As readers may recall, California previously attempted to enact a “Digital Financial Assets Law” with the introduction of AB 2269 in February 2022. In relevant part, AB 2269 proposed (1) a stringent licensing requirement for entities engaging in or holding themselves out as being able to engage in “digital financial business activity” with or on behalf of California residents and (2) substantial ongoing reporting and operational obligations, both of which California modeled after New York’s “BitLicense” requirements for virtual currency businesses.… Continue Reading

The Federal Reserve Board, FDIC, and OCC (collectively, the “Agencies”) issued on November 23 a short Joint Statement on Crypto-Asset Policy Sprint Initiative and Next Steps (“Joint Statement”), which announced – without further concrete detail – that they had assembled a “crypto asset roadmap” in order to provide greater clarity in 2022 to banks on the permissibility of certain crypto-asset activities. … Continue Reading