Overview On Friday, March 7, 2025, the new leadership of the Office of the Comptroller of the Currency (the “OCC”) took initial steps in what we believe to be a broader effort to liberalize the OCC’s approach to regulating crypto-asset activities of national banks and federal saving associations (“FSAs”). Most significantly, in Interpretive Letter #1183, it rescinded OCC Interpretive Letter…

Debevoise & Plimpton LLP has published a guide on the Trump administration’s approach to the crypto-asset industry, including potential regulatory implications and outlook. The key takeaways from the guide, which was authored by lawyers from the firm’s Banking, Capital Markets, National Security and White Collar Groups, are: President Trump has positioned himself as an ally of the crypto-asset industry. Signaling a…

The Department of Justice (“DOJ”) has moved ahead with its effort to protect Americans’ sensitive personal data and U.S. government data from exploitation by countries of concern or related covered persons, issuing a Notice of Proposed Rulemaking (the “Proposal”) that closely tracks its earlier Advance Notice of Proposed Rulemaking (the “Advance Notice”). The Advance Notice had been released in February concurrently…

Debevoise & Plimpton LLP has published a guide to the potential impact of the U.S. election on the financial services industry, including possible regulatory implications. The key takeaways from the guide, which was authored by 18 lawyers from the firm’s Antitrust, Banking, Data Strategy and Security, M&A and White Collar Groups, are: Although neither candidate has focused on financial services,…

On June 24, 2024, the Office of the Comptroller of the Currency (the “OCC”) issued a notice of proposed rulemaking (the “Proposal”) that would amend its recovery planning guidelines for large insured banks under OCC oversight (i.e., national banks, federal savings banks and federal branches). Comments are due on the Proposal 30 days after the date of publication in the…