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Carlin is a regulatory, compliance, and payments attorney with experience representing financial institutions, fintechs, lenders, debt collectors, payment processors, neobanks, virtual currency companies, and mortgage servicers.

On April 28, bipartisan lawmakers in the U.S. House of Representatives introduced legislation, allowing the Commodity Futures Trading Commission (CFTC) to oversee cryptocurrency spot markets. The legislation intends to create a framework to fill the regulatory gaps between the CFTC and Securities and Exchange Commission (SEC) digital asset marketplace and related regimes.

According to bill

On June 8, the New York State Department of Financial Services (NYDFS) issued new “Guidance on the Issuance of U.S. Dollar-Backed Stablecoins,” establishing a first-of-its-kind state standards for USD-backed stablecoins issued by entities subject to regulation by the NYDFS. Informal policies have been in place since 2018, but NYDFS Superintendent Adrienne A. Harris

On June 1, the California Department of Financial Protection and Innovation (DFPI) released an invitation for comment on the DFPI’s regulatory approach to crypto asset-related financial products and services, as well as the potential regulation of such products and services under the California Consumer Financial Protection Law (CCFPL).

On May 4, Governor Gavin Newsom issued

The New York State Department of Financial Services (NYDFS) recently issued guidance on the use of blockchain analytics for all virtual currency businesses that either have a BitLicense or are chartered as limited purpose trust companies under the New York Banking Law (VC Entities), emphasizing “the importance of blockchain analytics to effective policies, processes, and

On May 4, following in the footsteps of President Biden’s recent executive order (Federal EO), California Governor Gavin Newsom issued his own blockchain-related executive order (CA EO), making California the first among the states to endorse a proactive, harmonized approach to regulate blockchain technology. The CA EO assesses how existing state and public institutions may

On April 28, the Joint Chiefs of Global Tax Enforcement (the J5), a global joint operational taxation group consisting of Australia, Canada, Netherlands, United Kingdom, and the United States, issued an intelligence bulletin (Bulletin), enumerating its perceived dangers of non-fungible tokens (NFTs).

NFTs, ERC-20, and Fungibility

Cryptocurrencies and NFTs are similar in the sense that

On May 4, the Connecticut Banking Commissioner issued a temporary order to cease and desist and order to make restitution against lead generator SoLo Funds Inc. (SoLo) for allegedly engaging in unfair, deceptive, and abusive acts and practices (UDAAPs) in violation of the Consumer Financial Protection Act of 2010, as well as for operating in

On May 19, the Department of Commerce’s International Trade Administration issued a Request for Comment (RFC), seeking public input on the development of a framework for driving economic competitiveness and leadership in, and leveraging of, digital asset technologies as part of reinforcing U.S. leadership in the global financial system. This RFC is in response to

On March 9, Wyoming amended the Decentralized Autonomous Organizations (DAO) Supplement (Supplement), which permits decentralized autonomous organizations (DAOs) to incorporate and obtain legal status as limited liability companies under Wyoming’s Limited Liability Company Act. The most distinctive modification of the Supplement concerns the minimum threshold of a DAO’s overall membership that must participate in proposal

On March 31, Idaho Governor Brad Little signed HB 583, the Digital Asset Act. The bill amends Title 28 of the Idaho Code, which governs commercial transactions generally, to include a new chapter dedicated to regulation of digital assets. The bill goes into effect on July 1. Idaho’s bill is multifaceted:

(1) It distinguishes