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

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 includes games like slots, blackjack, and roulette when played for real money. The warning goes on to state: “Of particular concern are so-called “sweepstakes” or “social casino” sites that may offer real-money payouts, dual-currency systems, or prizes such as gift cards. These platforms are not…
Continue Reading Maine Gambling Control Unit Issues Warning on Illegal Online Gaming Including Certain Sweepstakes Models

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 New York State Gaming Commission, allegedly identified 26 online platforms offering players slots, table games, and sports betting using virtual coins that could be exchanged for cash and prizes. On June 6, the NY AG announced that it has stopped online sweepstakes casinos operating in…
Continue Reading NY AG Seeks to Shut Down Sweepstakes Casinos in NY

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 related to governance, custody, disclosure, and alignment with existing financial and national security laws.
Continue Reading Federal Crypto Ownership: Compliance Implications of the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile

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 the U.S. In the letter, CSBS expresses support for the development of a national framework for payment stablecoin issuers (PSIs), while warning that the current draft would unnecessarily preempt state regulatory authority and introduce risks to consumer protection and financial stability.
Continue Reading CSBS Flags Key Risks in Draft Stablecoin Legislation

Individually, AI and blockchain are among the hottest, most transformative technologies. Collectively, they are incredibly synergistic – hence the 1+1=3 concept in the title. We are seeing more examples of how the two will interact. Over time, the level of interaction will be extensive. Many projects are being developed that bring the power of AI to blockchain applications and vice versa. One of these projects that has garnered significant attention is the Virtuals Protocol. The project launched in October 2024 via integration with Base, an Ethereum layer-2 network. Just recently, the project announced that it is expanding to Solana. …
Continue Reading AI and Blockchain – 1+1 =3

The U.S. Securities and Exchange Commission (SEC) has launched a ‘Crypto Task Force’ page on its website, outlining the agency’s crypto regulatory agenda under the agency’s new leadership. This initiative follows the exit of former SEC Chair Gary Gensler under President Trump’s administration and signals a move away from the SEC’s previous enforcement-driven stance on cryptocurrency.
Continue Reading SEC Launches Crypto Task Force Website to Bring Clarity to Crypto Regulation

Until fall 2023, there were few SEC enforcements or litigations involving securities issues with non-fungible tokens (“NFTs”). This has changed dramatically. In rapid succession last fall, the SEC undertook two enforcements against NFT projects for alleged securities law violations. Yet, the SEC has declined to provide regulatory guidance or rules regarding the treatment of NFTs as securities. Instead, the agency has chosen to engage in selective enforcement against NFT projects. This year, the SEC has ramped up its enforcement efforts against digital asset marketplaces for selling NFTs (and other digital assets) the agency alleges are securities. In each of these…
Continue Reading NFTs and Securities Law Issues Are on the Rise – SEC Analysis Relies on Resale Royalties

This year, the SEC has ramped up its enforcement efforts against digital asset marketplaces for selling non-fungible tokens (“NFTs”) (and other digital assets) the agency alleges are securities. In response, some potential targets for SEC enforcement have proactively sued the SEC, challenging its jurisdiction to regulate digital assets and/or seeking a declaration that the digital assets are not securities. Escalating tensions further, several private plaintiffs have also filed civil lawsuits against NFT issuers and/or marketplaces. The SEC continues to decline to issue regulatory guidance or engage in rulemaking on whether NFTs qualify as securities, instead focusing on selective enforcement actions…
Continue Reading NFT Legal Issues

The U.S. Securities and Exchange Commission (SEC) has taken a significant step in its regulatory scrutiny of blockchain gaming projects by issuing a Wells notice to CyberKongz, a prominent NFT gaming platform. This development underscores growing tensions between blockchain innovators and federal regulators over the intersection of NFTs, utility tokens, and securities laws. See here for our discussion on some previous SEC NFT enforcements.
Continue Reading SEC Hits Blockchain Gaming Project with Wells Notice

Yet another “celebrity” token memecoin project seeking to leverage a “cultural movement” has become the subject of a lawsuit alleging that the tokens were unregistered securities. A group of plaintiffs recently sued over the promotion and sale of the Hawk Tuah cryptocurrency memecoin, known as the “$HAWK” token.
Continue Reading Hawk Thua – Sue that Thing! When Will Celebrities Learn the Risks of Launching Crypto Tokens?

Introduced in response to certain digital media sellers (e.g., game publishers) revoking consumer access to purchases with little to no recourse, AB 2426 forces sellers of “digital goods,” such as movies, apps, games, books and music to clarify what a consumer is actually receiving in connection with their “purchase.” Often companies refer to the “purchase” or “sale” of digital goods, yet the associated terms of service make clear that the buyer only receives a revocable license to such goods. In some cases, if a buyer violates the terms of service, the license is revoked, and the user is denied further…
Continue Reading New California Law Targets Sellers of Digital Goods – Applicability to NFTs is Uncertain

The United States Patent and Trademark Office (“USPTO”) and the United States Copyright Office (“USCO”) delivered a report to Congress entitled Non-Fungible Tokens and Intellectual Property on March 12, 2024 (“Report”). While the Report is comprehensive, it does not recommend any new action to address IP issues with NFTs.
Continue Reading The USPTO and USCO Delivered a Report to Congress on IP Issues with NFTs – Maintains Existing IP Regime