The Securities and Exchange Commission (“SEC”) has issued a no-action letter to the Depository Trust Company (“DTC”) in connection with the registered clearing agency’s pilot blockchain-based securities tokenization program. A no-action letter is a document issued by the SEC in response to a request from an individual or entity seeking confirmation that their planned activities do not constitute a violation of federal securities laws. The DTC’s program enables the tokenization of entitlements to certain eligible securities held by investors through the DTC. Investors opting into the program are able to utilize pre-approved blockchains and registered wallets to hold their tokenized securities entitlements and transfer them among other program participants. The plan also permits “de-tokenization” whereby the tokenized entitlement is reverted to a standard book entry with the DTC. The SEC’s blessing for the plan represents a significant step towards moving markets “on-chain.”Continue Reading SEC No-Action Letter Paves Way for Tokenization of Securities

On December 10, 2025, Gemini Space Station, Inc. (NASDAQ:GEMI) announced that the Commodity Futures Trading Commission (“CFTC”) approved the registration of its subsidiary—Gemini Titan, LLC—as a Designated Contract Market (“DCM”), making it the first crypto-native exchange to obtain the necessary regulatory license to operate a prediction market for U.S. retail investors.Continue Reading Digital Asset Exchange Receives CFTC Approval for US Prediction Markets, Signaling an Opportunistic Outlook

On December 12, the Office of the Comptroller of the Currency (OCC) announced conditional approval for five national trust bank charter applications from five major crypto companies. These conditional approvals mark a notable development in the federal supervision of crypto-native business models, underscoring the OCC’s continued caution in extending the national banking framework to firms engaged in digital asset custody and stablecoin-related activities.Continue Reading OCC Conditionally Approves Digital Asset Trust Bank Charters, Signaling Cautious Expansion of Federal Oversight

In United States v. Chastain, No. 23-7038, 2025 WL 2165839 (2d Cir. July 31, 2025), the United States Court of Appeals for the Second Circuit vacated wire fraud and money laundering convictions in what the government described as its first crypto insider trading case. The case involves a former employee of OpenSea, an online non-fungible token (“NFT”) marketplace, who allegedly used confidential information about which NFTs would be featured on OpenSea’s homepage to purchase those NFTs before they were promoted, then sold them after a post-promotion price bump for a profit. At trial, the United States District Court for the Southern District of New York instructed the jury that property protected by the wire fraud statute need not have commercial value, and the defendant could be convicted of wire fraud by failing to abide by societal mores.Continue Reading Second Circuit Vacates Fraud Conviction in First Crypto “Insider Trading” Case

Maine’s Gambling Control Unit (GCU) has issued a formal warning regarding the proliferation of illegal interactive gaming (“iGaming”) platforms operating within the state. The warning emphasized that while certain forms of online gambling—such as advance deposit wagering, fantasy contests, and sports betting—are legally permitted and regulated in Maine, online casino-style games remain strictly prohibited. This includes games like slots, blackjack, and roulette when played for real money. The warning goes on to state: “Of particular concern are so-called “sweepstakes” or “social casino” sites that may offer real-money payouts, dual-currency systems, or prizes such as gift cards. These platforms are not licensed or overseen by the GCU.”Continue Reading Maine Gambling Control Unit Issues Warning on Illegal Online Gaming Including Certain Sweepstakes Models

We have previously posted on some of the recent legal issues with social casino sweepstakes. See Social Casino Sweepstakes Model is Under Fire – What Game Companies, Payment Processors and App Stores Need to Know. Various states have taken action to shut down these apps in their states. The NY AG, working with the New York State Gaming Commission, allegedly identified 26 online platforms offering players slots, table games, and sports betting using virtual coins that could be exchanged for cash and prizes. On June 6, the NY AG announced that it has stopped online sweepstakes casinos operating in New York. This action follows cease and desist letters to operators dating back to March 7, 2025.Continue Reading NY AG Seeks to Shut Down Sweepstakes Casinos in NY

In a May 12, 2025 Keynote Address before the U.S. Securities and Exchange Commission (“SEC”) Crypto Task Force’s fourth industry roundtable on digital assets, newly-minted Chair Paul Atkins laid out a sweeping vision for modernizing the U.S. securities framework to accommodate blockchain-based assets. His remarks reflect a sharp departure from his predecessor’s enforcement-heavy stance and outline a more rules-based, innovation-oriented approach.Continue Reading Chairman Atkins Outlines SEC’s New Roadmap for Crypto Reform

On April 18, 2025, the State of Oregon brought a civil enforcement action against Coinbase Global, Inc. (“Coinbase”) for the alleged sale of unregistered securities. In a press release, Oregon Attorney General Dan Rayfield openly acknowledged the action was in response to the United States Securities and Exchange Commission (“SEC”) dropping its own case against Coinbase, noting his belief that “states must fill the enforcement vacuum being left by federal regulators who are giving up under the new administration.” This begs the question: is the federal government’s resetting of its approach to crypto regulation an “enforcement vacuum” or a return to order?Continue Reading Oregon Suit Muddies Crypto Regulatory Landscape

Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, federal agencies and market participants may begin to grapple with the operational and compliance implications of the federal government’s proposed foray into crypto ownership and stewardship. While many of the program’s details remain under development, the initiative raises questions related to governance, custody, disclosure, and alignment with existing financial and national security laws.Continue Reading Federal Crypto Ownership: Compliance Implications of the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile

On April 1, the Conference of State Bank Supervisors (CSBS) submitted a letter to the House Financial Services Committee expressing concerns with an introduced draft of H.R. 2392—the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025 (the “Act”)—which purports to establish a comprehensive regulatory framework for payment stablecoins in the U.S. In the letter, CSBS expresses support for the development of a national framework for payment stablecoin issuers (PSIs), while warning that the current draft would unnecessarily preempt state regulatory authority and introduce risks to consumer protection and financial stability.Continue Reading CSBS Flags Key Risks in Draft Stablecoin Legislation