engagement and signals an access path, but it does not approve a particular exchange, product, or intermediary model.

Who it affects
  • Registered securities and derivatives exchanges
  • Broker-dealers, FCMs, advisers, custodians, and clients seeking regulated-venue access
What remains unresolved
  • Agency approvals, product definitions, clearing, custody, capital, and customer-protection conditions
  • Jurisdiction for specific assets and transaction structures
Advisor workflow implications
  • Do not assume a venue or product is approved based solely on the joint statement
  • Evaluate actual registration, product approval, custody, clearing, liquidity, conflicts, and client eligibility
Previous interpretation

Federal registered-exchange pathways for spot crypto commodities were less explicit and agency coordination was uncertain.

Version 1 · published
August 2025 · 8 entries
Guidance Board of Governors of the Federal Reserve System

Federal Reserve sunsets its novel-activities supervision program

Primary document
What changed

The Federal Reserve ended its separate novel-activities supervision program and returned monitoring of bank crypto, distributed-ledger, and technology-driven activities to its standard supervisory process.

Who it affects
  • Federal Reserve-supervised banks, crypto and fintech service providers, investment advisers, and clients using bank-provided digital-asset services
What remains unresolved
  • How examination intensity will differ under ordinary supervision
Advisor workflow implications
  • Treat the program change as a supervisory-process shift, not a withdrawal of safety-and-soundness obligations.
Version 1 · published
Enforcement U.S. Department of the Treasury, Office of Foreign Assets Control

OFAC designates Garantex successor Grinex and associated crypto network

Primary document
What changed

OFAC redesignated Garantex under cyber authorities and designated successor exchange Grinex, executives, and supporting companies for sanctions evasion, ransomware, and other malicious cyber activity.

Who it affects
  • Digital-asset exchanges, custodians, investment advisers, compliance vendors, and clients
What remains unresolved
  • Further associated addresses, entities, licenses, and enforcement actions
Advisor workflow implications
  • Refresh exchange and address screening, successor-entity detection, beneficial-ownership review, ransomware exposure, and blocked-property controls.
Version 1 · published
Official signal · nonbinding President of the United States · U.S. Department of Labor · U.S. Securities and Exchange Commission

Executive Order directs review of 401(k) access to digital-asset and other alternative investments

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The President directed Labor to revisit its approach to alternative assets in participant-directed retirement plans and expressly included certain actively managed digital-asset vehicles in the review. The order does not amend ERISA’s prudence and loyalty duties or make any product suitable for a plan.

Who it affects
  • ERISA plan fiduciaries and investment committees
  • Retirement advisers, asset managers, recordkeepers, and participants
What remains unresolved
  • Labor and SEC implementing guidance or rulemaking
  • Appropriate vehicle, valuation, liquidity, fee, custody, and participant-protection standards
Advisor workflow implications
  • Treat the order as a forthcoming-guidance signal
  • Retain documented prudent-process, diversification, fee, liquidity, custody, and participant-communication analysis
Previous interpretation

Labor had rescinded its crypto-specific extreme-care guidance but had not yet been directed to develop this broader alternative-assets access framework.

Version 1 · published
Enacted law President of the United States

Executive order directs banking regulators to eliminate politicized or unlawful debanking practices

What changed

Executive Order 14331 directs federal banking regulators to remove reputation-risk concepts that could support politicized or unlawful debanking from guidance and examination materials, review past conduct, and consider remedial or enforcement action. It requires individualized, objective, risk-based banking decisions.

Who it affects
  • Banks and other financial-services providers, their customers, and advisers diligencing access to banking services
What remains unresolved
  • How each regulator will revise guidance, regulations, examinations, and enforcement practices
Advisor workflow implications
  • Reassess counterparty and service-provider diligence for objective risk criteria, including where lawful digital-asset activity previously affected access.
Version 1 · published
Enforcement New York State Department of Financial Services

NYDFS settles Paxos AML and Binance-diligence failures

Primary document
What changed

NYDFS required Paxos to pay a $26.5 million penalty and invest $22 million in remediation after finding deficient AML controls and insufficient due diligence and escalation concerning Binance and BUSD.

Who it affects
  • Stablecoin issuers, trust companies, virtual-currency businesses, investment advisers, and clients
What remains unresolved
  • Completion of the remediation plan and continuing supervisory findings
Advisor workflow implications
  • Strengthen issuer and platform diligence for affiliates, distributors, sanctions exposure, geofencing, transaction monitoring, escalation, and board reporting.
Version 1 · published
Official signal · nonbinding SEC Division of Corporation Finance

SEC staff states that described liquid-staking activities are not securities transactions

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Corporation Finance staff extended its category-specific analysis to certain liquid-staking arrangements and described receipt tokens, stating that the covered activities do not involve securities transactions. The view is nonbinding and does not cover arrangements with materially different managerial, lending, leverage, guarantee, or marketing features.

Who it affects
  • Advisers evaluating liquid-staking tokens or strategies
  • Protocols, staking providers, custodians, platforms, and token issuers
What remains unresolved
  • Treatment of restaking, lending overlays, leveraged vaults, depegs, or discretionary strategies
  • Custody, tax, liquidity, smart-contract, slashing, and fiduciary issues
Advisor workflow implications
  • Map each receipt token and service against the statement’s facts and retained rights
  • Diligence redemption, liquidity, validator, smart-contract, custody, slashing, fee, and conflict risks independently of securities status
Previous interpretation

The May protocol-staking statement did not expressly resolve the distinct receipt-token and liquid-staking fact pattern.

Version 1 · published
Official signal · nonbinding U.S. Commodity Futures Trading Commission

CFTC Commissioner outlines AI, third-party, cyber, and digital-asset governance expectations

This item records a policy signal. It does not by itself change applicable law.

Primary documents
What changed

Across a 2025 series culminating in an August roundtable recap, Commissioner Kristin Johnson identified governance expectations for financial-sector AI and digital-asset adoption, including explainability, bias controls, human oversight, post-deployment monitoring, scenario testing, cyber resilience, third-party oversight, incident response and firm accountability. These are an individual commissioner’s nonbinding policy and supervisory signals, not Commission rules.

Who it affects
  • CFTC registrants using AI in trading, risk, compliance or surveillance
  • Investment advisers and funds using AI or digital-asset infrastructure
  • Firms relying on critical technology and data vendors
What remains unresolved
  • Whether the Commission will convert these recommendations into rules, staff guidance or examination expectations
  • How any future framework will allocate accountability among firms, models and third-party providers
Advisor workflow implications
  • Treat the remarks as a watch signal; inventory covered AI and digital-asset uses, document human oversight and testing, and strengthen cyber, incident-response and critical-vendor controls without representing the recommendations as binding CFTC requirements.
Version 1 · published
Guidance Financial Crimes Enforcement Network

FinCEN issues virtual-currency kiosk scam and illicit-finance notice

Primary document
What changed

FinCEN urged financial institutions to identify and report suspicious CVC-kiosk activity and supplied typologies and red flags for scams, cybercrime, and drug-trafficking activity.

Who it affects
  • Money services businesses, banks, broker-dealers, digital-asset firms, investment advisers, and clients
What remains unresolved
  • Institution-specific exposure and how filing patterns will evolve
Advisor workflow implications
  • Add kiosk-related red flags to fraud escalation, transaction monitoring, vulnerable-client protection, and SAR decision procedures.
Version 1 · published
July 2025 · 10 entries
Official signal · nonbinding Chair of the U.S. Securities and Exchange Commission

SEC Chairman announces Project Crypto priorities for onchain securities markets

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Chairman Atkins publicly directed SEC staff toward a broad Project Crypto agenda covering asset classification, issuance exemptions, tokenized securities, custody, self-custodial software, integrated intermediaries, and onchain markets. The speech states the Chairman’s direction and views; it is not a Commission rule or exemption.

Who it affects
  • SEC registrants and prospective registrants
  • Advisers, funds, broker-dealers, custodians, trading venues, software providers, and issuers
What remains unresolved
  • Which initiatives will receive Commission votes or staff relief
  • Conditions, investor protections, and timing for proposed exemptions or rule changes
Advisor workflow implications
  • Track Project Crypto outputs matter by matter and preserve existing compliance controls meanwhile
  • Do not present the Chairman’s agenda as current legal authorization for self-custody, DeFi, or integrated services
Previous interpretation

The new Chair had not yet set out a comprehensive public crypto work program at this level of specificity.

Version 1 · published
Official signal · nonbinding President’s Working Group on Digital Asset Markets · U.S. Department of the Treasury

President’s Working Group issues a government-wide digital-asset regulatory roadmap

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The President’s Working Group delivered a coordinated roadmap recommending legislation and specific agency actions on digital-asset classification, trading, custody, banking, stablecoins, DeFi, tax, and illicit finance. The recommendations are not themselves binding law or agency relief.

Who it affects
  • Congress and federal financial regulators
  • Advisers, funds, custodians, banks, broker-dealers, platforms, issuers, and clients
What remains unresolved
  • Which recommendations will be adopted and on what timetable
  • How agencies will reconcile the roadmap with existing statutes and pending litigation
Advisor workflow implications
  • Use the report as a policy roadmap and source index, not as current permission
  • Track each implementing action under its own stable matter and legal posture
Previous interpretation

Executive Order 14178 required recommendations but the working group had not yet delivered its consolidated roadmap.

Version 1 · published
Agency order U.S. Securities and Exchange Commission

SEC approves in-kind creations and redemptions for bitcoin and ether ETPs

Primary documents
What changed

The Commission approved exchange rule changes allowing authorized participants to create and redeem covered spot bitcoin and ether ETP shares in kind, replacing the cash-only structure in the affected products. The orders govern listed-product mechanics and do not authorize advisers or retail clients to transact directly with the funds in kind.

Who it affects
  • Crypto ETP sponsors and authorized participants
  • Advisers and clients holding covered crypto ETP shares
  • Exchanges, market makers, custodians, and broker-dealers
What remains unresolved
  • Product-by-product implementation, spreads, costs, and tax effects
  • Treatment of later multi-asset or staking ETP structures
Advisor workflow implications
  • Refresh ETP trading-cost, tax, liquidity, and tracking-error diligence after implementation
  • Distinguish authorized-participant in-kind mechanics from retail shareholder redemption rights
Previous interpretation

The covered spot bitcoin and ether ETP approvals used cash-only creation and redemption mechanics.

Version 1 · published
Enforcement Financial Industry Regulatory Authority

FINRA fines TradeStation over crypto-affiliate communications

Primary document
What changed

FINRA censured TradeStation Securities and imposed an $85,000 fine after finding that website and video communications could confuse investors about whether the broker-dealer or an unregistered affiliate offered crypto services, which regulations and protections applied, and the risks of the assets discussed.

Who it affects
  • Broker-dealers and advisers with affiliated crypto platforms
  • Marketing and compliance teams responsible for websites and video content
  • Retail customers navigating shared brands and service journeys
What remains unresolved
  • Whether the parallel Firstrade and TradeStation cases signal continued targeted examination of crypto-affiliate communications
  • How FINRA will assess newer integrated account interfaces and embedded crypto services
Advisor workflow implications
  • Test websites, videos and embedded interfaces for provider identity and protection confusion; place balanced risk disclosure near benefit claims and keep affiliate boundaries prominent throughout the client journey.
Version 1 · published · effective 2025-07-25
Proposal · not in effect United States Congress

House passes a digital-asset illicit-finance working-group bill

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The House passed the Financial Technology Protection Act of 2025. The bill would establish an interagency working group on terrorist and illicit use of digital assets and emerging technology and require Treasury sanctions-evasion and mitigation reporting. It remains pending in the Senate.

Who it affects
  • Digital-asset firms, financial institutions, AML professionals, advisers, and clients
What remains unresolved
  • Whether the Senate will pass the bill and what recommendations a future working group would make
Advisor workflow implications
  • Monitor for later AML or sanctions proposals; the House action creates no current compliance duty.
Version 1 · published
Enacted law United States Congress

GENIUS Act creates a federal framework for payment stablecoin issuers

Primary document
What changed

S. 1582 became Public Law 119-27, establishing the first federal statutory framework specifically for permitted payment stablecoin issuers, including reserve, disclosure, redemption, supervision, and issuer-eligibility provisions.

Who it affects
  • Payment stablecoin issuers and prospective issuers
  • Advisers conducting diligence on stablecoin reserves, redemption, and issuer status
  • Custodians and platforms supporting payment stablecoins
What remains unresolved
  • Implementing regulations and the timing of operative requirements
  • How particular stablecoins and issuer structures will fit the permitted-issuer framework
  • Interaction with state regimes and other federal securities, commodities, banking, and sanctions requirements
Advisor workflow implications
  • Add permitted-issuer status and transition timing to stablecoin diligence
  • Map statutory reserve, disclosure, redemption, and insolvency provisions to each covered stablecoin
  • Do not treat enactment as automatic approval of any stablecoin, venue, or client use
Previous interpretation

Before enactment, U.S. payment stablecoin oversight depended on a patchwork of state money-transmission, banking, securities, commodities, sanctions, and consumer-protection regimes without a dedicated federal issuer statute.

Version 1 · published
Proposal · not in effect United States Congress

House passes a bill restricting Federal Reserve central-bank digital currency activity

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The House passed the Anti-CBDC Surveillance State Act. The bill would restrict Federal Reserve issuance, direct services, monetary-policy use, and specified testing or study of a central-bank digital currency, subject to its exceptions. It has not become law.

Who it affects
  • Federal Reserve institutions, payments firms, digital-asset businesses, advisers, and clients monitoring a U.S. CBDC
What remains unresolved
  • Whether the Senate will pass the bill and the final scope of exceptions
Advisor workflow implications
  • Treat the measure as pending legislation, not a present prohibition.
Version 1 · published
Guidance Board of Governors of the Federal Reserve System · Federal Deposit Insurance Corporation · Office of the Comptroller of the Currency

Banking agencies issue joint crypto-asset safekeeping risk-management statement

Primary document
What changed

The federal banking agencies jointly described risk-management considerations for banks that safeguard crypto assets, including key management, due diligence, governance, legal and compliance risks, audit, resilience, and third-party arrangements.

Who it affects
  • Banks providing crypto-asset safekeeping, investment advisers relying on bank custodians, funds, and advisory clients
What remains unresolved
  • How individual agencies and examiners will apply the principles to particular custody structures
Advisor workflow implications
  • Refresh custodian diligence and contractual controls for private keys, subcustody, segregation, incident response, auditability, and asset recovery.
Version 1 · published
Enforcement California Department of Financial Protection and Innovation

California penalizes Coinme for crypto-kiosk DFAL violations

Primary document
What changed

DFPI fined Coinme $300,000 and obtained $51,700 in restitution over crypto-kiosk violations involving transaction limits, pricing-spread disclosures, receipts, and related DFAL requirements.

Who it affects
  • Crypto-kiosk operators, digital-asset businesses, investment advisers, vulnerable clients, and California consumers
What remains unresolved
  • Continuing remediation and any later enforcement involving the operator
Advisor workflow implications
  • Use the order as a benchmark for kiosk limits, receipts, pricing-spread disclosures, exchange references, fraud controls, and restitution.
Version 1 · published
Guidance SEC Division of Corporation Finance

SEC staff identifies disclosure considerations for crypto-asset exchange-traded products

Primary document
What changed

Corporation Finance staff consolidated disclosure observations for crypto-asset ETP filings, including index or reference asset, custody, creation and redemption, fees, conflicts, valuation, network, trading, and service-provider risks. The statement does not approve any product or create new obligations.

Who it affects
  • Advisers selecting and monitoring crypto ETPs
  • Crypto ETP sponsors, authorized participants, custodians, and broker-dealers
What remains unresolved
  • How the staff will apply the considerations to staking, multi-asset, or novel ETPs
  • Product-specific materiality and registration-statement comments
Advisor workflow implications
  • Add the statement’s topics to ETP comparison and ongoing-monitoring checklists
  • Verify filed custody, index, liquidity, creation-redemption, fee, and conflict terms against marketing claims
Previous interpretation

The disclosure record was dispersed across individual filings and staff comments without this consolidated current statement.

Version 1 · published
June 2025 · 5 entries
Proposal · not in effect United States Congress

House passes a Commerce Department blockchain leadership bill

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The House passed the Deploying American Blockchains Act of 2025. The bill would direct the Commerce Department to advise the President on blockchain, distributed-ledger, token, and tokenization policy, establish advisory committees, develop best practices, and report annually. It remains pending in the Senate.

Who it affects
  • Blockchain and tokenization developers, financial institutions, advisers, and market participants
What remains unresolved
  • Whether the Senate will pass the bill and whether it will become law
Advisor workflow implications
  • Monitor as a policy-development measure; it creates no current private-sector obligation.
Version 1 · published
Final rule Securities and Exchange Commission

SEC withdraws a broad slate of 2022–2023 proposals affecting advisers and markets

Primary document
What changed

The SEC formally withdrew multiple proposals and stated it did not intend to issue final rules from them, including safeguarding advisory client assets, adviser cybersecurity, predictive-data conflicts, outsourcing, ESG disclosure, and Regulation Best Execution initiatives.

Who it affects
  • Registered investment advisers, funds, broker-dealers, exchanges, and service providers
What remains unresolved
  • Whether the Commission will issue replacement proposals in any withdrawn area
Advisor workflow implications
  • Remove the withdrawn texts from active-rule implementation calendars while retaining issue monitoring.
Version 1 · published
Guidance Internal Revenue Service · U.S. Department of the Treasury

IRS extends transition relief for digital-asset broker backup withholding and reporting

Primary document
What changed

Treasury and the IRS extended specified transition relief for brokers implementing Form 1099-DA reporting and backup withholding, including broad backup-withholding relief for 2026 transactions and conditional 2027 relief. The notice does not eliminate customers’ income-reporting or basis obligations.

Who it affects
  • Digital-asset brokers and custodial platforms
  • Advisers coordinating client tax records and transfer workflows
  • Clients disposing of digital assets
What remains unresolved
  • Broker implementation quality and handling of transferred or noncovered assets
  • Future guidance for transactions and participants covered by temporary relief
Advisor workflow implications
  • Prepare for mismatches between broker-reported proceeds, client basis records, and wallet histories
  • Explain that withholding relief does not excuse client gain, loss, income, or recordkeeping obligations
Previous interpretation

Notice 2024-56 supplied the earlier, narrower transition framework before this extension and modification.

Version 1 · published
Proposal · not in effect Securities and Exchange Commission

SEC seeks comment on foreign-private-issuer eligibility

This item records a proposal. It does not by itself change applicable law.

Primary document
What changed

The SEC issued a concept release examining whether the foreign-private-issuer definition and related accommodations remain appropriate.

Who it affects
  • Foreign issuers, funds, broker-dealers, investment advisers, and investors
What remains unresolved
  • Whether the SEC will propose eligibility or disclosure changes
Advisor workflow implications
  • Review exposure to foreign issuers and monitor possible changes to reporting comparability and product diligence.
Version 1 · published
Official signal · nonbinding Chair of the U.S. Securities and Exchange Commission

SEC Chair directs staff to explore an onchain innovation exemption

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Chair Paul Atkins said he directed staff to consider guidance, rulemaking, and a conditional innovation exemption for onchain markets and self-custodial systems.

Who it affects
  • Investment advisers, broker-dealers, funds, DeFi developers, and clients
What remains unresolved
  • Whether the Commission will propose or adopt an exemption and its eligibility conditions
Advisor workflow implications
  • Treat the remarks as a policy signal only; map potential opportunities and compliance conditions without assuming relief exists.
Version 1 · published
May 2025 · 9 entries
Enforcement U.S. Securities and Exchange Commission

SEC dismisses seven crypto enforcement cases as policy shifts to rulemaking

Primary documents
What changed

Between February and May 2025, the SEC dismissed with prejudice seven prior-administration crypto enforcement actions—Coinbase, Cumberland DRW, Consensys, Kraken/Payward, Dragonchain, Balina, and Binance—while stating that the dismissals supported a shift from enforcement-led policymaking toward the Crypto Task Force and did not decide the merits or establish a rule for other cases.

Who it affects
  • Crypto trading platforms
  • dealers
  • wallet and staking providers
  • token issuers
  • investment advisers
  • custodians
  • clients
What remains unresolved
  • The substantive treatment of particular tokens, transactions, staking services, and intermediary activities under later SEC rules, interpretations, and cases
Advisor workflow implications
  • Update enforcement-risk narratives and case trackers, but do not read the discretionary dismissals as holdings that the underlying activities fall outside the securities laws.
Version 1 · published
Official signal · nonbinding SEC Division of Corporation Finance

SEC staff states that described protocol staking activities are not securities transactions

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Corporation Finance staff stated that the protocol staking activities and ancillary services described in the statement do not involve securities transactions. The view is fact-specific, nonbinding, and does not extend automatically to liquid staking, restaking, yield guarantees, lending, or managed investment arrangements.

Who it affects
  • Advisers evaluating client staking programs
  • Custodians, validators, staking providers, platforms, and proof-of-stake networks
What remains unresolved
  • Treatment of arrangements with guarantees, discretion, leverage, pooling, or materially different economics
  • Custody-rule, tax, slashing, liquidity, disclosure, and fiduciary consequences
Advisor workflow implications
  • Map each staking arrangement against the staff’s stated facts
  • Document validator selection, slashing, lockup, fee, custody, smart-contract, liquidity, and conflict controls
Previous interpretation

SEC staff had not provided this current, category-specific view for the described protocol staking arrangements.

Version 1 · published
Enforcement National Futures Association

NFA sanctions OANDA over crypto-broker promotions and other supervisory failures

Primary document
What changed

NFA accepted OANDA’s settlement and found violations including deficient promotional materials for a third-party cryptocurrency broker and inadequate supervision. The underlying complaint says promotions misleadingly suggested customers traded crypto through or in a regulated environment provided by OANDA even though spot crypto accounts were opened directly with a non-Member broker. The decision ordered a $600,000 fine and good-faith restitution up to $428,592.26 for a separate pricing-display issue.

Who it affects
  • NFA member firms promoting affiliated or third-party crypto services
  • Retail forex dealers and futures commission merchants
  • Broker-dealers and advisers conducting diligence on crypto referral or co-marketing arrangements
What remains unresolved
  • How NFA will apply promotional-material and supervisory principles after its later Rule 2-51 amendments
  • The extent to which similar third-party crypto arrangements will draw examination attention
Advisor workflow implications
  • Clearly distinguish the regulated firm from a third-party crypto provider; disclose who holds the account, which regulator and protections apply, material risks, and conflicts; review linked webpages, social posts, referrals, and supervisory evidence.
Version 1 · published · effective 2025-05-29
Guidance U.S. Department of Labor, Employee Benefits Security Administration

Labor Department rescinds its special 'extreme care' cryptocurrency guidance

Primary document
What changed

EBSA rescinded its 2022 cryptocurrency compliance release in full and returned to a neutral, context-specific application of ordinary ERISA fiduciary principles rather than a special 'extreme care' formulation.

Who it affects
  • ERISA plan fiduciaries and committees
  • Advisers and consultants serving retirement plans
  • Service providers offering digital-asset investment exposure to plans
What remains unresolved
  • Whether a particular digital-asset option is prudent for a specific plan
  • Operational, valuation, custody, liquidity, cybersecurity, and participant-communication requirements
  • How future enforcement and guidance will apply ordinary fiduciary principles
Advisor workflow implications
  • Update policies that quote the rescinded 2022 release as current DOL guidance
  • Retain a documented, context-specific ERISA prudence process
  • Do not present rescission as DOL endorsement of cryptocurrency in retirement plans
Previous interpretation

The 2022 release directed plan fiduciaries to exercise 'extreme care' before adding cryptocurrency to a 401(k) investment menu.

Version 1 · published · effective 2025-05-28
Enforcement Financial Industry Regulatory Authority

FINRA fines Firstrade over crypto-affiliate communications

Primary document
What changed

FINRA censured Firstrade and imposed an $85,000 fine after finding that crypto communications did not prominently identify the affiliate that offered the assets, distinguish it from the registered broker-dealer or SIPC membership, or fairly balance benefits against speculative and loss risks.

Who it affects
  • Broker-dealers with crypto affiliates
  • Dual registrants and advisers sharing websites, brands or referral journeys with crypto providers
  • Retail customers evaluating whether brokerage protections apply
What remains unresolved
  • Whether FINRA will impose additional requirements on affiliate handoffs beyond Rule 2210’s existing content standards
  • How firms should present evolving federal and state protections without implying coverage that does not exist
Advisor workflow implications
  • Name the actual provider at every material handoff, distinguish broker-dealer and SIPC protections from affiliate crypto services, describe material risks alongside benefits, and review the entire linked customer journey.
Version 1 · published · effective 2025-05-28
Agency order Consumer Financial Protection Bureau

CFPB withdraws proposed EFTA treatment for emerging payment mechanisms

Primary documents
What changed

CFPB withdrew its proposal to interpret Regulation E and the Electronic Fund Transfer Act for accounts using emerging payment mechanisms. The proposed expansion therefore did not become operative.

Who it affects
  • Wallet and payment providers, digital-asset firms, banks, investment advisers, and consumers
What remains unresolved
  • Whether CFPB will pursue a narrower interpretation or new rulemaking
Advisor workflow implications
  • Do not implement the withdrawn proposal as law; continue mapping wallet and payment functions to currently operative EFTA, state, contract, and fraud obligations.
Version 1 · published
Guidance U.S. Securities and Exchange Commission staff

SEC staff withdraws the joint broker-dealer digital-asset custody statement

Primary document
What changed

SEC staff withdrew the 2019 joint statement on broker-dealer custody of digital asset securities.

Who it affects
  • Broker-dealers, investment advisers, custodians, funds, and clients
What remains unresolved
  • What replacement Commission or staff standards will govern particular custody models
Advisor workflow implications
  • Remove reliance on the withdrawn statement while continuing to apply operative customer-protection and custody requirements.
Version 1 · published
Guidance Office of the Comptroller of the Currency

OCC confirms banks may execute and outsource crypto transactions tied to custody services

Primary document
What changed

The OCC confirmed that national banks may provide customer-directed crypto-asset execution as an accommodation to custody services and may use sub-custodians and other third parties for permissible activities. Banks remain responsible for risk management, legal compliance, and safe-and-sound execution.

Who it affects
  • National banks providing crypto custody
  • Advisers selecting custody and execution arrangements for clients
What remains unresolved
  • Which bank service models and asset lists will be offered
  • Allocation of execution, sub-custody, insolvency, and technology risks by contract
Advisor workflow implications
  • Diligence custody and execution as separate functions even when bundled by a bank
  • Review routing, pricing, conflicts, sub-custodian, asset-control, and incident-response terms
Previous interpretation

Earlier OCC letters confirmed custody authority but left more uncertainty around ancillary execution and outsourcing models.

Version 1 · published
Guidance U.S. Securities and Exchange Commission, Division of Corporation Finance

SEC staff withdraws its 2022 crypto-market disclosure sample letter

Primary document
What changed

Corporation Finance staff withdrew its December 2022 sample letter focused on disclosure of crypto-market disruption, bankruptcy, counterparty, liquidity, custody, collateral, and regulatory risks. The withdrawal removes that staff comment template but does not remove issuers’ underlying federal disclosure obligations.

Who it affects
  • Public companies with crypto exposure
  • funds and issuers
  • investment advisers conducting issuer diligence
  • auditors
  • investors
What remains unresolved
  • How staff will frame future comments on material crypto exposure under general disclosure requirements
Advisor workflow implications
  • Remove the withdrawn letter as current staff guidance while continuing materiality-based diligence on crypto exposure, custody, counterparties, liquidity, conflicts, collateral, and legal proceedings.
Version 1 · published
April 2025 · 8 entries
Guidance Board of Governors of the Federal Reserve System

Federal Reserve withdraws crypto and dollar-token notification and nonobjection guidance

Primary document
What changed

The Federal Reserve withdrew prior guidance directing supervised banks to notify the Board before crypto activities and establishing a written nonobjection process for dollar-token activities. Crypto and dollar-token activities remain subject to ordinary legal and safety-and-soundness supervision.

Who it affects
  • Federal Reserve-supervised banking organizations
  • Advisers evaluating bank stablecoin, custody, and settlement counterparties
What remains unresolved
  • Whether replacement joint-agency guidance will be issued
  • How reserve-bank and Board exam practices will converge
Advisor workflow implications
  • Refresh counterparty questionnaires that assumed a special Federal Reserve nonobjection
  • Continue evaluating actual control, liquidity, redemption, operational, and legal risks
Previous interpretation

Covered banks were expected to provide advance notice and, for dollar-token activities, receive written supervisory nonobjection.

Version 1 · published
Official signal · nonbinding Commodity Futures Trading Commission staff

CFTC staff seeks comment on 24/7 trading and perpetual derivatives

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

CFTC staff opened public-comment initiatives on round-the-clock trading and perpetual contracts in derivatives markets.

Who it affects
  • DCMs, DCOs, FCMs, commodity pools, CTAs, investment advisers, and clients
What remains unresolved
  • Whether the Commission will propose rules or guidance and what operational safeguards will apply
Advisor workflow implications
  • Assess resilience, staffing, margin, settlement, liquidity, and disclosure issues while awaiting binding action.
Version 1 · published
Enacted law United States Congress · U.S. Department of the Treasury · Internal Revenue Service

Congress nullifies the DeFi broker reporting rule under the Congressional Review Act

Primary document
What changed

Public Law 119-5 disapproved the Treasury and IRS final rule that would have required specified non-custodial DeFi participants to report digital-asset sales as brokers. The agencies subsequently removed the rule from the CFR and treated it as having no legal force or effect.

Who it affects
  • Operators of DeFi trading front ends and other non-custodial interfaces addressed by the revoked rule
  • Advisers assessing transaction-record and tax-reporting dependencies
  • Digital-asset users whose activity would have been reported under the rule
What remains unresolved
  • Other existing tax reporting and taxpayer recordkeeping obligations
  • Future legislation or materially different rulemaking
  • Classification of custodial brokers and other intermediaries under rules not revoked by Public Law 119-5
Advisor workflow implications
  • Remove the revoked DeFi broker rule from forward-looking vendor and workflow assumptions
  • Do not infer that clients or advisers have no digital-asset tax recordkeeping obligations
  • Distinguish non-custodial DeFi interfaces from custodial brokers covered by other reporting rules
Previous interpretation

The December 2024 final rule was expected to bring specified DeFi trading front-end providers into section 6045 reporting beginning with later transaction years.

Version 1 · published
Enforcement New York State Department of Financial Services

NYDFS settles Cash App AML and virtual-currency compliance failures with Block

Primary document
What changed

NYDFS imposed a $40 million penalty and independent monitor after finding customer-identification, due-diligence, and transaction-monitoring failures, including controls for high-risk Bitcoin activity.

Who it affects
  • Virtual-currency and money-transmission firms, investment advisers diligencing platforms, and clients using Cash App
What remains unresolved
  • Completion of remediation and the monitor’s findings
Advisor workflow implications
  • Use the order as a diligence benchmark for platform growth controls, alert backlogs, customer identification, transaction monitoring, and board oversight.
Version 1 · published
Guidance SEC Division of Corporation Finance

SEC staff identifies disclosure considerations for crypto-asset securities offerings and registrations

Primary document
What changed

Corporation Finance staff organized disclosure considerations for registered offerings and registrations involving crypto assets, including business, technical, rights, network, custody, market, and legal risks. The statement does not create new disclosure obligations or determine whether a particular crypto asset is a security.

Who it affects
  • Advisers diligencing crypto-related issuers and tokenized securities
  • Public companies, funds, broker-dealers, and offering participants
What remains unresolved
  • How the staff will apply the considerations to new structures
  • Which disclosures are material for a specific issuer or product
Advisor workflow implications
  • Add the identified disclosure topics to product and issuer diligence checklists
  • Compare marketing claims against filed rights, custody mechanics, network dependencies, and risk factors
Previous interpretation

Crypto-related filing comments existed, but the Division had not consolidated its current disclosure observations in this form.

Version 1 · published
Official signal · nonbinding Acting Chair of the Commodity Futures Trading Commission

CFTC leadership narrows digital-asset enforcement priorities toward fraud and willful violations

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The CFTC Acting Chair directed enforcement staff to focus digital-asset resources on fraud, manipulation, customer harm, and willful misconduct and to deprioritize certain registration-only cases lacking evidence of knowing and willful violation. The direction changes enforcement emphasis but does not repeal registration requirements or bind courts.

Who it affects
  • Digital-asset derivatives and retail commodity market participants
  • FCMs, CTAs, CPOs, exchanges, platforms, advisers, and clients
What remains unresolved
  • How later Commission leadership and enforcement staff will apply the direction
  • Matter-specific charging, litigation, and settlement decisions
Advisor workflow implications
  • Do not treat lower enforcement priority as permission to ignore registration or conduct rules
  • Continue platform, counterparty, marketing, fraud, manipulation, and client-harm diligence
Previous interpretation

CFTC digital-asset enforcement placed greater emphasis on registration theories without this express prioritization directive.

Version 1 · published
Guidance U.S. Department of Justice, Office of the Deputy Attorney General

DOJ narrows digital-asset enforcement priorities

Primary document
What changed

The Deputy Attorney General directed DOJ personnel to stop using criminal enforcement to create digital-asset regulatory frameworks and to focus cases on knowing or willful violations and conduct involving investor victimization, terrorism, narcotics, human trafficking, organized crime, hacking, or illicit finance. The memorandum also disbanded the National Cryptocurrency Enforcement Team and restricted charges against exchanges, mixers, and wallets based only on end-user conduct or unwitting regulatory violations.

Who it affects
  • Digital-asset businesses
  • investment advisers conducting digital-asset diligence
  • compliance and AML teams
  • custodians
  • exchanges
  • wallet and mixer providers
  • digital-asset investors
What remains unresolved
  • How individual U.S. Attorney offices will apply the memorandum to particular facts
  • The relationship between narrowed criminal priorities and civil regulatory enforcement
Advisor workflow implications
  • Recalibrate enforcement-risk diligence to the new DOJ priorities without treating the memorandum as a safe harbor or reducing independent securities, commodities, sanctions, AML, custody, or fiduciary analysis.
Version 1 · published · effective 2025-04-07
Official signal · nonbinding SEC Division of Corporation Finance

SEC staff states that described reserve-backed payment stablecoins are not securities

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Corporation Finance staff stated that offers and sales of stablecoins meeting the statement’s reserve, redemption, marketing, and non-yield characteristics do not involve securities. The statement is nonbinding and does not cover algorithmic, yield-bearing, under-reserved, or differently marketed products.

Who it affects
  • Advisers using stablecoins in client cash, settlement, or DeFi workflows
  • Stablecoin issuers, custodians, platforms, and payment providers
What remains unresolved
  • Treatment of stablecoins outside the described facts
  • Interaction with the later-enacted GENIUS Act and implementing rules
Advisor workflow implications
  • Create product-level controls for reserve quality, redemption, issuer, jurisdiction, and yield features
  • Avoid applying the statement categorically to every asset called a stablecoin
Previous interpretation

SEC staff had not supplied this current fact pattern for distinguishing described payment stablecoins from securities.

Version 1 · published
March 2025 · 7 entries
Guidance Federal Deposit Insurance Corporation

FDIC rescinds prior-approval expectations for bank crypto-related activities

Primary document
What changed

The FDIC rescinded FIL-16-2022 and stated that FDIC-supervised institutions may engage in permissible crypto-related activities without first notifying the agency or receiving nonobjection. Institutions must continue to manage safety, soundness, consumer-protection, and legal risks.

Who it affects
  • FDIC-supervised banks
  • Advisers evaluating bank custody, payment, and settlement providers
What remains unresolved
  • How supervised banks will implement new services
  • Activity-specific supervisory expectations and consumer disclosures
Advisor workflow implications
  • Refresh bank-provider diligence and service-availability assumptions
  • Confirm the institution’s actual authority, controls, and contract terms for the contemplated client workflow
Previous interpretation

FIL-16-2022 directed FDIC-supervised institutions to notify the agency and obtain supervisory feedback before engaging in crypto-related activities.

Version 1 · published
Guidance U.S. Commodity Futures Trading Commission

CFTC staff withdraws special risk-review advisory for expanded digital-asset clearing

What changed

CFTC clearing staff withdrew Advisory 23-07, which had described review of risks associated with DCO expansion into digital-asset clearing.

Who it affects
  • DCOs, FCMs, advisers, and clients using cleared digital-asset products
What remains unresolved
  • Whether replacement clearing-risk guidance will be issued
Advisor workflow implications
  • Update due-diligence references so the withdrawn advisory is not described as current staff policy.
Version 1 · published
Guidance Commodity Futures Trading Commission staff

CFTC staff withdraws special virtual-currency derivative listing advisory

Primary document
What changed

CFTC staff withdrew Advisory 18-14 concerning virtual-currency derivative product listings.

Who it affects
  • DCMs, DCOs, FCMs, commodity pools, CTAs, investment advisers, and clients
What remains unresolved
  • How ordinary product-review processes will address virtual-currency derivatives
Advisor workflow implications
  • Update product-listing and diligence assumptions but retain all generally applicable CFTC requirements.
Version 1 · published
Agency order U.S. Department of the Treasury · Office of Foreign Assets Control

Treasury removes Tornado Cash property and addresses from OFAC sanctions lists

Primary document
What changed

Treasury removed Tornado Cash-related persons and property from OFAC’s Specially Designated Nationals and Blocked Persons List following legal and policy review. Delisting removes those particular blocking sanctions but does not eliminate sanctions screening, anti-money-laundering duties, or exposure to independently sanctioned counterparties.

Who it affects
  • Advisers and compliance teams screening wallets and protocols
  • Custodians, exchanges, transaction-monitoring providers, and clients
What remains unresolved
  • How providers will update risk models and service restrictions
  • Ongoing litigation and treatment of transactions involving separately sanctioned actors
Advisor workflow implications
  • Update sanctions-screening references and vendor rules to reflect the official delisting
  • Do not equate delisting with a general finding that all Tornado Cash-related activity is lawful or appropriate
Previous interpretation

OFAC designations required U.S. persons to block covered Tornado Cash property and avoid prohibited dealings absent authorization.

Version 1 · published
Official signal · nonbinding SEC Division of Corporation Finance

SEC staff states that described proof-of-work mining activities are not securities transactions

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Corporation Finance staff stated that the proof-of-work mining activities described in the statement do not involve securities transactions. The view is limited to the stated facts and is not a Commission rule or a conclusion about mining-company securities, hosted products, or other arrangements.

Who it affects
  • Advisers assessing mining-related strategies and client assets
  • Miners, mining-pool operators, platforms, and issuers
What remains unresolved
  • Treatment of materially different pooled, financed, or managed mining arrangements
  • Tax, commodities, environmental, state, and contractual consequences
Advisor workflow implications
  • Separate protocol mining activity from interests in mining businesses or managed arrangements
  • Retain classification and counterparty analysis for each recommended exposure
Previous interpretation

No current SEC staff statement expressly addressed the described proof-of-work activities as a category.

Version 1 · published
Guidance Office of the Comptroller of the Currency

OCC removes supervisory nonobjection requirement for permissible bank crypto activities

Primary document
What changed

The OCC reaffirmed prior legal conclusions permitting specified crypto custody, stablecoin, and distributed-ledger activities and rescinded the requirement that a national bank obtain written supervisory nonobjection before engaging in them. Banks remain subject to safe-and-sound practices and ordinary supervisory review.

Who it affects
  • National banks and federal savings associations
  • Advisers conducting diligence on bank custodians and settlement providers
What remains unresolved
  • Which banks will launch or expand services
  • How institution-specific risk management and examiner expectations will develop
Advisor workflow implications
  • Reassess the bank-custody vendor universe and actual service capabilities
  • Verify contract, control, insurance, segregation, and asset-support details rather than relying on general legal permissibility
Previous interpretation

Interpretive Letter 1179 required written OCC supervisory nonobjection before a bank began the covered crypto activities.

Version 1 · published
Official signal · nonbinding President of the United States · U.S. Department of the Treasury

President establishes a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The President directed the government to hold forfeited bitcoin in a Strategic Bitcoin Reserve and other forfeited digital assets in a separate stockpile, subject to agency and Treasury implementation. The order governs federal holdings and is not an endorsement, suitability finding, or purchase mandate for private clients.

Who it affects
  • Federal agencies holding forfeited digital assets
  • Advisers addressing client questions about government digital-asset policy
What remains unresolved
  • Treasury’s custody, accounting, disposition, and reporting procedures
  • Whether budget-neutral acquisition strategies will be pursued
Advisor workflow implications
  • Keep client communications factual and avoid implying a federal guarantee or price support
  • Monitor Treasury implementation for market, custody, and operational implications
Previous interpretation

Forfeited federal digital assets were generally administered without a presidential reserve-and-stockpile framework.

Version 1 · published
February 2025 · 3 entries
Official signal · nonbinding Board of Governors of the Federal Reserve System

Federal Reserve Vice Chair Barr discusses lessons from novel-activity supervision

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Vice Chair Michael Barr discussed the Federal Reserve’s supervisory approach to novel bank activities and the balance between innovation, risk controls, and consistent treatment.

Who it affects
  • Banks, fintech and crypto counterparties, investment advisers, and clients
What remains unresolved
  • Whether the supervisory framework would be retained or revised
Advisor workflow implications
  • Use the speech as a policy signal only and continue diligence on bank counterparties’ novel-activity controls.
Version 1 · published
Official signal · nonbinding SEC Division of Corporation Finance

SEC corporation-finance staff states that described meme coins generally are not securities

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Corporation Finance staff stated that the offer and sale of meme coins with the characteristics described in the statement generally do not involve securities. The statement is nonbinding, fact-specific, and does not protect products labeled as meme coins that are structured or marketed differently.

Who it affects
  • Advisers evaluating meme-coin exposure or client requests
  • Issuers, promoters, platforms, and custodians
What remains unresolved
  • How the SEC will analyze hybrid or promoter-supported meme-coin arrangements
  • Application of state law, commodities law, fraud law, and adviser fiduciary obligations
Advisor workflow implications
  • Do not use the staff statement as a blanket asset-approval list
  • Document product-specific facts, liquidity, manipulation, custody, valuation, and communication risks
Previous interpretation

There was no comparable current staff statement identifying a described category of meme coins as outside federal securities registration.

Version 1 · published
Official signal · nonbinding Board of Governors of the Federal Reserve System

Federal Reserve Governor Waller outlines a bank-and-nonbank stablecoin framework

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

Governor Christopher Waller described stablecoins as potentially useful payment instruments and called for a framework that permits both bank and nonbank issuers with appropriate safeguards.

Who it affects
  • Stablecoin issuers, banks, payment firms, investment advisers, and clients using stablecoins
What remains unresolved
  • The final statutory and agency framework and division of federal and state oversight
Advisor workflow implications
  • Track issuer eligibility, reserve, redemption, custody, and payment-use requirements without treating the speech as binding law.
Version 1 · published
January 2025 · 9 entries
Guidance Financial Industry Regulatory Authority

FINRA’s 2025 oversight report details crypto-asset supervisory findings

Primary document
What changed

FINRA’s 2025 report identified crypto-related failures and effective practices involving public communications, SIPC distinctions, private-placement diligence, AML monitoring, outside activities, and supervision of affiliates and associated persons.

Who it affects
  • FINRA member firms, dual registrants, associated persons, investment advisers, and clients
What remains unresolved
  • How FINRA will apply the observations in individual examinations and enforcement matters
Advisor workflow implications
  • Test crypto communications, account and SIPC disclosures, private-placement diligence, AML monitoring, outside-activity questionnaires, and affiliate supervision.
Version 1 · published
Official signal · nonbinding President of the United States · President’s Working Group on Digital Asset Markets

Executive Order 14178 sets a federal digital-asset policy and creates a presidential working group

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The President revoked the prior digital-assets executive order, barred agencies from taking action to establish or promote a U.S. central bank digital currency, and created a working group to recommend a federal digital-asset framework. The order directs executive-branch policy but does not itself authorize an adviser product or override statutes and independent-agency rules.

Who it affects
  • Federal financial regulators and executive departments
  • Advisers, clients, issuers, custodians, and trading venues monitoring policy direction
What remains unresolved
  • Which recommendations will be implemented by rule, order, guidance, or legislation
  • How independent agencies will act within their statutory mandates
Advisor workflow implications
  • Treat the order as a policy and timing signal
  • Map later agency actions back to the order without assuming immediate workflow permission
Previous interpretation

Executive Order 14067 supplied the prior government-wide digital-assets policy framework.

Version 1 · published
Guidance SEC Office of the Chief Accountant · SEC Division of Corporation Finance

SEC accounting staff rescinds SAB 121 through Staff Accounting Bulletin 122

Primary document
What changed

SEC accounting staff rescinded SAB 121’s staff view that an entity safeguarding customer crypto assets should recognize a safeguarding liability and corresponding asset. The rescission does not eliminate generally applicable accounting, loss-contingency, or risk-disclosure requirements.

Who it affects
  • Public companies and financial institutions safeguarding crypto assets
  • Advisers assessing the financial condition and operational resilience of crypto custodians
What remains unresolved
  • How individual custodians will revise financial statements and controls
  • Whether custody capacity and pricing will change in response
Advisor workflow implications
  • Refresh custodian financial-condition diligence using post-rescission statements
  • Do not describe the bulletin as an SEC custody exemption or qualified-custodian determination
Previous interpretation

SAB 121 stated that safeguarding entities should recognize a liability and corresponding asset for customer crypto assets held.

Version 1 · published · effective 2025-01-30
Enforcement Financial Industry Regulatory Authority

FINRA sanctions Avenue Securities over influencer communications including crypto promotions

Primary document
What changed

FINRA censured Avenue Securities, fined it $300,000, and required remediation certification after finding that paid influencer posts were misleading or not fair and balanced, were not consistently identified as advertisements, lacked required approval and retention, and were inadequately supervised. Some posts encouraged crypto purchases without clearly explaining the risk of total loss.

Who it affects
  • Broker-dealers using influencers or affiliates for social-media marketing
  • Advisory affiliates sharing a brand or campaign with a broker-dealer
  • Compliance teams reviewing crypto, ETF and cross-border retail communications
What remains unresolved
  • How FINRA will distinguish firm communications from affiliate or influencer content in future cases
  • Whether similar campaigns will draw coordinated SEC or state scrutiny
Advisor workflow implications
  • Inventory paid and affiliate influencers; preapprove static content, retain communications and approvals, label advertisements, substantiate claims, balance benefits with crypto loss risk, and make supervisory ownership explicit.
Version 1 · published · effective 2025-01-22
Official signal · nonbinding U.S. Securities and Exchange Commission · SEC Crypto Task Force

SEC launches a Crypto Task Force led by Commissioner Peirce

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The SEC created a dedicated Crypto Task Force and assigned it to identify registration paths, disclosure frameworks, and sensible enforcement deployment. Formation of the task force is an agency-direction signal, not a rule, exemption, or change to existing adviser obligations.

Who it affects
  • SEC-registered investment advisers with digital-asset exposure
  • Broker-dealers, funds, custodians, issuers, and trading venues
What remains unresolved
  • Which recommendations will become Commission rules or orders
  • Timing and scope of any registration or disclosure accommodations
Advisor workflow implications
  • Track task-force outputs separately by legal posture
  • Continue applying existing custody, fiduciary, disclosure, and trading rules until operative relief is issued
Previous interpretation

Crypto policy work was distributed across SEC divisions without a newly designated cross-agency task force.

Version 1 · published
Guidance New York State Department of Financial Services

NYDFS warns regulated firms about sentiment-based virtual currencies

Primary document
What changed

NYDFS directed regulated virtual-currency businesses to apply product-listing, governance, disclosure, and consumer-protection controls to rapidly proliferating sentiment-based virtual currencies, including so-called memecoins.

Who it affects
  • New York-licensed virtual-currency businesses, their counterparties, investment advisers, and clients considering sentiment-based tokens
What remains unresolved
  • How DFS will assess particular listings, delistings, disclosures, and promotional practices
Advisor workflow implications
  • Apply heightened product, liquidity, manipulation, concentration, custody, and disclosure diligence before permitting client exposure.
Version 1 · published
Court decision U.S. Court of Appeals for the Third Circuit

Third Circuit orders the SEC to better explain its denial of Coinbase rulemaking petition

Primary document
What changed

The Third Circuit remanded the SEC’s denial of Coinbase’s petition for crypto-specific rules because the agency had not adequately explained its reasoning. The court did not order the SEC to adopt rules and did not decide the status of any particular token or transaction.

Who it affects
  • Investment advisers evaluating the legal classification of crypto assets
  • Trading platforms and other market participants seeking SEC rulemaking
What remains unresolved
  • How the SEC will respond on remand
  • Whether later Commission interpretations or legislation will displace the petition dispute
Advisor workflow implications
  • Do not treat the remand as substantive permission to recommend or trade a particular asset
  • Preserve classification and venue due-diligence records while the agency response remains pending
Previous interpretation

The SEC’s denial stood without a judicial requirement that the agency provide a fuller rationale.

Version 1 · published
Official signal · nonbinding Consumer Financial Protection Bureau

CFPB seeks input on privacy and surveillance in digital payments

This item records a policy signal. It does not by itself change applicable law.

Primary document
What changed

The CFPB requested public input on collection, use, sharing, protection, and monetization of consumer payment and other financial data, including payment-platform surveillance, personalized pricing, Regulation P notices and opt-outs, and routine monitoring. The notice expressly discussed stablecoins and other digital currencies; it did not itself change law.

Who it affects
  • Payment and wallet providers
  • Stablecoin and other digital-currency platforms with consumer payment use cases
  • Financial institutions and fintech data recipients
  • Advisers whose client portals or vendors access payment data
What remains unresolved
  • Whether the CFPB will pursue Regulation P, privacy, supervision, or enforcement changes based on the record
  • How leadership changes and related withdrawn payment-mechanism guidance affect future action
Advisor workflow implications
  • Inventory payment-data collection and vendor sharing, privacy notices, opt-out mechanics, secondary uses, personalized pricing, retention, security, and complaint handling while treating the RFI as nonbinding.
Version 1 · published
Guidance Internal Revenue Service · U.S. Department of the Treasury

IRS basis-identification relief takes effect for digital assets held with brokers

Primary document
What changed

Temporary relief took effect allowing eligible taxpayers during 2025 to make adequate unit identification for broker-custodied digital assets through specified records or standing instructions when broker systems could not support the new identification rules. The relief was transitional and did not eliminate basis substantiation or gain and loss reporting.

Who it affects
  • Taxpayers holding digital assets with custodial brokers
  • Advisers managing tax-aware digital-asset transactions
  • Digital-asset brokers and tax-reporting providers
What remains unresolved
  • Whether client and broker records will reconcile under the transition methods
  • Application of the post-2025 broker-communication and default-ordering rules
Advisor workflow implications
  • Preserve contemporaneous wallet, account, lot, transfer, and standing-order records for 2025 transactions
  • Coordinate tax-lot instructions with broker functionality and qualified tax professionals before dispositions
Previous interpretation

Without the temporary relief, taxpayers risked default ordering or inadequate identification when broker technology could not accept the required instructions.

Version 1 · published · effective 2025-01-01

Coverage and corrections

The ledger monitors U.S. authorities relevant to registered investment advisers and records nationally material state developments. Published entries are versioned. Corrections and changed interpretations supersede prior versions rather than silently rewriting them.