Debevoise & Plimpton LLP has updated its Guide to the GENIUS Act to include the recently published OCC final implementing rules, the U.S. Treasury Department’s proposed rulemaking on the extraterritorial scope of the GENIUS Act and other recent rule proposals under the Act. The updated Guide also includes our observations on key issues and on the potential implications and opportunities…

On October 21, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued final rules (the “Final Rules”) implementing major provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act” or the “Act”). This is the first federal rulemaking to finalize substantive prudential requirements under the GENIUS Act for payment stablecoin issuers. The Final Rules…

On August 18, 2026, the Securities and Exchange Commission (the “SEC”) proposed a new set of rules titled “Regulation Crypto Assets” (the “Proposal”) that would create a tailored offering and reporting regime for certain investment contracts involving non-security crypto assets (“covered investment contracts”). The proposed rules build directly on the interpretive release that the SEC issued on March 17, 2026, which…

On July 22, 2026, SEC Commissioner Hester M. Peirce issued a statement warning that crypto vaults and onchain lending products may trigger obligations under the federal securities laws. The statement comes against the backdrop of the SEC indicating, over the past year, that much digital asset activity does not implicate those laws—and thus serves as an important reminder that crypto projects…

Congress and the federal government under the Trump Administration have made substantial progress in establishing the outlines of a set of interrelated federal regimes for digital financial assets in the United States, but much remains to be done. In particular, the future and contours of market structure legislation for digital securities and commodities remains uncertain, and the federal regulators continue…