Insights

Fed Withdrawal of Guidance Marks Milestone for Banks’ Future Crypto Activity

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Summary: Situation Overview: The federal banking agencies have withdrawn previously issued guidance related to banks’ crypto activities, marking a shift in regulatory posture toward digital asset engagement. What: On April 25, the Federal…

Key Takeaways from SEC Crypto Task Force Custody Roundtable

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Summary: Situation Overview: The SEC’s Crypto Task Force is advancing its exploration of regulatory frameworks for digital asset custody. What: The SEC hosted its third roundtable, Know Your Custodian, focusing on challenges and potential…

Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership

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What’s Happening Federal Reserve (FRB) denies membership and master account application for state-chartered Custodia Bank with crypto-focused business model FRB presumptively prohibits banks it supervises from holding crypto as principal…

Banking Regulators Send Strong Warning About Crypto Risks

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Federal banking agencies encourage banks to monitor crypto risks, stress importance of keeping crypto sector risks isolated from broader financial system. Regulators view open, public or decentralized networks as highly likely to be inconsistent…

Crypto Requires Robust Risk Management Framework

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Effective and comprehensive risk management is key to the cryptocurrency industry’s future success. The industry would mitigate various risks by following the five principles described here. The recent bankruptcy of a major cryptocurrency…

FSOC Releases Digital Asset Report, Signaling Increased Future Scrutiny

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A recent digital asset report (“Report”) issued by the Financial Stability Oversight Council (“FSOC”) criticized many digital asset market activities and market participants for lacking sufficient risk controls or amplifying financial…

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

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The crypto industry yearns for legislative clarity on stablecoins, but the industry and consumers may be better off under the status quo than a flawed compromise. A one-size-fits-all approach could squash innovation. Expanding Federal…

Federal Reserve Board Provides Additional Information for Banks Interested in Crypto-Related Activities

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Federal Reserve outlines step-by-step process for banks considering crypto-related activities. Despite efforts to add controls to crypto activities, several senators still believe crypto-related activities pose too great a risk for national…

Federal Reserve Board Announces Updated Guidelines for Account Access, But Questions Remain

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Federal Reserve Board introduces three-tiered review system for access to its payments system. Federally insured banks will on average have less stringent reviews, while nonbanks will receive the most diligence and scrutiny. Despite…

Senators Pressure OCC to Rescind Crypto Bank Guidance, Adding Regulatory Uncertainty

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Senators ask the Office of the Comptroller of the Currency (OCC) to rescind interpretive letters clarifying banks’ authority to engage in crypto-related activities. Despite efforts adding controls to crypto activities, senators still…