Sky Blog
The Securities and Exchange Commission (SEC) on March 17 issued an interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets. This is a major step in the Commission’s efforts to provide greater …
A fundamental misconception pervades American law’s engagement with blockchain technology. State legislatures, federal regulators, courts, and private market participants routinely treat the technical capabilities of blockchain systems as sources of legal rights and obligations, collapsing the distinction between what code …
In 2025, U.S. Department of Justice (“DOJ” or the “Department”) leaders announced significant recalibrations of the Department’s corporate enforcement priorities. For example, in a May 12, 2025 memorandum from then-Acting Assistant Attorney General of DOJ’s Criminal Division, Matthew R. Galeotti, …
As part of an effort to provide greater clarity on the application of the federal securities laws to crypto assets,[1] the Division of Corporation Finance, Division of Investment Management, and Division of Trading and Markets are providing their views…
Key Points:
The enactment of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act established the nation’s first federal prudential framework for “payment stablecoins,” mandating 1:1 reserve backing and explicitly prohibiting issuers from paying interest.[1] This legislative bargain was …
The environment has never been more favorable for existing banking organizations launching a digital asset business and those Fintech and other nonbank companies considering acquiring or chartering a full-service or limited-purpose bank in order to operate a digital asset business. …
On December 5, 2025, New York Governor Kathy Hochul signed A.3307-A/S.1840-A—the New York Emerging Technologies Amendments to the New York Uniform Commercial Code—into law (the “UCC Amendments”)[1]. The UCC Amendments will become effective in New York on June …
On November 12, 2025, SEC Chairman Paul Atkins delivered remarks (the November Remarks) revisiting his announcement of “ Project Crypto,” the Commission-wide initiative launched earlier this year to promote blockchain innovation in U.S. financial markets. Chairman Atkins laid …
The proposed Digital Asset Market Clarity Act would establish a comprehensive, top-down regulatory framework for digital assets that reflects a growing bipartisan push in Congress for clear oversight of the digital asset industry. On Nov. 9, 2025, the Senate Committee …
When I spoke recently about American leadership in the digital finance revolution, I described “Project Crypto” as our effort to match the energy of American innovators with a regulatory framework worthy of them. Today, I would like to outline the …
The rapid rise of technologies such as artificial intelligence (AI) and blockchain is placing significant pressure on the established framework of corporate law. This pressure raises fundamental questions about whether these innovations require minor regulatory updates or warrant a re-examination …
Sovereign wealth funds (SWFs) are now central to how nations stabilize fiscal balances, diversify assets, and project financial influence. Norway’s oil fund, Singapore’s Temasek, and the Gulf states’ investment vehicles all serve as stabilizers and strategic tools in global markets. …
In an important development for the asset management industry, the Staff of the SEC’s Division of Investment Management issued a no-action letter to Simpson Thacher in response to our request for confirmation that state-chartered trust companies—which are among the most …
For over a decade, regulators, market participants, and Congress have wrestled with the challenge of regulating crypto assets. This relatively nascent asset class, underpinned by novel technology, has been difficult to regulate under existing financial regulatory frameworks. While both the …
President Trump recently signed an executive order[1] (the Order) aimed at preventing the so-called practice of “debanking,” which refers to actions taken by banks and other financial services providers to restrict the ability of certain individuals, groups, or industries …
President Trump entered the White House in January 2025 promising to make the United States the “Crypto Capital of the World.” The federal agencies and Congress are responding with unprecedented speed to make that a reality.
In the depth of …
On July 30, 2025, the White House released a report titled “Strengthening American Leadership in Digital Financial Technology,” which outlines the Trump administration’s proposed policy roadmap on digital assets (Report). The Report was mandated by Executive Order 14178, issued on …
Executive Summary
On August 7, 2025, the Trump Administration released the heavily anticipated Executive Order, “Democratizing Access to Alternative Assets for 401(k) Investors” (the “Executive Order”), which represents a significant development and a positive step toward facilitating investment by defined …