We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging 2023. Courts across the country issued rulings that will have immediate and lasting impacts on the industry. Our team of more than 140 professionals has prepared this concise, yet thorough analysis of the most important issues and trends throughout our industry. We not only examined what happened in 2023, but also what to expect — and how to prepare — for the months ahead.

Cryptocurrency, with its anonymity and decentralization, has revolutionized financial transactions. However, it has also opened doors for illicit activities, such as terrorist financing. Below we explore the role of cryptocurrency in terrorist financing, focusing on Hamas, a U.S.-designated terrorist organization.

On November 20, 2023, the California Department of Financial Protection and Innovation (DFPI) issued an invitation for comments on proposed application-related rulemaking under the Digital Financial Assets Law (DFAL). This move comes after Governor Gavin Newsom signed Assembly Bill 39 and Senate Bill 401, which together create the DFAL. The DFAL and Senate Bill 401, signed into law by Governor Gavin Newsom on October 13, 2023, are set to regulate virtual currency activities within California, effective July 1, 2025.