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…
Gemini Trust Company (“Gemini”) is a New York‑based cryptocurrency trust company founded by Tyler and Cameron Winklevoss. The associated cryptocurrency exchange is now known as Gemini Space Station. The Securities and Exchange Commission’s 2023 lawsuit against Gemini was one of the most closely watched legal battles to emerge from the turmoil of the 2022 crypto‑market collapses. On January 23, 2026, the lawsuit came to an end with a dismissal of the case. The Underlying Lawsuit…
Earlier this week, the Senate Banking Committee appeared poised to advance the Digital Asset Market CLARITY Act, a sweeping effort to establish a comprehensive federal framework for digital assets. The legislation passed the House during last summer’s “Crypto Week.” See our post here. The momentum evaporated after leading industry participants publicly withdrew support for the bill’s revised text. Within hours, on January 14, committee leadership delayed the markup, with no new date announced. The Senate’s sudden…
In a decision on December 30, 2025, Judge Roy Altman of the of the U.S. District Court for the Southern District of Florida dismissed a putative class action lawsuit against Mark Cuban and the Dallas Mavericks basketball team. Karnas v. Cuban, No. 22-cv-22538- Altman (S.D. Fla. Dec. 30, 2025). The suit alleged wrongdoing related to their marketing of a cryptocurrency platform. Background (from the Complaint) Voyager Digital, LLC (“Voyager”) launched the “Voyager Platform” in October…