Overview

Chapman is at the vanguard of the emerging cryptocurrency, digital asset, and blockchain industry. Our attorneys have an unparalleled command of the unique and complex issues surrounding investments and other transactions in this emerging asset class.

Chapman's century of experience as a law firm focused on finance uniquely positions our firm to provide clients with comprehensive advice and deep insight into the developing ecosystem of cryptocurrency, digital assets, and blockchain technology. We understand the evolving needs of the participants in this space and combine creative legal acumen with business and market insight. As this space has matured, so have the diversity, breadth, and depth of our representation.

Chapman attorneys advise clients across legal products, including regulatory, corporate, investment management, tax, and litigation matters, and across borders on multi-jurisdictional mandates. We also maintain close relationships with leading trade organizations, such as the Chamber of Digital Commerce, that represent the industry before regulatory bodies and local and federal governmental bodies, including the US Congress and Securities and Exchange Commission.

Fund Formation and Investing

  • Formation and structuring of ETFs and other 1940 Act-registered investment fund structures, including preparing registration statements and facilitating SEC review process

  • Organization of private investment funds, including hedge funds and venture funds

  • Preparation of private fund documents such as private placement memorandums, limited partnership agreements, trust agreements, escrow agreements, subscription booklets, and investment management agreements

  • Advising on 19b-4 exchange listing applications for publicly traded digital asset investment funds

  • Negotiating side letters with private fund investors and arrangements with administrators and other service providers

  • Negotiating cryptocurrency custody agreements and derivatives trading documentation
  • Advising institutional investors on due diligence considerations associated with investments in private funds investing in digital assets
  • Guidance through evolving regulatory and enforcement landscape, including proceedings and investigations involving federal and state regulatory and law enforcement authorities (Department of Justice, Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), and various self regulatory organizations, including FINRA, NFA, and national securities exchanges)
  • Risk management and compliance guidance regarding custody, AML, MNPI, registration, and other digital asset enforcement priorities, including developing bespoke compliance manuals, policies, and procedures

SEC, CFTC, and Other Regulations

  • Counseling on SEC, CFTC, and other regulations applicable to asset managers, issuers of virtual currencies and tokens, foundations, DAOs, and other entities operating in the crypto and blockchain space
  • Analysis of whether coins, tokens and other digital assets may be classified as securities or commodities, and the implications of any applicable regulatory frameworks
  • Advising on issues related to both centrally cleared and over-the-counter cryptocurrency derivatives
  • Considerations related to the formation of DAOs, initial coin offerings and other token disbursement programs

Tax Planning and Structuring

  • Evaluating the treatment of cryptocurrencies and derivatives on cryptocurrencies under rules applicable to repurchase and lending transactions, straddles, wash sales, constructive sales, mandatory and elective mark- to-market recognition of gains and losses
  • Evaluating tax consequences of cryptocurrency investments to different taxpayers in light of IRS guidance that cryptocurrencies are "property" and applicable tax treatment of air drops, staking, lending, other DeFi activities, including grantor trust and publicly traded partnership issues
  • Determining whether a fund is engaged in a US-trade or business and evaluating the application of safe harbor rules to various cryptocurrencies

Corporate and M&A Practice

  • Advising clients on public market mergers and acquisitions with and of crypto and blockchain companies
  • Guidance on infrastructure partnership and commercial arrangements with organizations that mint and issue digital assets
  • Assistance with entity formation, financings, and joint ventures for companies creating and developing digital assets
  • Advising on the integration of digital assets into advertising, marketing, and other consumer-facing activities and related legal considerations


Transaction Highlights

  • Representing the first to market spot litecoin and hedera ETFs
  • Representing the first to market solana staking ETF
  • Representing three of the first to market spot bitcoin ETFs
  • Representing the first to market blockchain ETF
  • Representing the second to market bitcoin futures ETF
  • Advise 1933 Act exchange-traded products on new and novel structures to advance digital asset strategies
  • Represented the sponsors of privately offered single- and multi-digital asset trusts that offer exposure to various cryptocurrencies, including Bitcoin (BTC), Ethereum (ETH), Polkadot (DOT), Avalanche (AVA), TRON (TRX), Algorand (ALGO), and HBAR, among others, as well as those pursuing a "staking" strategy
  • Advise privately offered trusts holding cryptocurrencies and other digital assets seeking to "uplist" their shares to OTCQX
  • Advise registered investment advisers offering private funds that engage in stablecoin lending to large cryptocurrency exchanges
  • Co-counsel to an institutional cryptocurrency wallet and custody platform in the sale of its institutional bitcoin custody business
  • Represented a financial services firm that serves as a third-party key agent for digital asset/crypto-collateralized loans, including bitcoin- and ether-backed loans, originated by a decentralized platform operated by a financial technology company
  • Represented a cryptocurrency firm in establishing a lending program based upon and backed by cryptocurrency accounts
  • Represented digital asset custodians on regulatory and contract matters
  • Represented a member of a stablecoin consortium project on regulatory and contractual matters
  • Represented sponsors and advisers of registered and private investment vehicles on formation, securities law, and commodities issues, as well as ongoing compliance and best practices
  • Represented digital asset lending platforms on regulatory matters
  • Represented participants on a blockchain-based loan purchase platform
  • Advised a servicing agent on regulatory and contract issues relating to participating in a digital asset lending platform
  • Advised a data platform on regulatory and operational issues

Concentrations

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Cryptocurrency, Digital Assets, and Blockchain Updates

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News and Events

August 18, 2026

On-Chain Spotlight

Read our synopsis of key regulatory, market, and litigation developments shaping the blockchain and digital assets industry:

Regulatory Developments

  • August 14: The OCC has granted “preliminary conditional approval” to World Liberty Trust Company for a federal trust bank charter, enabling it to issue and custody the USD1 stablecoin for institutional clients nationwide. Final approval is contingent on meeting additional requirements – read the decision here.

  • August 14: The SEC postponed its meeting to propose “Regulation Crypto,” the agency’s first major rulemaking initiative for digital assets. The postponement also delays the SEC’s planned “innovation exemption” for tokenized securities, as concerns over legal authority, market impact, and regulatory process continue to stall regulatory clarity for blockchain-based securities – read the scheduling page here.

  • August 12: SEC staff issued a no-action letter permitting Franklin Templeton funds to hold shares of the Franklin OnChain US Government Money Fund through a blockchain-enabled custody and recordkeeping setup that does not fit traditional “physical custody” requirements. The position is conditioned on implementing robust control, oversight, and reconciliation measures – read the letter here.

  • August 12: The Bank of England has advanced its Digital Pound Lab into Phase 2, testing whether public stablecoins and central bank digital currency can operate together in a single payment flow for trade finance – read more on this page.

  • August 10: The FDIC and OCC announced continued efforts to encourage new bank formation, with the FDIC implementing a two-phase review process designed to provide contingent authorization for deposit insurance applications within 120 days and the OCC noting it has received 40 de novo applications in the last 18 months after receiving only 48 in the prior 14 years – read the related press release from the FDIC here and read the OCC release here.

  • August 10: Senate Majority Leader John Thune set a Sept. 15 cloture vote that will effectively determine whether the CLARITY Act can advance for further Senate review – read the Senate Schedule here.

  • August 7: The CFTC warned regulated platforms listing event contracts that displaying prices in “American” sportsbook-style odds could mislead consumers, and it asked regulated entities to review pricing/marketing practices – read the press releases here.

  • August 4: US regulators denied Dutch fintech Bunq’s bid for a US banking charter, with the OCC citing insufficient detail on its US market strategy, funding clarity, governance, and credit-risk assumptions, and management experience with US banking rules – read the corporate decision here.

Market Developments

  • August 13: Chime Financial is exploring the integration of stablecoin wallet services into its consumer banking app, allowing users to send and receive digital assets within its platform. The move follows Chime’s participation in the Open USD stablecoin initiative – read more in this article.
  • August 12: Crypto.com has launched tokenized derivatives tracking 1,500 US equities and ETFs for eligible users in the European Economic Area, offering synthetic exposure to stocks like Apple, Nvidia, and Tesla starting at $1 with around-the-clock trading through its MiFID-licensed subsidiary – read the press release here.
  • August 11: CeDeFi platform Grvt plans to partner with Ondo Finance to build and hold up to a $100 million balance-sheet position in Ondo’s yield-bearing USDY token over the next year and route its roughly 3.5% Treasury-linked yield into Grvt Earn users’ base rate without requiring users to hold USDY directly – read this article to learn more.
  • August 11: Coinbase has launched a suite of derivatives products, including perpetuals, dated futures, and crypto options across more than 170 contracts, for eligible professional investors in the UK, leveraging its recently secured MiFID license as part of its broader "Everything Exchange" strategy – read more in this article.
  • August 11: MoneyGram has expanded its Ramps cash-to-crypto infrastructure to the Solana blockchain, expanding its fiat on- and off-ramp infrastructure and enabling wallets, exchanges, and developers to integrate compliant cash-to-crypto and crypto-to-cash flows. Rift is the first Solana wallet to integrate the service, providing users access to MoneyGram’s global cash network (offering cash deposits in more than 25 countries and cash withdrawals in more than 170 countries and territories). – read this press release to learn more.
  • August 6: Wintermute USA LLC has registered as a broker-dealer with the SEC and FINRA, formally expanding its operations into US regulated markets. The registration allows Wintermute USA to provide proprietary liquidity in equities and options, act as an authorized participant for ETPs, and self-clear digital asset securities transactions for its own account – read the press release here.
  • August 6: Digital banking software firm Alkami Technology has reportedly initiated a sale process following interest from potential buyers and pressure from activist investor Jana Partners, which holds a 5.1% stake and has urged the company to explore strategic or private equity acquisition options – read more in this article.

Litigation, Enforcement, and Examination Developments

  • August 12: New York City Council Speaker Julie Menin announced an investigation into four major prediction market platforms, Kalshi, Polymarket, Coinbase, and Gemini Titan. The investigation will focus on potentially deceptive or predatory marketing practices directed at New Yorkers, with particular concern for tactics targeting young people – read the announcement here.
  • August 11: The SEC and CFTC filed parallel suits against bankrupt cryptocurrency firm Goliath Ventures and its founder, Christopher Delgado, alleging they operated a $400-425 million Ponzi scheme that promised returns from crypto liquidity pools but instead used investor funds for personal expenses and payments to earlier investors – read the SEC press release here and the CFTC press release here.
  • August 11: The CFTC issued an emergency order directing prediction market platform Kalshi to continue operating normally, asserting its exclusive federal jurisdiction over event contract swaps in defiance of New York's pending request for a restraining order that would shut down the platform's offerings under state gambling laws. In addition, Kalshi asked a Utah federal court to enjoin the state from enforcing its anti-gambling laws – read the order to Kalshi here and the Utah filing here.
  • August 10: A New York federal judge entered a default judgment ordering BitConnect promoter Craig Grant to pay more than $2.6 million to the SEC for allegedly recruiting investors into BitConnect’s unregistered crypto lending program through online promotion and referrals – read the decision here.
  • August 7: A Michigan federal judge denied Coinbase’s request for a preliminary injunction to block state enforcement related to its planned sports event contracts offering, finding Coinbase had not shown federal law preempts Michigan’s authority or that compliance with both federal and state law is impossible – read the decision here.

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GENIUS Act Tracker

As of July 16, 2026

Jump to: GENIUS Act Rulemaking Timeline  |  GENIUS Act Reporting Requirements

Download a PDF of this page.

The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act (the "GENIUS Act") enacted in July 2025 instructs the prudential bank regulators and the U.S. Treasury to promulgate regulations, and coordinate as appropriate, implementing the GENIUS Act. Majority of the implementation final rules must be promulgated are within one year of the statute's effective date, and GENIUS Act officially takes effect on the earlier of January 18, 2027, or 120 days after final rules are issued. The timeline to promulgate each regulation is set out below along with updates on the status of the notice and comment processes that each of the FDIC, the Federal Reserve, OCC, NCUA, and the Department of the Treasury (FinCEN/OFAC) have initiated to comply with the rulemaking requirements set out in the GENIUS Act.


GENIUS Act Rulemaking Timeline

Required RulemakingResponsible RegulatorTimeline to Promulgate Required RegulationStatusGENIUS Act Section


GENIUS Act Reporting Requirements

In addition to the rulemaking activity summarized above, the GENIUS Act requires the primary federal payment stablecoin regulators, including the FDIC, NCUA, Federal Reserve and OCC for banks and the OCC for non-bank and state-supervised PPSIs, the Treasury Secretary and/or the Attorney General, to produce reports for the Committee on Banking, Housing, and Urban Affairs of the Senate; the Committee on Financial Services of the House of Representatives; or the Director of the Office of Financial Research, as summarized below.

Required ReportsResponsible RegulatorDue DateStatusGENIUS Act Section



1. The Federal Reserve Board, FinCEN, OCC, FDIC and the NCUA have proposed rules in parallel to modernize AML/CFT program requirements for entities subject to their supervision to implement provisions of the Anti-Money Laundering Act of 2020. While these proposed rules are outside of the scope of the GENIUS Act, they are relevant as as to overall BSA compliance. The Board of Governors of the Federal Reserve System, “Anti-Money Laundering and Countering the Financing of Terrorism Programs” (Proposed Rule), published July 9, 2026; Financial Crimes Enforcement Network (FinCEN), Department of the Treasury, “Anti-Money Laundering and Countering the Financing of Terrorism Programs” (Proposed Rule), published April 10, 2026; Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA), “Anti-Money Laundering and Countering the Financing of Terrorism Programs” (Proposed Rule), published April 10, 2026

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