Digital Assets Download – Summertime For Digital Assets

Digital Assets Download: Summer Heats Up for Digital Assets. This issue highlights a wave of US regulatory activity implementing the GENIUS Act, including proposed KYC, AML, and sanctions requirements for stablecoin issuers. We also examine key developments in the United Kingdom, where policymakers continue to advance frameworks for tokenized securities, digital asset custody, and distributed ledger-based market infrastructure.

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. We also invite readers to explore our new Stablecoins & Tokenization Resource Center, designed to help navigate the rapidly expanding tokenization landscape.

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.

FinCEN and Banking Agencies Propose CIP Rules for Stablecoin Issuers

FinCEN, together with federal banking regulators, proposed new rules under the GENIUS Act requiring permitted payment stablecoin issuers to implement customer identification programs (CIPs) similar to those used by traditional financial institutions. The proposal would subject stablecoin issuers to enhanced KYC and AML obligations, including customer identity verification, recordkeeping, and sanctions screening, marking a significant step in establishing a comprehensive federal regulatory framework for the US stablecoin market.

FCA and Bank of England Seek Input on Tokenisation of UK Wholesale Capital Markets

The Financial Conduct Authority and Bank of England issued a joint Call for Input outlining a proposed regulatory framework for tokenised securities in wholesale markets, including bonds, equities, and fund units. The paper sets out core regulatory principles—such as accountability, operational resilience, market integrity, AML/KYC compliance, and settlement finality—while emphasizing that tokenised activity should remain anchored in existing regulatory standards and central bank money. It also identifies key priority areas for further rulemaking, including digital securities settlement, prudential treatment, tokenised collateral, and custody frameworks, signaling a multi‑year roadmap toward integrating distributed ledger technology into the UK’s capital markets infrastructure while mitigating risks around fragmentation, governance, and investor protection.

Coinbase Litigation Leader on Navigating Crypto and AI

In a recent Tools of the Trade podcast, Coinbase’s Vice President of Legal and Global Head of Litigation shares insights on navigating the rapidly evolving cryptocurrency industry, drawing on experience across both the public and private sectors. The discussion highlights practical approaches to addressing regulatory complexity, including leveraging internal expertise to bridge knowledge gaps in new and technical areas. It also explores how emerging technologies such as AI are transforming the digital assets landscape, underscoring the continued importance of human judgment and decision‑making in managing legal, compliance, and operational risks.

UK Jurisdiction Taskforce Issues Guidance on Control of Digital Assets

The UK Jurisdiction Taskforce published a report offering non‑binding but practical guidance on how “control” operates in digital asset systems under English law, building on the United Kingdom’s evolving “third category” of property for digital assets. The report clarifies how control—through mechanisms such as private keys, smart contracts, and custodial arrangements—serves as the functional equivalent of possession, and provides a framework for courts and market participants to assess ownership, jurisdiction, and evidentiary challenges. By bridging technical realities with legal analysis, the guidance aims to enhance certainty in digital asset transactions and disputes, particularly in cases involving complex custody structures and privacy‑enhancing technologies.

FDIC Proposes GENIUS Act Stablecoin Rules, Diverging from OCC Framework

The FDIC issued proposed rules to implement the GENIUS Act for payment stablecoins, largely aligning with the OCC’s framework but introducing notable differences on reserve requirements, redemption mechanics, and supervisory controls. The proposal also addresses deposit insurance treatment—clarifying that stablecoin reserves would not receive pass‑through coverage—highlighting emerging divergence in how US regulators are shaping oversight of stablecoin issuers.

Treasury Proposes AML and Sanctions Framework for Stablecoin Issuers

Treasury, through FinCEN and OFAC, proposed rules implementing the GENIUS Act that would subject stablecoin issuers to bank‑like AML/CFT obligations and, for the first time, require a mandatory sanctions compliance program. The proposal underscores a significant shift toward integrating stablecoin issuers into the core US financial crime compliance regime, while drawing a nuanced distinction between primary market oversight and more limited obligations for secondary market activity.

News Node

Regulatory/Enforcement

Bitcoin Suisse Wins Abu Dhabi License, Extends Digital Asset Push into the UAE

The SEC Just Included Digital Assets In Its 5-Year Strategic Plan. Which Cryptocurrencies Could See the Biggest Gains?

CFTC aligns whistleblower award rules with SEC, adds 30% presumption for claims under $5M

SEC to propose tokenized stock framework as Wall Street efforts deepen

US Senate committee advances crypto bill in milestone for digital assets

UK regulators set out program to boost digital assets

CLARITY Act, GENIUS Act, and the Next Phase of U.S. Crypto Regulation

Markets

Vanguard opens search for digital assets leader in sign of evolving crypto strategy

JPMorgan says Strategy's bitcoin sales policy adds risk to crypto markets

Sovereign wealth funds favor regulated access to Bitcoin and digital assets

Robinhood Launches Its Own Blockchain, New Stock Tokens And DeFi Products

Standard Chartered to acquire Zodia Custody

Courts

Judge halts Ken Paxton's 'retaliatory' ActBlue fundraising lawsuit

Prime Trust estate demands $150M in digital assets in bankruptcy

Select Events

Stablecoins and the Evolving Transatlantic Regulatory Landscape: Mayer Brown partners Matt Bisanz, Musonda Kapotwe, and Marcel Hörauf discussed the shifting regulatory frameworks governing stablecoins across the United States and Europe, highlighting key divergences and emerging areas of convergence in transatlantic oversight.

Global Blockchain & Crypto Symposium 2026: Mayer Brown sponsored the Global Blockchain & Crypto Symposium 2026, which took place in London on June 24. Musonda Kapotwe spoke at the “Crypto Fraud — What’s Next?” panel, which examined the evolving landscape of crypto-related fraud and the strategies organizations can adopt to mitigate risk. The discussion covered emerging fraud schemes; regulatory, enforcement, and legal responses; technology-driven detection tools; corporate risk management practices; and the importance of industry collaboration. Panelists also explored practical measures to protect digital assets, enhance governance, and strengthen resilience across the digital asset ecosystem.

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.

PRUDENTIAL BACKSTOPS

Prudential backstops are regulatory safeguards—such as capital, liquidity, and reserve requirements—designed to ensure financial institutions can meet their obligations under stress. In the context of stablecoins, proposed frameworks like the GENIUS Act incorporate prudential backstops to require issuers to maintain high-quality reserves, implement risk management controls, and ensure orderly redemption, reflecting a broader shift toward bank-like oversight of digital asset providers.

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.