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

September 15, 2026

On-Chain Spotlight

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

Regulatory Developments

  • September 14: As the Senate prepares a Sept. 15 cloture vote to proceed on the Digital Asset Market CLARITY Act, Senate Republicans released what they describe as the final text, incorporating 125 changes requested by Democrats. The latest version of the bill contains 1) stricter ethics rules, agreed to by President Trump, that would require senior government officials with significant crypto holdings to divest those interests or place them in a qualified blind trust, with state attorneys general now empowered to enforce; 2) a new “regulatory circuit breaker” that would permit the Treasury Secretary to rein in stablecoin yield if community-bank deposits suffer substantial harm, expiring 18 months after enactment; 3) narrowed protections for developers, enabling them to avoid some civil—but not criminal—liability; and 4) sharper DeFi rules requiring protocols that are "decentralized in name only" to register with the CFTC and comply with the Bank Secrecy Act. In the event the Senate passes the bill, the House will have until its Sept. 17 departure date, plus its remaining legislative days left in this Congress, to pass it – read the article here and read the press release and bill text here.

  • September 8: Federal banking regulators and FinCEN issued new FAQs clarifying that state-issued mobile driver’s licenses and other government-issued verifiable digital credentials (VDCs) may be used to verify the identities of natural person customers under the Customer Identification Program rule. Coupled with an FAQ update confirming that a digital certificate can also serve as a non-documentary means of verifying customer identity, this guidance should streamline customer onboarding and compliance for banks and fintechs offering cryptocurrency and digital asset services by allowing the use of digital credentials for identity verification – read the announcement here.

  • September 2: The Wyoming Stable Token Commission said it adopted Chainlink Proof of Reserve as its exclusive on-chain verification layer for the Frontier Stable Token (FRNT), combining independent examination with automated on-chain reserve verification – read the joint announcement here.

Market Developments

  • September 10: Nasdaq Ventures is investing $100 million in Payward, the parent company of Kraken, to expand their partnership and accelerate development of tokenized equity infrastructure through the Nasdaq Equity Token (NET) framework, with NETs expected to launch in 2027 – read the press release here.
  • September 10: Nu has partnered with Lead Bank to launch its suite of digital banking products in the US, while also pursuing a national bank charter. The launch includes Nu Global, a multicurrency digital account leveraging stablecoins – read the press release here.
  • September 9: The Canary Staked TRX ETF is set to debut on Cboe under the ticker TRXS, offering investors exchange-traded exposure to TRX while staking most of its holdings so that staking rewards are retained in the fund and increase net asset value – read the prospectus here.
  • September 8: Block said it submitted an application to the OCC to form Builders Bank & Trust, N.A., an uninsured national trust bank intended to provide custody and related fiduciary services for assets including bitcoin and stablecoins without accepting deposits or making loans – read Block’s announcement here.
  • September 8: Visa said it launched a program that combines VisaNet settlement data with on-chain credit infrastructure to help stablecoin-linked card programs and FinTechs obtain working capital, and it reported that stablecoin-linked card program payment volume on its network is up nearly 200% year over year – read Visa’s press release here.
  • September 8: Robinhood said it will route selected football event contracts to OG.com’s CFTC-regulated exchange and clearinghouse and take equity stakes in OG.com and Crypto.com. Robinhood will continue routing event contracts to venues including Kalshi, ForecastEX and Rothera as it expands its prediction markets offering during the NFL season – read Robinhood’s announcement here.
  • September 8: Liquid Network said purported white-hat hackers withdrew about 4,000 BTC (about $320 million) from the Liquid Federation wallet, prompting the network to temporarily disable bridge nodes and halt new transactions. Perpetrators stated that the funds will be returned after the vulnerability is fixed – read a breakdown of the vulnerabilities here.
  • September 6: DBS, a financial services group in Asia with a presence in 19 markets, and Citi said they completed a successful weekend cross-border US dollar payment between Singapore and the United States using tokenized deposits via the Swift Digital Ledger, with the transaction taking minutes and enabling 24/7 cross-border USD payments outside traditional banking hours – read the press release here.
  • September 3: Coinbase announced that it filed registration documents with the SEC to offer equity perpetual derivatives and that the product would also require CFTC approval – read Coinbase’s announcement here.

Litigation, Enforcement, and Examination Developments

  • September 9: Mexican federal authorities and Puebla state police seized and shut down a crypto mining site in Tlaola, Puebla, that allegedly drew power illegally, confiscating roughly 300 specialized mining computers along with related electrical and satellite internet infrastructure while prosecutors pursue an electricity-theft investigation – read the article here.
  • September 9: Kalshi petitioned the Ninth Circuit for a rehearing, arguing that the court’s recent decision wrongly classified its sports event contracts as sports bets rather than swaps governed by the Commodity Exchange Act, creating a circuit split on prediction market regulation – read the petition here.
  • September 8: Malone Lam, a 22-year-old Singapore citizen living in Miami, pleaded guilty in federal court in Washington, DC to one count of racketeering conspiracy for leading an international “social engineering” scheme that prosecutors say stole and laundered more than $245 million in cryptocurrency, with Lam now facing up to 20 years in prison with a status hearing set for Dec. 8 – read the US Attorney’s press release here.
  • September 4: Three alleged crypto scam victims filed a proposed class action against Meta, alleging that scam ads on Facebook and Instagram caused their losses and that Meta’s advertising and generative AI tools helped scammers optimize those ads. The complaint seeks class certification, injunctive relief, and monetary damages – read the complaint here.
  • September 4: Robinhood Derivatives agreed to stop offering new sports-related event contracts in Michigan by Sept. 9 and to close remaining open positions for Michigan customers by Oct. 9, in exchange for the Michigan attorney general agreeing to hold off on enforcement action until the Sixth Circuit rules on pending appeals concerning the legality of sports event contract offerings including Robinhood, Kalshi, Coinbase, and Polymarket – read the joint stipulation order here.

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September

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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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