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A seasoned regulatory and compliance attorney, Carlin brings extensive experience representing financial institutions, fintechs, lenders, payment processors, neobanks, virtual currency companies, and mortgage servicers.

On April 6, Senator Pat Toomey (R-PA) released a draft of his proposed stablecoin legislation titled, Stablecoin Transparency of Reserves and Uniform Safe Transactions Act, or the Stablecoin TRUST Act. Toomey, the ranking member of the Senate Banking Committee, has been a vocal proponent of blockchain innovation, and his recent bill calls for a deft

On March 31, a New York federal court dismissed a proposed securities class-action lawsuit filed against Binance, the world’s largest cryptocurrency exchange. The lawsuit, one of a host of similar actions brought against cryptocurrency exchanges in 2020, was filed by token buyers who purchased cryptocurrency on Binance’s platform.

The plaintiffs asserted that Binance had violated

Several recent releases of draft legislation, reports, and speeches highlight the federal government’s efforts in the first quarter of 2022 to address the rapidly developing digital asset marketplace and its regulatory landscape.

Congressional Legislative Activity

On February 15, Representative Warren Davidson (R-OH) introduced the “Keep Your Coins Act,” which is intended “[t]o prohibit

The fiscal year 2022-2023 budget for New York, which takes effect in two months, includes requiring the New York Department of Financial Services (NYDFS) to charge a new “assessment” to all virtual currency businesses licensed in New York in order to “defray operating expenses.”

The legislation, signed by New York Governor Kathy Hochul on

On April 11, Virginia enacted a new law (HB 263), which goes into effect on July 1, 2022, permitting “banks” to provide customers with “virtual currency custody services so long as the bank has adequate protocols in place to effectively manage risks and comply with applicable laws.” The law, in a first for

On April 7, in front of American University’s Kogod School of Business Center for Innovation, Secretary of the Treasury Janet Yellen addressed the Biden administration’s forthcoming legislative approach to digital assets, as we discussed here, as well as the digitization of the American economy, which Yellen assessed through the lens of five lessons she

On March 28, Representative Stephen Lynch (D-MA), along with co-sponsors Jesús G. García (D-IL), Rashida Tlaib (D-MI), Ayanna Pressley (D-MA), and Alma Adams (D-NC), introduced H.R. 7231, the Electronic Currency and Secure Hardware Act (ECASH Act), which would direct the secretary of the U.S. Department of the Treasury (not the Federal Reserve) to develop

On March 17, Senators Elizabeth Warren (D-MA), Jack Reed (D-RI), Mark Warner (D-VA), and Jon Tester (D-MT) introduced the Digital Asset Sanctions Compliance Enhancement Act (Act) in an attempt to ensure blacklisted Russian individuals and businesses do not use cryptocurrency to evade economic sanctions.

“In order for the sanctions levied by the United States and

On March 17, the Senate Committee on Banking, Housing and Urban Affairs conducted a hearing titled, “Understanding the Role of Digital Assets in Illicit Finance,” which focused extensively on whether and how Russia could use digital assets to avoid sanctions, as well as how Ukraine is using cryptocurrency to support their fight against Russia.

In

On March 8, the U.S. Federal Reserve Banks launched the FedNow Service Provider Showcase (Showcase) to show financial institutions and users the various services to assist them in implementing the FedNow Service (Service).

The FedNow Service is an instant payment service to provide all depository institutions in the United States with access to instant payment