Debevoise & Plimpton LLP has published a guide on the GENIUS Act, and the OCC and FDIC proposed rules, including our observations on key issues and on the potential implications and opportunities for the banking industry. The key takeaways from the guide, which was authored by lawyers from the firm’s Banking and National Security Groups, are: the GENIUS Act, signed…
On March 17, 2026, the Securities and Exchange Commission (the “SEC”) issued an interpretive release (the “Release”) regarding the application of the federal securities laws to certain types of crypto assets and transactions involving crypto assets, based primarily on whether they are subject to an “investment contract” under the Howey test. The Release articulates the SEC’s view as to how the Howey test applies to crypto…
On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a comprehensive rulemaking proposal (the “NPR”) to implement its statutory responsibilities under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (“GENIUS Act” or the “Act”). The GENIUS Act, enacted on July 18, 2025, establishes a framework for the issuance and sale of payment stablecoins…
On July 18, 2025, President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” or the “Act”) after its passage in the House and Senate with broad bipartisan support. The GENIUS Act establishes a comprehensive regulatory framework for payment stablecoins, and it is the first federal statute to directly regulate the digital asset market.…