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Meet the New Disruptor in the Music Business: The Family Office
This is a new ongoing series about the business of music with a SPIN twist. There’s a new headliner in the music business, and it’s not on stage. It’s in the wings, in a tailored suit, with a checkbook bigger than the tour budget. Originally Published by Spin on - November 19, 2025....By: Bradley Arant Boult Cummings LLP
New York Updates UCC Law to Address Emerging Technologies in Commercial Transactions
On December 5, the governor of New York signed into law an act to amend the state’s UCC, aiming to address emerging technologies and update rules for commercial transactions involving virtual currencies. The legislation updates rules regarding control of electronic documents of title, specifying that a person has control if an electronic copy or record establishes the person as the recipient. The act also clarifies that purchasers have control of electronic copies of records evidencing chattel...By: Orrick, Herrington & Sutcliffe LLP
Minnesota Appeals Court Affirms Broad Application of Debt Collection Licensing Requirements
Recently, the Minnesota Court of Appeals affirmed a cease-and-desist order against a Utah-based company for allegedly conducting unlicensed debt collection in Minnesota. The court held Minnesota’s collection agency statutes apply broadly and require licensure for any entity that seeks to collect payment on behalf of others, even if the company is out-of-state collecting on Minnesota-based claims....By: Orrick, Herrington & Sutcliffe LLP
Final Texts for PSD3 and PSR Awaited as European Parliament and Council of EU Announce Provisional Political Agreement
On 27 November 2025, the European Parliament and the Council of the EU announced that they have reached a provisional political agreement on the texts of the proposed Directive on payment services and electronic money services (PSD3) and Regulation on payment services in the EU (PSR). Subject to completion of work on the technical elements of the payments package, payment service providers (PSPs) should expect to see the final texts in the coming weeks....By: Hogan Lovells
New York Enacts Law Adding Civil Penalties for Unlicensed Acts
On December 5, the governor of New York signed into law new provisions to amend the state’s financial services laws in connection with engaging in certain activities without a license. Specifically, the amendment adds § 408-a, “Civil penalty,” which defines prohibited unlicensed acts under the banking law and its regulations and sets forth specific penalties....By: Orrick, Herrington & Sutcliffe LLP
Israel Securities Authority Regulates Online Advertising: Mutual Funds, Likes, Influencers, and Everything in Between
The Israel Securities Authority published a new staff position recently on the regulation of advertising in digital space (including on social networks), focusing on advertising relating to mutual funds. The staff position seeks to bridge the gap between the law and the dynamic reality in today’s digital age, and focuses on regulating ongoing online activities and activities with external parties....By: Barnea Jaffa Lande & Co.
OCC Confirms National Banks May Engage in ‘Riskless Principal’ Digital Assets Transactions
On December 9, the OCC issued an interpretive letter, confirming that national banks may engage in “riskless principal” transactions involving digital assets as part of the business of banking. The OCC stated these transactions involve a bank acting as principal in a digital asset transaction with one customer while simultaneously entering into an offsetting transaction with another customer, serving as an intermediary and not holding digital assets in inventory....By: Orrick, Herrington & Sutcliffe LLP
OCC Head Speaks How Banks Could Embrace Digital Assets
On December 8, the OCC published a speech made by Comptroller of the Currency Jonathan V. Gould at an industry policy summit on his commitment to chartering new banks, aligning the importance of de novo chartering with novel technologies like digital assets. From 2011 through 2024, the OCC received fewer than four charter applications annually. However, in 2025, the agency reported receiving 14 de novo charter applications, including applications from entities involved in digital or fintech...By: Orrick, Herrington & Sutcliffe LLP
FinCEN Reports Ransomware Payments Exceeded $2.1B From 2022 to 2024
On December 4, FinCEN released a financial trend analysis showing that reported ransomware payments in BSA data totaled more than $2.1 billion between January 2022 and December 2024. FinCEN received 7,395 BSA reports related to 4,194 ransomware incidents during this period. The report found ransomware incidents and payments peaked in 2023, with 1,512 incidents and $1.1 billion in payments — a 77 percent increase in total payments from the previous year. By comparison, the report noted that, from...By: Orrick, Herrington & Sutcliffe LLP
FinCEN Fines Virtual Currency Platform $3.5M for BSA Violations Tied to Illicit Activity
On December 9, FinCEN announced a consent order levying a $3.5 million civil money penalty against a peer-to-peer virtual currency trading platform for willful BSA violations. FinCEN alleged the company facilitated more than $500 million in suspicious transactions involving illicit actors and high-risk jurisdictions, including individuals from Iran, North Korea, and Venezuela....By: Orrick, Herrington & Sutcliffe LLP
Democratic Senators Raise Concerns Over Potential Mortgage Market Disruption if CFPB is Shuttered
On December 3, Senators Elizabeth Warren (D-MA), Raphael Warnock (D-GA), Ruben Gallego (D-AZ), and Andy Kim (D-NJ) published a letter to CFPB Acting Director Russell Vought expressing concern that efforts to close the agency could disrupt the U.S. mortgage market and harm homebuyers. The letter cited the Bureau’s central role as the primary regulator of the consumer mortgage market and its responsibility for publishing average prime offer rates (APOR) tables and maintaining rules that underpin...By: Orrick, Herrington & Sutcliffe LLP
Court Approves Joint Motion to Reduce CFPB’s $5M Settlement With Student Loan Trusts and Servicer
On December 8, a judge in the U.S. District Court for the Middle District of Pennsylvania granted a joint motion filed by the CFPB and parties to a student loan enforcement action to modify previously proposed stipulated judgments involving a Pennsylvania-based student loan servicer and 15 student loan trusts, significantly reducing the scope and monetary relief of a settlement first proposed in May 2024 (covered by InfoBytes here). The original proposed orders would have required the student...By: Orrick, Herrington & Sutcliffe LLP
Court Grants Former Fed Officials’ Motion for Leave to File Amici Curiae Brief in Support of CFPB Union, CFPB Responds to Motion to Clarify
On December 5, former Fed officials moved for leave to file a brief as amici curiae in the U.S. District Court for the District of Columbia in support of the CFPB union’s motion to clarify the term “combined earnings” as recently addressed by the DOJ’s Office of Legal Counsel (OLC). The meaning of the term has been a central part of ongoing litigation between the union representing CFPB employees and the Trump administration concerning the administration’s plans for the agency, as the CFPB is...By: Orrick, Herrington & Sutcliffe LLP
Nonprofit Groups Challenge CFPB’s Refusal to Request Funding From the Fed
On December 5, a coalition of nonprofit organizations filed a complaint seeking declaratory and injunctive relief in the U.S. District Court for the Northern District of California against the CFPB and Acting Director Russell Vought. The plaintiffs alleged the CFPB’s refusal to request funds from the Fed, as contemplated by 12 U.S.C. § 5497, violates the APA. The complaint asserted the Dodd-Frank Act obliges the CFPB director to request the funds “reasonably necessary” to execute the agency’s...By: Orrick, Herrington & Sutcliffe LLP
Joint Status Report Indicates CFPB Plans to Issue ‘Interim’ Final Section 1033 Rule Amid Funding Concerns
On December 8, the parties in ongoing litigation over the CFPB’s Personal Financial Data Rights rule (covered by InfoBytes here) filed a joint status report in the U.S. District Court for the Eastern District of Kentucky. The report updated the court on recent developments, including the CFPB’s publication of an advanced notice of proposed rulemaking (ANPR) to implement Section 1033 of the Dodd-Frank Act (covered by InfoBytes here) and DOJ’s Office of Legal Counsel’s determination that the CFPB...By: Orrick, Herrington & Sutcliffe LLP
Innovation Law Insights - December 2025 # 2
Legal Break - Age verification in Italy: What adult content websites must do now - As part of our “Legal Break” video series, we discuss the impact of the Caivano Decree, which introduces a significant change: as of 12 November, pornographic websites have to adopt age-verification systems to prevent minors accessing them....By: DLA Piper
2025 FinAccelerations - US Digital Assets Publications
The Office of the Comptroller of the Currency (the "OCC") has held for the first time that national banks may hold crypto assets as principal on their balance sheet in order to pay reasonably expected amounts of "network fees" or "gas fees" on blockchain networks. On November 18, 2025, the OCC issued Interpretive Letter #1186 to confirm that national banks may permissibly hold, as principal, sufficient crypto assets to pay blockchain network fees, in anticipation of paying such fees....By: Jones Day
Speaking Sustainability - Legal & Regulatory Updates - November 2025
On November 18, the United States Court of Appeals for the Ninth Circuit granted a partial injunction blocking enforcement of California’s climate-related financial risk disclosure law (SB 261). Inaugural reports under SB 261 were intended to be published by reporting entities by January 1, 2026....By: Akin Gump Strauss Hauer & Feld LLP
What to Expect from the SEC’s Examination Focus in 2026
It’s that time again for investment advisers, broker-dealers, fund managers and other financial professionals to prepare for the U.S. Securities and Exchange Commission’s (SEC) continued focus on certain topics in examinations during 2026. On November 17, 2025, the SEC’s Division of Examinations Division released its 2026 Examination Priorities....By: Procopio, Cory, Hargreaves & Savitch LLP
UK Pension: What's new this week? December 2025 # 3
Welcome to your weekly update from the A&O Shearman Pensions team, covering all the latest legal and regulatory developments in the world of workplace pensions....By: A&O Shearman
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