The GENIUS Act’s Signing Triggers Countdown to New Stablecoin Rules
On Friday, President Donald Trump signed the GENIUS Act (S.1582)[1] into law, one day after the U.S. House of Representatives passed the bill by a vote of 308 to 122 and a month after the Senate approved it, 68 to 30. The GENIUS Act establishes a framework for the regulation stablecoins, and it is the first major piece of federal legislation affecting digital assets in the United States.
Policy Tracker
Review our Policy Tracker to stay informed about new or potentially forthcoming legislation or regulation affecting blockchain technology and high-tech financial services sectors in the United States. Come back for important updates.
Importantly, we make no representation whatsoever that the DLx Law Policy Tracker is up to date, comprehensive, or accurate, and it should not be relied on as legal or regulatory advice. Read our full disclaimer.
Dec 15, 2025
HMT confirms 2027 start for proposed digital asset regulatory regime under the FCMA
United Kingdom (Regulatory)
On December 15, 2025, His Majesty’s Treasury (HMT) confirmed the U.K. will implement a comprehensive digital asset regulatory regime in 2027 and emphasized that bringing digital assets within the perimeter of the Financial Services and Markets Act 2000 (FSMA) remains a central policy objective. HMT officials indicated that the April 2025 draft statutory instrument amending the FSMA (Order 2001) has undergone only minor revision and would provide the primary legal mechanism for bringing specified digital asset activities within the FSMA framework.
Under the proposed regime, the Financial Conduct Authority (FCA) would develop and enforce rules governing digital asset trading, custody, issuance, and disclosure. The framework would operate alongside the U.K.’s parallel work on stablecoin regulation and existing supervisory arrangements involving the Bank of England. The HMT emphasized this legislation was “a crucial step in securing the U.K.’s position as a world leading financial centre in the digital age.”
Last Updated 12/15/2025.
History:
- Dec 15, 2025: His Majesty’s Treasury, through Chancellor of the Exchequer Rachel Reeves, confirms that the United Kingdom will implement a digital asset regulatory regime in 2027.
- Apr 29, 2025: His Majesty’s Treasury (HMT) publishes a draft statutory instrument and policy note (in Order 2001) proposing amendments to the Financial Services and Markets Act 2000 (FSMA) to bring specified digital asset activities within the Act’s regulatory perimeter. Draft SI; Policy Note.
Dec 11, 2025
White House launches new policy effort in bid to preempt any state laws or regulations on AI
United States (Regulatory)
On December 11, 2025, the President issued an executive order (the “EO”) launching a national artificial intelligence policy framework and directing federal agencies to challenge state laws that conflict with federal priorities. The EO tasks the Department of Justice to create an Artificial Intelligence Litigation Task Force and bring challenges in courts seeking to block state AI laws based on conflict preemption, obstacle preemption, or interstate commerce grounds. The EO also tasks the Secretary of Commerce to review existing state laws and identify provisions that conflict with the policy objectives set out in the EO. It also directs grant-making agencies to condition certain discretionary federal funds on state commitments not to enforce conflicting artificial intelligence statutes.
The EO additionally charges the Federal Communications Commission (FCC) to begin considering federal disclosure and reporting standards for AI models, and it requires the Federal Trade Commission (FTC) to ssue a policy statement applying Section 5 of the Federal Trade Commission Act to AI practices that implicate unfair or deceptive conduct. Under the EO, the President’s advisors must prepare legislative recommendations for a comprehensive federal framework that could preempt conflicting state laws while preserving state authority over child safety, permitting, and the procurement and use of AI systems. The EO expands on the Trump administration’s existing laissez-faire posture on AI policy and stands in stark tension with the Senate’s July action striking a 10-year moratorium on state AI laws in the 2025 budget reconciliation bill (formerly known as the “One Big Beautiful Bill”).
Last Updated 12/11/2025.
History:
- Dec 11, 2025: White House issues Executive Order 14179, launching a national artificial intelligence framework and directing federal agencies to challenge state laws that conflict with federal policy. Executive Order 14179.
- Jul 1, 2025: The Senate passes the Blackburn-Cantwell amendment stripping the state AI-regulation moratorium from H.R. 1. S.Amdt. 2814 to H.R. 1.
- May 22, 2025: The House of Representatives passes the “One Big Beautiful Bill,” a sweeping budget measure that includes a ten-year moratorium on states’ ability to regulate the AI sector. H.R. 1, § 43201.
- Jan 20, 2025: President Donald Trump signs an executive order titled “Initial Rescissions of Harmful Executive Orders and Actions,” which revokes, among other orders, Biden’s “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence” order, effectively invalidating and repealing previous NIST guidance. E.O. No. 14148, 90 Fed. Reg. 8237 (Jan. 20, 2025).
- Jul 26, 2024: NIST publishes its three sets of final AI guidance, effective immediately. NIST AI 600-1; NIST SP 800-218A; NIST AI 100-5.
- Apr 29, 2024: NIST releases three initial public draft guidance documents related to AI risk management, secure software development for generative AI, and global AI standards. NIST AI 600-1; NIST SP 800-218A; NIST AI 100-5.
- Oct 30, 2023: President Joe Biden signs an executive order on the safe and responsible development of AI technologies. E.O. No. 14110, 88 Fed. Reg. 5191 (Oct. 30, 2023).
Dec 8, 2025
CFPB signals in court filing that an interim final Rule 1033 covering retail bank API account access is imminent
United States (Regulatory)
On December 8 in a filing in the Bank Policy Institute lawsuit challenging Rule 1033, the Consumer Financial Protection Bureau (CFPB) informed the court it is preparing an interim final rule to replace the controversial 2024 framework. The CFPB indicated the interim rule will advance its accelerated reconsideration of previously proposed personal financial data rights rules. Earlier in the case, a judge with the Federal District Court for the District of Kentucky stayed the 2024 Rule’s compliance deadlines and issued an injunction preventing the CFPB from enforcing the Rule during the reconsideration process. The CFPB has said it will move quickly once it completes the record for the new rulemaking.
Rule 1033, originally authorized by Section 1033 of the Dodd-Frank Act, establishes consumer rights to access and share the account and payment information that banks and card issuers hold. The 2024 Rule required covered institutions to provide this information without charge to consumers or to any third parties that consumers designate. The CFPB reopened the rule to stakeholder feedback on August 22, 2025 and issued an advance notice of proposed rulemaking to request views on scope, data sharing architecture, and implementation timelines. The CFPB had sought new comments to build a fresh administrative record and to address the legal and technical issues that the Bank Policy Institute lawsuit and other industry participants raised about the Rule. The comment period closed on October 21.
The CFPB is pursuing this work while operating with reduced staff following layoffs and senior personnel departures, which has raised concerns about its capacity to manage complex technical regulations like this one. Consumer advocacy groups and fintech stakeholders argue that revising Rule 1033 can strengthen data portability and support more competitive financial services. Banking groups argue the 2024 Rule oversteps the CFPB’s statutory authority and would require banks to build costly data sharing systems without adequate safeguards or compensation. The CFPB intends to promulgate the interim final rule sometime in 2026.
Last updated 12/08/2025.
History:
- Dec 8, 2025: The CFPB informs the court in the Bank Policy Institute’s lawsuit that it is preparing an interim final rule to replace the controversial 2024 framework. Forcht Bank, NA v. CFPB, Doc. 92 (CFPB Status Report).
- Oct 21, 2025: The public comment period for the CFPB’s August 22 ANPR closes.
- Aug 22, 2025: The CFPB issues an advance notice of proposed rulemaking to reopen and revise Rule 1033, soliciting comments through October 21, 2025. 90 Fed. Reg. 40986.
- Jul 29, 2025: The CFPB announced its intent to revise Rule 1033 in its motion to stay proceedings in the Bank Policy Institute’s lawsuit challenging the Rule. Forcht Bank, NA v. CFPB, Doc. 80 (CFPB Motion to Stay).
- Nov 18, 2024: The CFPB publishes the final version of Rule 1033. 89 Fed. Reg. 90838.
- Oct 31, 2025: The CFPB publishes its Notice of Proposed Rulemaking for Rule 1033.88 FR 74796.
- Jul 21, 2010: President Barack Obama signs the Dodd–Frank Wall Street Reform and Consumer Protection Act, directing the CFPB to write rules giving consumers on‑demand access to their account data. Pub. L. No. 111‑203, 124 Stat. 1376 (2010).
Nov 13, 2025
MAS director announces plans for stablecoin legislation
Singapore (Regulatory)
On November 13, 2025, the Monetary Authority of Singapore (MAS) announced it had finalized the features of its stablecoin regulatory regime and will prepare draft legislation to implement that framework. MAS expects the final laws to take effect sometime in 2026 and has emphasized that the regime will prioritize “sound reserve backing and redemption reliability” for fiat referenced stablecoins and framed regulated stablecoins as core settlement assets in MAS’s tokenized finance system.
MAS’s announcement also describes how the government agency is extending its tokenization experiments, reporting that 3 major Singapore banks (DBS Bank Ltd., Oversea-Chinese Banking Corporation Limited, and United Overseas Bank Limited) recently completed the first live overnight interbank lending transactions using Singapore dollar wholesale central bank digital currency (CBDC) on the SGD Testnet, MAS’s shared ledger test network for wholesale CBDC and tokenized assets. MAS then plans to release a trial for tokenized treasury bills settled in wholesale CBDC, publish a regulatory guide for tokenized capital markets products, and expand cross border pilots with the Bank of England, the Bank of Thailand, and Deutsche Bundesbank focused on real time foreign exchange and digital asset settlement.
Last Updated 11/13/2025.
History:
- Nov 13, 2025: MAS announces it has finalized the features of its stablecoin regulatory regime, indicating it has begun to prepare draft legislation to implement that framework.
- Aug 15, 2023: MAS announces a framework to regulate fiat referenced stablecoins and outlines planned reserve, capital, redemption, and disclosure standards. Consultation Paper.
Court Tracker
Consider DLx Law a source for updates on recent legal outcomes and ongoing cases that are shaping the landscape of blockchain and the financial services industry. With our Court Tracker, you can closely monitor other legal developments that are noteworthy for many of our clients and the industry as a whole. Check back in from time to time to stay informed about some recent regulatory enforcement actions and notable court cases.
Importantly, we make no representation whatsoever that the Court Tracker is up to date, comprehensive, or accurate, and it should not be relied on as legal or regulatory advice. Read our full disclaimer.
Notable Decisions
SEC v. Terraform Labs PTE Ltd. & Do Hyeong Kwon
S.D.N.Y. (Fed. Trial Ct.)
Filed: Feb 16, 2023
Description: The SEC charged Terraform Labs PTE Ltd and Do Hyeong Kwon with a multibillion-dollar crypto asset securities fraud. The SEC alleged that from April 2018 to May 2022, Terraform and Kwon raised billions of dollars from investors by offering and selling digital asset securities, including an algorithmic stablecoin called Terra USD (UST) and other crypto asset securities, many in unregistered transactions. In its complaint, the SEC alleged the following digital assets are unregistered securities: UST, LUNA, MIR.
Judgment entered
(Jun 12, 2024 )
Summary: The defendants entered a settlement agreement with the SEC, and the judge entered the consent order on June 12, 2024, with civil penalties, including just under $4.5 million in total monetary remedies against Terraform Labs, to be allocated under the organization’s Chapter 11 plan in U.S. Bankruptcy Court.
SEC v. Beaxy Digital, Ltd., et al.
N.D. Ill. (Fed. Trial Ct.)
Filed: Dec 25, 2023
Description: The SEC charged Beaxy (a digital asset trading platform) and its executives and founders with (1) raising $8 million in an unregistered securities offering (BXY tokens), misappropriating $900,000 of it for personal use, and (2) failing to register as a national securities exchange, broker, and clearing agency when facilitating the purchase and sale of digital assets as securities. The SEC alleged in its complaint that BXY tokens are securities.
Judgment entered
(Feb 13, 2024 )
Summary: The court entered default judgment against the defendants after they failed to make an appearance or respond to the SEC’s complaint.
In re: Coinbase Inc.
3d Cir. (Fed. Appeals Ct.)
Filed: Apr 24, 2023
Description: In spring of 2023, Coinbase filed an appellate-level petition seeking a writ of mandamus to compel the SEC to act on Coinbase’s pending rulemaking petition to provide clarity for the crypto industry.
Judgment entered
(Dec 18, 2023 )
Summary: Considered to be in large part the result of Coinbase’s mandamus petition seeking to compel a decision, the SEC on December 15, 2023, finally issued a formal decision denying Coinbase’s petition to have the SEC engage in rulemaking to clarify its interpretation of how securities laws can be applicable to business activities involving cryptocurrencies. As a result, the judge denied Coinbase’s mandamus petition as moot. Although it is not the outcome Coinbase sought, it now has a judicially reviewable decision to move forward with.
Ongoing Cases
U.S. v. Iurii Gugnin
E.D.N.Y. (Fed. Trial Ct.)
Filed: Jun 9, 2025
On June 9, 2025, the Department of Justice (DOJ) unsealed a 22-count indictment against crypto executive Iurii Gugnin, charging him with laundering over $500 million through cryptocurrency exchanges and U.S. banks. Prosecutors allege that Gugnin primarily acted on behalf of sanctioned Russian financial institutions, using his company, Evita, to facilitate transactions for various sanctioned entities worldwide. The DOJ also charged Gugnin with wire fraud, conspiracy to defraud the United States, and operating an unlicensed money transmitter business. Although Evita held a money transmitter license in Florida, the DOJ asserts that Gugnin secured it through fraudulent representations. If convicted, Gugnin faces a potential life sentence. Prosecutors claim Gugnin used Evita to facilitate purchases for foreign clients, including U.S. electronics and components (including those subject to export controls) for Rosatom, Russia’s state-owned nuclear technology company. Gugnin allegedly knew authorities were investigating him; the DOJ states he searched the web for “how to know if there is an investigation against you” and “evita investments inc. criminal records search.”
Status: DOJ prosecutors unsealed the 22-count indictment against Iurii Gugnin on June 9, 2025, and Gugnin was immediately arrested and now awaits trial. Updated 06/11/2025.
SEC v. Consensys Software Inc.
E.D.N.Y. (Fed. Trial Ct.)
Filed: Jun 28, 2024
Description: The SEC charged Consensys Software Inc., the development company behind MetaMask, for allegedly conducting unregistered offers and sales of securities by facilitating investments by MetaMask users into certain cryptocurrency staking protocols, namely, Lido and Rocket Pool. According to the SEC’s complaint, Consensys failed to register as a broker and did not meet the legal requirements for offering staking services while it collected more than $250 million in fees. The SEC’s complaint comes shortly after Consensys sued the SEC in April following its receipt of a Wells notice from the agency, challenging its attempts to classify ETH tokens and related staking service protocols as being unregistered securities.
Status: In anticipation of forthcoming guidance from the SEC’s Crypto Task Force, the SEC and Consensys jointly agreed to dismiss the case with prejudice. The move signals a strategic retreat in the agency’s approach to crypto infrastructure. It marks a win for firms that provide foundational services such as wallets and developer tools, rather than issuing or promoting tokens, and suggests that future enforcement may be reshaped by evolving internal policy. Updated 03/27/2025
U.S. v. Roman Storm et. al.
S.D.N.Y (Fed. Trial Ct.)
Filed: Aug 21, 2023
The U.S. government filed criminal charges against Tornado Cash developer Roman Storm on August 21, 2023, alleging that he conspired to operate an unlicensed money-transmitting business, violated U.S. sanctions law, and engaged in money laundering in connection with his role in developing the Tornado Cash protocol. Storm faces up to 45 years in prison if convicted. The case is viewed as a major test of developer liability in decentralized finance and the legal treatment of smart contracts and dApps. Storm’s defense argues that Tornado Cash’s smart contracts are immutable and self-executing, and that Storm did not actively facilitate money laundering. Counsel maintains the protocol was designed to enhance privacy in the transparent crypto ecosystem and that Storm’s code contributions are protected speech under the First Amendment. Prosecutors responded that Tornado Cash was repeatedly used to launder illicit funds, including by the Lazarus Group, a North Korean state-backed hacking organization under U.S. sanctions.
Status: On August 6, 2025, a federal jury convicted Roman Storm of operating an unlicensed money transmission business, following four days of deliberation. The jury acquitted Storm on related counts of money laundering and sanctions evasion, which carried potential 20-year prison terms. Storm now faces a maximum sentence of five years. He remains free on bail and is expected to appeal the conviction. Updated 08/11/2025.
Alerts & Announcements
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