After years of uncertainty and regulation by enforcement, the U.S. may finally be moving toward a more comprehensive framework for the regulation of digital assets. On June 4, 2025, the House Committee on Financial Services held a hearing on American Innovation and the Future of Digital Assets: From Blueprint to a Functional Framework. The hearing followed Committee Chairman French Hill’s introduction of H.R. 3633 — the CLARITY Act of 2025 (the Act) — on May 30, 2025. The Committee is expected to continue its markup of the Act at its June 10, 2025, Full Committee Markup hearing.

We are pleased to share with you our latest publication, “Navigating Change: First 100 Days under the Trump Administration,” authored by our Digital Assets + Blockchain team. This retrospective examines the pivotal developments in the digital assets industry during the initial phase of the Trump administration.

The U.S. Senate’s proposal to regulate stablecoins, known as the GENIUS Act, has successfully cleared a significant procedural hurdle, moving closer to a full floor debate. On May 19, lawmakers voted to invoke cloture on the bill, marking a pivotal moment in its legislative journey. This vote followed an earlier setback on May 8, when Democrats withdrew their support to engage in further negotiations.

On April 9, the House of Representatives passed two Congressional Review Act (CRA) joint resolutions aimed at nullifying certain Consumer Financial Protection Bureau (CFPB) rules finalized in the final days of the Biden-Harris Administration. These resolutions, S.J. Res. 18 and S.J. Res. 28, target rules related to limiting the overdraft fees that may be charged by large financial institutions, and extending supervisory authority over certain providers of digital payments services, respectively. The CRA resolutions are now before President Trump for signature.

The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and U.S. territories, has raised significant concerns regarding the current draft of the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act.

In a stated effort to provide greater clarity on the application of federal securities laws to “crypto assets,” the Securities and Exchange Commission’s (SEC) Division of Corporation Finance has released its views on “meme coins.” In sum, while the offer and sale of meme coins may not be subject to federal securities laws, fraudulent conduct related to meme coins could still be subject to enforcement actions.

On January 8, Senate Bill No. 1252 (SB 1252) was introduced to the Virginia General Assembly, aiming to amend and reenact sections of the Code of Virginia related to the application of usury rates. Just two weeks ago, the bill was passed by both the House and Senate. Opponents of the bill contend that the language and effect is very unclear, but that broad language and stringent provisions could stifle innovation and ultimately harm consumers by limiting their access to credit.

After two and a half years, Coinbase, Inc. (Coinbase) and other crypto market participants may finally get an answer for why the Securities and Exchange Commission (SEC) has declined to promulgate rules clarifying how and when federal securities laws apply to digital assets like cryptocurrencies.

Last week, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released final regulations that significantly impact the reporting requirements for brokers involved in digital asset transactions. The stated aim of the new rules, which are part of the Biden-Harris Administration’s implementation of the bipartisan Infrastructure Investment and Jobs Act, is to streamline tax reporting and ensure compliance within the decentralized finance (DeFi) sector. The regulations will become effective 60 days after their publication in the Federal Register.

On December 3, the Office of the Comptroller of the Currency (OCC) issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook, also known as the UDAAP booklet. The UDAAP booklet was last updated in June 2020.