In a recent Law360 article, Baker McKenzie partner David Zaslowsky examines the FDIC’s most recent proposed rule to implement the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act. The proposed rule represents the financial crime compliance pillar of this emerging regime, following earlier agency proposals addressing application procedures and prudential requirements.Under the proposed rule, FDIC-supervised permitted payment stablecoin issuers would be required to implement robust, risk-based compliance programs. These programs would encompass core…
On June 22, 2026, the U.S. Senate passed sweeping bipartisan housing legislation—the 21st Century ROAD to Housing Act—aimed primarily at increasing housing supply and improving affordability. The House followed suit the next day in a 358-32 vote. President Trump was scheduled to sign the bill on June 24, 2026, but, at the last moment, cancelled the signing ceremony. Tucked within the bill is a provision with potentially far-reaching consequences for the future of digital finance:…
The Federal Deposit Insurance Corporation (FDIC) has taken a significant step toward implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) by approving a notice of proposed rulemaking (NPRM) that would establish a comprehensive Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance framework for certain stablecoin issuers. The proposal signals that stablecoin issuance within the U.S. regulatory perimeter will be subject to compliance expectations closely aligned with those applicable…
On April 8, 2026, the US Department of the Treasury’s (“Treasury“) Financial Crimes Enforcement Network (“FinCEN“) and the Office of Foreign Assets Control (“OFAC“) issued a joint proposed rule (“Proposed Rule“) to implement provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (“GENIUS Act“). The Proposed Rule implements the GENIUS Act’s anti-money laundering (“AML“) and sanctions compliance program requirements and encourages innovation in payment stablecoins while providing a regulatory regime to mitigate potential illicit…
The U.S. Department of the Treasury has taken a significant step in implementing the GENIUS Act’s stablecoin framework. On April 1, Treasury released a Notice of Proposed Rulemaking (the “Treasury NPRM”) to implement Section 4(c) of the Act, establishing broad‑based principles for determining whether a State‑level stablecoin regulatory regime is “substantially similar” to the federal regulatory framework established by the GENIUS Act. The Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act” or “Act”)…
One of the most anticipated features of the bi-partisan Digital Asset Protection, Accountability, Regulation, Innovation, Taxation, and Yields Act (the PARITY Act) has been its attempt to mitigate the tax reporting burdens associated with small‑value digital asset transactions. When the bill was first released in discussion draft form in December 2025, it proposed a relatively familiar solution: a de minimis exception modeled on existing foreign‑currency rules. When a revised draft was released on March 26, 2026,…
For years, blockchain developers have urged U.S. courts to provide clearer ex ante guidance on when writing or deploying decentralized software crosses the line into regulated financial activity. A March 26, 2026 decision by Chief Judge Reed O’Connor of the Northern District of Texas underscores just how difficult that path remains. Case Background The plaintiff, blockchain developer Michael Lewellen, sued the Department of Justice (DOJ) seeking declaratory relief that his Ethereum‑based crowdfunding tool, “Pharos,” did…
In a recent Law360 article, Baker McKenzie partners David Zaslowsky and Peter Chan explore how the US Digital Asset Market Clarity Act, though still pending in Congress, can be used to influence litigation strategy in crypto‑related matters in terms of shaping how courts, regulators and litigants view questions of jurisdiction, classification and regulatory uncertainty.David and Peter explain that even before enactment, the Clarity Act can be used to strengthen fair‑notice and due‑process arguments, support stays…
IRS Form 1099-DA, “Digital Asset Proceeds,” is being rolled out starting with the 2025 tax year. With this new form, the federal government is moving crypto reporting toward the familiar broker-based regime long used for stocks and bonds. However, for those who actively engage with decentralized finance (DeFi), Form 1099-DA may cause increased confusion, inaccurate reporting, and heightened audit risk stemming from the mismatch between how crypto transactions actually function and how they will be…
On January 29, 2026, the U.S. Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) held a closely watched joint public meeting on cryptocurrency regulation and market structure. Led by SEC Chair Paul Atkins and CFTC Chair Michael Selig, the meeting marked one of the most visible efforts in years to present a coordinated federal regulatory approach to digital assets. While the meeting did not result in new rules, its importance lies…