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FDIC Seeks to Establish Pathway for Subsidiaries of Insured Banks to Issue Payment Stablecoins

The Federal Deposit Insurance Corporation (FDIC) has issued a Notice of Proposed Rulemaking (NPR) to establish procedures for an insured depository institution (state-chartered insured banks that are not members of the Federal Reserve System and state-chartered savings associations) to become approved to issue payment stablecoins through a subsidiary pursuant to the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). Comments on the proposal are due 60 days after...By: Stinson LLP

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UK FCA Consults on Recalibrating Client Categorisation and Rationalising Conflicts of Interest Rules

The UK Financial Conduct Authority published a package of consumer investments reforms on 8 December 2025 to empower retail investment and reinforce wholesale markets. At the heart of the proposals is the FCA’s ambition to rebalance risk in a way that supports growth, innovation and competitiveness....By: Morgan Lewis

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SFO Publishes Updated Annual Report on Whistleblowing Disclosures for 2024–25

On 28 November 2025, the Serious Fraud Office (SFO) published its annual report on whistleblowing disclosures and updated its guidance titled “Information for Whistleblowers”. While the guidance itself remains unchanged, the accompanying Report reflects a shift towards greater transparency compared to previous years. Last year’s publication focused primarily on headline numbers; this year, the SFO has provided more detail on how disclosures were handled....By: Hogan Lovells

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EU Fast-Tracks New Russia and Belarus Sanctions while Indefinitely Immobilizing Russian Sovereign Assets

While discussions surrounding the adoption of a more substantive 20th “package” of sanctions in response to Russia’s war in Ukraine continue, the European Union has moved forward with the imposition of additional restrictive measures targeting (i) Russia’s energy sector and shadow fleet enablers, and (ii) hybrid threats posed by Russia and Belarus....By: Mayer Brown

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2025 Has Been a Strong Year for IPOs. The 2026 Outlook is Even Stronger.

Moore & Van Allen (MVA) Head of International Capital Markets John I. Sanders and Corporate Associate Noah Edmondson co-authored the article, “2025 Has Been a Strong Year for IPOs. The 2026 Outlook is Even Stronger.”...By: Moore & Van Allen PLLC

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A Year of Change Across Financial Regulation – and What Comes Next, December 2025 - OCC Conditionally Approves Five Crypto-Focused National Trust Bank Charters

On December 12, 2025, the Office of the Comptroller of the Currency (“OCC”) granted the conditional approval of five national trust bank charter applications involving crypto-focused institutions. The approvals include two de novo charters, First National Digital Currency Bank and Ripple National Trust Bank, and the conversion of three state trust companies, BitGo Bank & Trust, Fidelity Digital Assets, and Paxos Trust Company, into uninsured national trust banks subject to OCC supervision....By: Cadwalader, Wickersham & Taft LLP

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Key Takeaways from FCA Consultation Paper 25/42 – A Prudential Regime for Cryptoasset Firms

On 16 December 2025, the Financial Conduct Authority (“FCA”) published Consultation Paper 25/42 on a prudential regime for cryptoasset firms (the “Consultation Paper”). This paper is one of three consultation papers released by the FCA as part of the UK's cryptoasset regulatory framework. This Consultation Paper follows an earlier Consultation Paper (“CP 25/15”), as part of the FCA's efforts to obtain industry views on key matters before publishing a more complete set of rules to consult on....By: Hogan Lovells

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Driving Digital Innovation: Sultan Almasoud on the Top Trends in Technology and Esports in Saudi Arabia

Dr. Sultan Almasoud, managing partner of Morgan Lewis’s Riyadh office, has been closely involved in the Kingdom of Saudi Arabia’s rapid evolution into a global hub for innovation. His insights on the questions below shed light on the trends reshaping technology and esports—and the opportunities they unlock for investors and operators entering the market....By: Morgan Lewis - Tech & Sourcing

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HL UK Pensions Law Digest 18 December 2025

A bite-sized summary of recent UK pension news - What’s happening in Parliament? A quick update on the progress of pensions-related Bills through Parliament; Department for Work and Pensions (DWP) launches consultation on the future of pensions trusteeship - The DWP has published a consultation paper on raising the standards of pensions trusteeship; Pensions Regulator (TPR) publishes its annual overview of the UK occupational defined benefit and hybrid scheme landscape....By: Hogan Lovells

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Update on New EU and UK Regimes for Third-Country Branches: Key Developments and Implications

Following our previous review of the evolving UK and EU approaches to the regulation of third-country bank branches and subsidiarization, the European Banking Authority (EBA) has now published a significant Consultation Paper on draft guidelines for the authorisation of third-country branches (the Guidelines) under the revised Capital Requirements Directive (CRD)....By: Skadden, Arps, Slate, Meagher & Flom LLP

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Art Basel Miami Beach: An Art Appraiser’s Perspective

One of the art world’s most important events in the United States has recently concluded in Miami Beach, Florida. Running December 3-7, 2025, Art Basel Miami Beach featured 283 galleries from 43 countries, attracting more than 80,000 attendees to South Florida, including Shook Senior Counsel Channah Norman, who co-chairs the firm’s Art Law Practice....By: Shook, Hardy & Bacon L.L.P.

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Bermuda digital assets - December 2025 update

Bermuda continues to retain its reputation as one of the leading jurisdictions for establishing digital asset products and services business. Benefitting from the world’s first fully comprehensive digital asset sector specific regulatory framework introduced in 2018, Bermuda has continued to attract the most legitimate and credible companies to its shores....By: Carey Olsen

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Hybrid financing in life sciences: Unlocking growth amid market challenges

Life sciences companies and investors continue to navigate a complex and challenging investment landscape – marked by high interest rates, a volatile regulatory environment, tight venture capital (VC) markets, and slowly rebounding initial public offering (IPO) activity....By: McDermott Will & Schulte

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The Hidden Pitfalls Of Letters Of Credit In Lease Negotiations

Most leases require a tenant to provide some form of security. In a residential context, this could be a cosigner or a cash security deposit. In commercial leasing, the lease security is usually in the form of either a cash security deposit or a standby letter of credit, or LC. Originally Published by Law360 - December 10, 2025....By: Allen Matkins

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AI Regulation in Financial Services: Turning Principles into Practice

As 2026 approaches, the UK financial services sector stands at a pivotal moment in its AI journey. What began as cautious pilots has matured into widespread deployment, prompting regulators to sharpen their focus on governance and risk....By: BCLP

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D.C. Circuit to Reconsider Injunction Barring CFPB Reductions in Force

The U.S. Court of Appeals for the District of Columbia Circuit granted a petition for rehearing en banc filed by the National Treasury Employees Union (NTEU) and agreed to reconsider a three-judge panel's decision lifting an injunction that sought to block the Trump Administration from pursuing extensive reductions in force (RIFs) at the CFPB....By: Holland & Knight LLP

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Eleventh Circuit Clears Path for Corporate Transparency Act Enforcement

The Corporate Transparency Act (“CTA”) has cleared a major legal hurdle. On December 16, 2025, the U.S. Court of Appeals for the Eleventh Circuit reversed a lower court decision that blocked enforcement of the CTA, holding that the Act is constitutional and enforceable. Nat’l Small Bus. United v. U.S. Dep’t of the Treasury, No. 24-10736 (11th Cir. Dec. 16, 2025)....By: Cole Schotz

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How the GENIUS Act Is Reshaping Stablecoin Regulation and Emerging Financial Disputes

The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act became law on July 17, 2025, marking the first comprehensive federal framework governing cryptocurrency in the United States. The law marks a defining moment in U.S. financial regulation, offering long-awaited clarity for stablecoins while creating new layers of accountability for those who issue, trade or rely on them....By: JAMS

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OCC Conditionally Approves Digital Asset Trust Bank Charters, Signaling Cautious Expansion of Federal Oversight

On December 12, the Office of the Comptroller of the Currency (OCC) announced conditional approval for five national trust bank charter applications from five major crypto companies. These conditional approvals mark a notable development in the federal supervision of crypto-native business models, underscoring the OCC’s continued caution in extending the national banking framework to firms engaged in digital asset custody and stablecoin-related activities....By: Sheppard Mullin Richter & Hampton LLP

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FinCEN Publishes First Set of Compliance Considerations in Parallel Civil and DOJ Enforcement Actions Against Crypto Company Paxful

For the first time, FinCEN’s press release announcing an enforcement action includes a section describing key “Compliance Considerations” arising from the case. This section mirrors an identically titled section that has for years appeared in the Office of Foreign Assets Control’s (OFAC) enforcement releases. With respect to the Paxful Order, key compliance considerations highlighted by FinCEN include......By: Akin Gump Strauss Hauer & Feld LLP

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