Digital Assets Download: Announcing Our Stablecoin & Tokenization Resource Center. Stablecoins and tokenization (or tokenized assets) are significant elements of the wave of innovation that is revolutionizing markets, finance, and money flows. While both have blockchain backbones and have their roots in decentralized finance, both are quickly being adopted by a wide variety of market participants, including traditional financial institutions, payments providers and fintechs. At the same time, stablecoins and tokenized assets also have different use cases, business opportunities, audiences and regulatory challenges. Our Stablecoins & Tokenization Resource Center is designed to track the latest developments in global regulation, legislation, and business issues that are shaping these two trends.
From all of us at Digital Assets Download, we send our best holiday and new year's wishes to all of our readers. Please look for our first edition of 2026 soon after the new year!
For the Uninitiated: Digital Assets Download is a curated mix of insights and headlines that provide a Layer 3 Legal Perspective" on the digital assets multiverse—created by Mayer Brown's global Digital Assets, Blockchain & Cryptocurrency group.
The Lead Block
Perspectives and insights from Mayer Brown lawyers and other thought leaders that touch on digital assets, decentralized finance, cryptocurrencies and related fields.
Virtual Currency Exchange Pleads Guilty to Criminal Charges Related to Anti-Money Laundering Violations and Pays Multi-Million Dollar Fine to FinCEN
On December 9, the US Department of Justice and the Department of the Treasury's Financial Crimes Enforcement Network announced guilty pleas and a consent order a peer-to-peer convertible virtual currency exchange for violations of numerous federal laws. This Legal Update summarizes the DOJ and FinCEN's enforcement actions, key AML compliance considerations identified by FinCEN, and takeaways for financial institutions.
SEC Division of Trading and Markets Issues FAQs on Crypto Asset Activities Focusing on Trading and Settlement Issues
On December 17, the staff of the Division of Trading and Markets of the Securities and Exchange Commission released an update to its May 2025 FAQs relating to crypto asset activities and distributed ledger technology. The additional FAQs focus on trading and settlement issues, including how alternative trading systems and national securities exchanges can facilitate pairs trading (e.g., where one of the crypto assets is a security and the other is a crypto asset that is not a security). This Legal Update describes the update and its implications for crypto market participants.
SEC Staff Statement on Broker-Dealer Custody ("Physical Possession") of Crypto Asset Securities
On December 17, the Staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission issued a statement explaining its views on the application of paragraph (b)(1) of SEC Rule 15c3-3 to broker-dealers seeking to establish custody of crypto asset securities. The statement focuses on broker-dealers' "physical possession" of such securities and is an "interim step" while the SEC continues to consider issues relating to broker-dealer custody of crypto asset securities and the feedback it has received. This Legal Update describes the statement and its implications for broker-dealers.
FDIC Proposes GENIUS Act Application Process for IDI Subsidiary Stablecoin Issuers
On December 16, the Federal Deposit Insurance Corporation ("FDIC") issued a proposal to implement the application-related provisions of the GENIUS Act for subsidiaries of FDIC-supervised insured depository institutions ("IDIs"). The FDIC's proposed application process closely tracks the GENIUS Act's statutory factors, timelines, and denial standard while building out the application process, content and requirements in a manner that is consistent with existing FDIC processes applicable to FDIC-supervised IDIs. This Legal Update reviews key features of the proposal and its implications for FDIC-supervised IDIs.
Proposed Rules from the Bank of England to Regulate Systemic Stablecoins
The Bank of England has proposed a regulatory framework for sterling-denominated systemic stablecoins, covering issuers, payment systems, and custodians. The draft rules introduce requirements for UK-based issuance, asset backing, and operational safeguards. This Legal Update reviews key features of the proposal and its implications for stablecoin providers and financial institutions.
News Node
Regulatory/Enforcement
SEC Pushes New Crypto Rule Despite Major Wall Street Warnings
CFTC Approves First-Ever Spot Crypto Trading On
Regulated Exchanges
FDIC Proposes Application Process for Banks Seeking to Issue Stablecoins
UK Moves Toward Comprehensive Regulation of Digital Assets
SEC Provides Practical Guidance on Custody of
Crypto Assets
Senate Banking will Not Vote on Crypto Bill This Week
Markets
JPMorgan Launches Tokenized Money-Market Fund
Coinbase and Standard Chartered Expand Institutional Crypto Services
Vanguard Opens XRP ETF Access to 50 Million Clients
Coinbase Plans to Launch Prediction Markets Powered by Kalshi
Crypto Groups Slam Citadel for Urging Tighter DeFi Tokenization Rules
Courts
Trump Considers Another Controversial Crypto Pardon
Simulated Trading Firm MyForexFunds Clears Legal
Hurdle to Restart
Florida Court Reopens $80M Bitcoin Theft Case Against Binance
Select Events
Why Stablecoins and the GENIUS Act Matter to IACPM Members: On December 17, Mayer Brown partners Yuliya Feldman and Matthew Bisanz joined an International Association of Credit Portfolio Managers program to examine the GENIUS Act and its impact on stablecoins. The discussion explored the Act's role in creating a federal framework for payment stablecoins, implications for financial institutions and insurers, and emerging opportunities for innovation in the digital asset space.
What to Expect in Banking Regulation in 2026: On January 21, Mayer Brown partners Jeffrey Taft and Matt Bisanz will join a Practicing Law Institute program to discuss key developments in banking regulation. The session will review major reforms from 2025, including GENIUS Act implementation, digital asset activities, fintech charters, Basel III Endgame proposals, and OCC preemption oversight, and explore what these changes mean for institutions moving forward. Visit the event webpage
LEARN THE LINGO
For those new to the digital assets and DeFi world, each edition of the Digital Assets Download will highlight a different term to help you be a part of the conversation.
PROOF OF RESERVES
Proof of Reserves ("PoR") is a verification method used by custodians, exchanges, and stablecoin issuers to demonstrate that they hold sufficient assets to back customer balances or circulating tokens. Typically implemented through cryptographic audits and third-party attestations, PoR provides transparency and helps mitigate counterparty risk. In practice, PoR has become a key trust mechanism for centralized platforms and is increasingly relevant as regulators focus on custody requirements and systemic stablecoin backing. While PoR enhances confidence, it also raises questions about audit standards, frequency, and whether liabilities are fully accounted for—issues that remain central to ongoing regulatory discussions.
Writing on the Wall, Translating 'Crypto' Terms with Mayer Brown
From Airdrop to Wrapped Token, our illustrated glossary, "Writing on the Wall, Translating Securities with Mayer Brown," has been updated with additional digital assets and cryptocurrency terms. Check out our "featured" list for the crypto terms and the full list of terms.
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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.
