Regulatory Intelligence

GLBA: Financial Privacy & Blockchain

Gramm-Leach-Bliley Act mandates safeguards for consumer financial data. Tokenized transactions and on-chain privacy controls (zero-knowledge, selective disclosure) align with GLBA's requirement to protect nonpublic personal information.

Sarbanes-Oxley: Immutable Audit Trails

SOX requires public companies to maintain accurate financial records and internal controls. Blockchain's immutable ledger and HSM-backed signatures provide tamper-proof audit trails that satisfy SOX Section 404. As enterprises tokenize assets and adopt on-chain treasury management, SOX compliance becomes a blockchain infrastructure requirement.

FinCEN Lays Foundation

FinCEN amended MSB definitions to include 'other value that substitutes for currency,' preparing the regulatory framework for virtual currency oversight.

Basel III: Capital & Crypto Exposure

Basel III capital and liquidity standards affect banks with crypto exposure and CBDC interoperability. On-chain settlement and tokenized assets require clear risk-weighting and disclosure alignment with Basel frameworks.

First Federal Crypto Guidance

FinCEN issued landmark guidance classifying crypto exchangers and administrators as Money Services Businesses, requiring AML compliance and BSA registration.

BitLicense Takes Effect

New York's BitLicense became operational, establishing the first comprehensive state-level cryptocurrency regulatory framework in the United States.

CFTC: Bitcoin is a Commodity

CFTC's first enforcement action officially declared Bitcoin and virtual currencies as commodities under the Commodity Exchange Act, establishing regulatory jurisdiction.

SEC DAO Report

SEC determined that DAO tokens were securities under the Howey Test, establishing that ICOs may be subject to federal securities laws and marking a pivotal regulatory moment.

CFTC v. McDonnell Court Decision

Federal court confirmed CFTC's authority over virtual currencies as commodities, providing first judicial approval of crypto regulatory framework under Commodity Exchange Act.

GDPR Enforcement Begins

EU General Data Protection Regulation took full effect, mandating data minimization, consent management, and right-to-erasure. Enterprise blockchain deployments must ensure private data channels, selective disclosure, and verifiable credentials to maintain GDPR alignment.

Wyoming SPDI Charter Created

Wyoming HB 74 established Special Purpose Depository Institution charter - first U.S. banking framework designed for digital assets with 1:1 reserve backing, enabling crypto custody and stablecoin issuance by state-chartered banks.

FinCEN Consolidates Rules

FinCEN consolidated nearly a decade of guidance (2011-2019) on virtual currencies, clarifying that certain decentralized applications are also MSBs under BSA jurisdiction.

FATF Travel Rule Introduced

FATF extended Travel Rule to crypto, requiring VASPs to collect and share transaction details over $1,000 for AML/CFT compliance across jurisdictions.

Wyoming Digital Asset Law

Wyoming SF 125 enacted comprehensive digital asset property law defining legal status, custody operations, and UCC treatment for digital assets - becoming first state to classify crypto as property with clear ownership rights.

CFTC: Ethereum is a Commodity

CFTC Chairman declared Ethereum a commodity, expanding regulatory clarity beyond Bitcoin and establishing framework for major crypto assets.

OFAC Sanctions: Real-Time On-Chain Screening

U.S. Treasury's Office of Foreign Assets Control requires all financial transactions to be screened against sanctioned entities. Smart contract integration with on-chain credentials enables automated, real-time sanctions checks without disrupting transaction flows — critical for any enterprise digital asset operation.

Kraken Financial - First SPDI Charter

Wyoming awarded first SPDI charter to Kraken, creating first state-chartered crypto bank in U.S. with federal banking powers, custody authority, and ability to issue bank notes backed by digital assets.

Avanti Bank - Second SPDI Charter

Wyoming chartered Avanti Bank as second SPDI, focused on institutional digital asset custody and tokenized dollar (Avit) issuance - demonstrating SPDI model's viability for diverse business models.

NCUA: Third-Party Digital Assets

NCUA clarified credit unions can partner with third-party providers offering digital asset services, enabling member access to crypto custody, trading, and wallet services through vetted vendors.

FINRA: Tokenized Securities & Broker-Dealer Compliance

FINRA guidance on digital asset securities and broker-dealer obligations. Critical for tokenized securities, ATSs, and custody. Enterprise blockchain infrastructure must support FINRA recordkeeping and supervisory control requirements.

NCUA: Distributed Ledger Technology

NCUA confirmed credit unions can deploy blockchain/DLT for permissible activities with appropriate risk management, opening door for payment systems, recordkeeping, and smart contract applications.

Wyoming Stable Token Commission

Wyoming Stable Token Act established commission to issue state-backed stablecoin (WYST) with 102% capitalization requirement backed by U.S. Treasuries - first state-issued stablecoin initiative.

Bitcoin ETF Approval

SEC approved 11 spot Bitcoin ETFs after rejecting 20+ applications since 2018, signaling institutional legitimization and Wall Street's entry into crypto markets.

EU MiCA Fully Implemented

Markets in Crypto-Assets regulation creates comprehensive international framework with unified licensing for Crypto-Asset Service Providers across all EU member states, enabling cross-border operations.

ASU 2023-08 Effective Date

GAAP fair value accounting standard transforms crypto asset reporting from cost-less-impairment to daily mark-to-market valuation, requiring separate balance sheet presentation and enhanced disclosures.

SEC Enhanced Disclosure Requirements

Public companies holding crypto must disclose technical specifications, consensus mechanisms, risk factors, revenue generation methods, and custody arrangements under Item 105 of Regulation S-K.

GENIUS & CLARITY Acts Signed

President signed the GENIUS Act into law, creating the first federal stablecoin regulatory framework including credit unions and Wyoming SPDIs as permitted issuers. CLARITY Act passed House establishing asset classification certainty.

SAB 122 & OCC Letter 1183

SEC rescinded SAB 121 enabling standard contingency accounting for crypto custody. OCC, Federal Reserve, and FDIC provided unified guidance allowing banks to offer institutional crypto custody and transaction services.

Wyoming Stable Token (WYST) Launch

Wyoming launches WYST as first state-issued stablecoin, fully backed by U.S. Treasuries with 102% capitalization. Exempt from federal GENIUS Act requirements as governmental entity, demonstrating state-level innovation model.

NCUA Succession Planning & EU DAC8

Credit unions must implement written succession plans for key positions. EU crypto exchanges begin detailed transaction reporting under DAC8 to tax authorities by January 31, 2027.

EU MiCAR Transition Complete

All transition periods end for Markets in Crypto-Assets Regulation, requiring full CASP compliance with capital requirements (€50k-€150k), governance standards, and AML controls.

GENIUS Act Implementation Deadlines

Federal regulators (Fed, OCC, FDIC, NCUA) must issue final stablecoin regulations. State regulators including Wyoming submit substantial similarity certifications to Treasury. California DFAL takes effect requiring state licenses.

GENIUS Act Takes Effect

Federal stablecoin framework becomes operational requiring permitted issuer licenses for banks, credit unions, and SPDIs. Mandates 1:1 reserve backing, monthly audited reports with CEO/CFO certification, and BSA/AML compliance. Issuers over $50B must publish annual audited financials.