The Securities and Exchange Commission (“SEC”) has issued a no-action letter to the Depository Trust Company (“DTC”) in connection with the registered clearing agency’s pilot blockchain-based securities tokenization program. A no-action letter is a document issued by the SEC in response to a request from an individual or entity seeking confirmation that their planned activities
Law of the Ledger
Legal Issues with Blockchain and Cryptocurrency
Digital Asset Exchange Receives CFTC Approval for US Prediction Markets, Signaling an Opportunistic Outlook
On December 10, 2025, Gemini Space Station, Inc. (NASDAQ:GEMI) announced that the Commodity Futures Trading Commission (“CFTC”) approved the registration of its subsidiary—Gemini Titan, LLC—as a Designated Contract Market (“DCM”), making it the first crypto-native exchange to obtain the necessary regulatory license to operate a prediction market for U.S. retail investors.…
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…
Second Circuit Vacates Fraud Conviction in First Crypto “Insider Trading” Case
In United States v. Chastain, No. 23-7038, 2025 WL 2165839 (2d Cir. July 31, 2025), the United States Court of Appeals for the Second Circuit vacated wire fraud and money laundering convictions in what the government described as its first crypto insider trading case. The case involves a former employee of OpenSea, an online…
Louisiana Governor Vetoes Legislation That Would Have Banned Social Casino Sweepstakes Games
Louisiana Gov. Jeff Landry (R) vetoed legislation that would have banned websites from conducting sweepstakes games that some say violate online gambling laws. …
Maine Gambling Control Unit Issues Warning on Illegal Online Gaming Including Certain Sweepstakes Models
Maine’s Gambling Control Unit (GCU) has issued a formal warning regarding the proliferation of illegal interactive gaming (“iGaming”) platforms operating within the state. The warning emphasized that while certain forms of online gambling—such as advance deposit wagering, fantasy contests, and sports betting—are legally permitted and regulated in Maine, online casino-style games remain strictly prohibited. This…
NY AG Seeks to Shut Down Sweepstakes Casinos in NY
We have previously posted on some of the recent legal issues with social casino sweepstakes. See Social Casino Sweepstakes Model is Under Fire – What Game Companies, Payment Processors and App Stores Need to Know. Various states have taken action to shut down these apps in their states. The NY AG, working with the…
Oregon Suit Muddies Crypto Regulatory Landscape
On April 18, 2025, the State of Oregon brought a civil enforcement action against Coinbase Global, Inc. (“Coinbase”) for the alleged sale of unregistered securities. In a press release, Oregon Attorney General Dan Rayfield openly acknowledged the action was in response to the United States Securities and Exchange Commission (“SEC”) dropping its own case…
Federal Crypto Ownership: Compliance Implications of the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile
Following President Trump’s March 6 Executive Order establishing a Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, federal agencies and market participants may begin to grapple with the operational and compliance implications of the federal government’s proposed foray into crypto ownership and stewardship. While many of the program’s details remain under development, the initiative raises questions…
CSBS Flags Key Risks in Draft Stablecoin Legislation
On April 1, the Conference of State Bank Supervisors (CSBS) submitted a letter to the House Financial Services Committee expressing concerns with an introduced draft of H.R. 2392—the Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025 (the “Act”)—which purports to establish a comprehensive regulatory framework for payment stablecoins in…