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
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Formation and structuring of ETFs and other 1940 Act-registered investment fund structures, including preparing registration statements and facilitating SEC review process
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Organization of private investment funds, including hedge funds and venture funds
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Preparation of private fund documents such as private placement memorandums, limited partnership agreements, trust agreements, escrow agreements, subscription booklets, and investment management agreements
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Advising on 19b-4 exchange listing applications for publicly traded digital asset investment funds
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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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Insights
Cryptocurrency, Digital Assets, and Blockchain Updates
Engagements
Notable Engagements
News and Events
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August 4, 2026 On-Chain SpotlightRead our synopsis of key regulatory, market, and litigation developments shaping the blockchain and digital assets industry: Regulatory Developments
Market Developments
Litigation, Enforcement, and Examination Developments
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Past EditionsJulyDownload a PDF of the July 28, 2026 edition. Download a PDF of the July 20, 2026 edition. Download a PDF of the July 13, 2026 edition. Download a PDF of the July 6, 2026 edition. JuneDownload a PDF of the June 29, 2026 edition. Download a PDF of the June 22, 2026 edition. Download a PDF of the June 15, 2026 edition. Download a PDF of the June 8, 2026 edition. Download a PDF of the June 2, 2026 edition. MayDownload a PDF of the May 26, 2026 edition. Download a PDF of the May 18, 2026 edition. Download a PDF of the May 11, 2026 edition. Download a PDF of the May 4, 2026 edition. AprilDownload a PDF of the April 27, 2026 edition. Download a PDF of the April 20, 2026 edition. Download a PDF of the April 13, 2026 edition. Download a PDF of the April 7, 2026 edition. MarchDownload a PDF of the March 30, 2026 edition. Download a PDF of the March 26, 2026 edition. Download a PDF of the March 16, 2026 edition. Download a PDF of the March 6, 2026 edition. FebruaryDownload a PDF of the February 27, 2026 edition. Download a PDF of the February 20, 2026 edition. Download a PDF of the February 13, 2026 edition. Download a PDF of the February 6, 2026 edition. JanuaryDownload a PDF of the January 23, 2026 edition. |
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GENIUS Act Tracker
As of July 16, 2026
Jump to: GENIUS Act Rulemaking Timeline | GENIUS Act Reporting Requirements
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 Rulemaking | Responsible Regulator | Timeline to Promulgate Required Regulation | Status | GENIUS Act Section |
| Issuance and treatment of payment stablecoins | Treasury Secretary | July 18, 2026 (one year after enactment) | Advance Notice of Proposed Rulemaking on GENIUS Act Implementation issued by the Department of Treasury on September 18, 2025; as published in the Federal Register on September 19, 2025 (“Treasury ANPRM”). Comment period closed November 4, 2025. | §§3(c)-(d) 12 U.S.C. § 5902 |
| Capital, liquidity, risk management, amendments to capital requirements |
FDIC, Federal Reserve, OCC, NCUA, and any applicable State Payment Stablecoin Regulator |
July 18, 2026 (one year after enactment) |
Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency issued on February 25, 2026; as published in the Federal Register on March 2, 2026 (“OCC Implementation NPRM”). Comment period closes May 1, 2026. GENIUS Act Requirements and Standards for FDIC‑Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions issued on April 7, 2026; as published in the Federal Register on April 10, 2026 (“FDIC Implementation NPRM”). Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration; as published in the Federal Register on May 18, 2026 ("NCUA Implementation NPRM"). Comment period closes July 17, 2026. |
§ 4(a)(4) 12 U.S.C. § 5903(a)(4) |
| PPSI BSA and Economic Sanctions Compliance Standards |
FDIC |
July 18, 2026 (one year after enactment) |
Bank Secrecy Act and Sanctions Compliance Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers on May 22, 2026; as published in the Federal Register on June 06, 2026 (“FDIC Comment Request”). Comment period closes August 04, 2026. |
§ 4(a)(4)(A)(iv) of the GENIUS Act (12 U.S.C. 5903(a)(4)(A)(iv)) |
| Rules applying BSA/AML and sanctions obligations to permitted payment stablecoin issuers1 | Treasury Secretary | Presumed—July 18, 2026 (one year after enactment) deadline may apply | Permitted Payment Stablecoin Issuer Anti‑Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements issued on April 8, 2026; as published in the Federal Register on April 10, 2026 (“Treasury AML NPRM”). Comment period closes June 9, 2026. |
§ 4(a)(5)(B) 12 U.S.C. § 5903(a)(5)(B) |
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PPSI Customer Identification Program (“CIP”) Requirements |
FinCEN, jointly with OCC, Federal Reserve, FDIC, NCUA |
[TBD] |
Notice of Proposed Rulemaking on Permitted Payment Stablecoin Issuer Customer Identification Program issued on June 18, 2026; as published in the Federal Register on June 22, 2026 (“PPSI Customer Identification Program NPRM”). Comment period closes August 21, 2026. |
§ 4(a)(5)(A) 12 U.S.C. § 5903(a)(5)(A) |
| General regulations for financial stability and implementation of the principal requirements of § 4(a) | OCC, in coordination with other relevant payment stablecoin regulators | July 18, 2026 (one year after enactment) | OCC Implementation NPRM |
§ 4(b) 12 U.S.C. § 5903(b) |
| General regulations for implementation of and compliance with the principal requirements of § 4(a) |
FDIC, Federal Reserve, OCC, NCUA, and any applicable State Payment Stablecoin Regulator |
July 18, 2026 (one year after enactment) |
OCC Implementation NPRM FDIC Implementation NPRM NCUA Implementation NPRM |
§ 4(h) 12 U.S.C. § 5903(h) |
| Processes for applications by, and regulation and supervision of, Federal‑qualified payment stablecoin issuers |
FDIC, Federal Reserve, OCC, and NCUA |
July 18, 2026 (one year after enactment) |
OCC Implementation NPRM FDIC Implementation NPRM Investments in and Licensing of Permitted Payment Stablecoins Issuers issued on February 11, 2026; as published in the Federal Register on February 12, 2026 (“NCUA Licensing NPRM”). Comment period closed April 13, 2026. Approval Requirements for Issuance of Payment Stablecoins by Subsidiaries of FDIC‑Supervised Insured Depository Institutions issued on December 16, 2025; as published in the Federal Register on December 19, 2025 (“FDIC Licensing NPRM”). Comment period extended from February 17, 2026 to May 18, 2026. |
§ 5(a)(2)(A) 12 U.S.C. § 5904(a)(2) |
| Regulation of payment stablecoin issuance | FDIC, Federal Reserve, OCC, and NCUA | July 18, 2026 (one year after enactment) |
OCC Implementation NPRM FDIC Implementation NPRM NCUA Implementation NPRM NCUA Licensing NPRM FDIC Licensing NPRM |
§ 5(g) 12 U.S.C. § 5904(g) |
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Federal Reserve backup enforcement authority against State‑qualified permitted payment stablecoin issuers in unusual and exigent circumstances |
Federal Reserve | July 18, 2026 (one year after enactment) | Pending |
§ 7(e)(1)(B) 12 U.S.C. § 5906(e)(2) |
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Office of the Comptroller of the Currency backup enforcement authority against State‑qualified permitted payment stablecoin issuers that are nonbanks in unusual and exigent circumstances |
OCC | July 18, 2026 (one year after enactment) | OCC Implementation NPRM |
§ 7(e)(1)(B) 12 U.S.C. § 5906(e)(2) |
| Criteria regarding resumption of compliance by a foreign payment stablecoin issuer | Treasury Secretary | July 18, 2026 (one year after enactment) | Treasury ANPRM |
§ 8(b)(3)(B) 12 U.S.C. § 5907(b)(3)(B) |
| Standards for registration requests and appeals process of foreign payment stablecoin issuers | OCC | July 18, 2026 (one year after enactment) | OCC Implementation NPRM |
§ 18(c)(1)(E) 12 U.S.C. § 5916(c)(1)(E) |
| Rules implementing the anti‑tying provision and permitting exceptions | Federal Reserve, in consultation with the FDIC, Federal Reserve, OCC, and NCUA as related to exceptions to the anti‑tying provision | No deadline—regulators “may” issue such orders | Pending |
§ 4(a)(8)(B) 12 U.S.C. § 5903(a)(8)(B) |
| Rules clarifying the application of ownership limitations, including restrictions on payment stablecoin issuance by U.S. public companies and companies not domiciled in the United States that are “not predominantly engaged” in financial activities | Stablecoin Certification Review Committee (Treasury Secretary, Federal Reserve Chair, and FDIC Chair) | July 18, 2026 (one year after enactment) | Pending |
§ 4(a)(12)(D) 12 U.S.C. § 5903(a)(12) |
| Principles for assessment of whether state regulatory frameworks are “substantially similar” to federal frameworks | Treasury Secretary | Presumed—July 18, 2026 (one year after enactment) deadline may apply | GENIUS Act Broad‑Based Principles for Determining Whether a State‑Level Regulatory Regime Is Substantially Similar to the Federal Regulatory Framework issued on April 1, 2026; as published in the Federal Register on April 3, 2026 (“Treasury Substantially Similar NPRM”). Comment period closes June 2, 2026. |
§ 4(c)(2) 12 U.S.C. § 5903(c)(2) |
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Certifications from state payment stablecoin regulators that the state‑level regulatory regime satisfies applicable criteria and is “substantially similar” to the federal framework, and annual recertifications of the accuracy of the initial certification |
State Payment Stablecoin Regulator | July 18, 2026 (one year after enactment) | Pending |
§ 4(c)(4) 12 U.S.C. § 5903(c)(4) |
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Established process for expedited review of state regimes for substantial similarity to the federal regime if the state has a prudential regulatory regime in effect by January 14, 2026 |
Stablecoin Certification Review Committee (Treasury Secretary, Federal Reserve Chair, and FDIC Chair) | Responsible regulator shall endeavor for the process must be in effect by January 14, 2026 to enable expedited review | Pending |
§ 4(c)(7) 12 U.S.C. § 5903(c)(7) |
| State‑level requirements for state‑qualified payment stablecoin issuers may be issued to the same extent as federal regulations | State Payment Stablecoin Regulator | No deadline—regulators “may” issue such orders | Pending |
§ 7(d) 12 U.S.C. § 5906(d) |
| Public comment on anti‑money laundering innovation | Treasury Secretary | Beginning August 17, 2025 for a period of 60 days |
Treasury ANPRM Treasury Issues Request for Comment Related to the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act issued on August 18, 2025; comment period closed October 17, 2025 (“Treasury Illicit Finance RFC”). |
§ 9(a) 12 U.S.C. § 5908(a) |
| Rulemaking to mitigate illicit financial activity | FinCEN | July 18, 2028 (three years after enactment) | Pending |
§ 9(d) 12 U.S.C. § 5908(a) |
| Prescribe terms and conditions under which exceptions to custody requirements apply | FDIC, Federal Reserve, OCC, and NCUA | No deadline—regulators “may” issue such orders | Pending |
§ 10(c)(2)(C) 12 U.S.C. § 5909(c)(2)(C) |
| Assessment of the necessity of interoperability standards among permitted payment stablecoin issuers and the broader digital finance ecosystem | FDIC, Federal Reserve, OCC, and NCUA, in consultation with NIST | Unclear—July 18, 2026 (one year after enactment) deadline may apply | Pending |
§ 12 12 U.S.C. § 5912 |
| Review of existing regulations applicable to regulated entities |
FDIC, Federal Reserve, OCC, and NCUA |
Unclear—July 18, 2026 (one year after enactment) deadline may apply |
Pending NCUA Implementation NPRM |
§ 16(b) 12 U.S.C. § 5915(b) |
| Issuance of rules that may be required to regulate foreign payment stablecoin issuers offering and selling payment stablecoins in the United States | Treasury Secretary | July 18, 2026 (one year after enactment) | Treasury ANPRM |
§ 18(b)(6) 12 U.S.C. § 5916(b)(6) |
| Creation and implementation of reciprocal arrangements or bilateral agreements between the U.S. and comparable payment stablecoin regulatory regimes | Treasury Secretary | July 18, 2027 (two years after enactment) | Treasury ANPRM |
§ 18(d)(3) 12 U.S.C. § 5916(d)(3) |
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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 Reports | Responsible Regulator | Due Date | Status | GENIUS Act Section |
| Justification for the determination of Unusual and Exigent Circumstances in approving safe harbors | Treasury Secretary | Prior to issuing such safe harbor | Pending |
§ 3(c) 12 U.S.C. § 5902 |
| National security coordination with permitted payment stablecoin issuers | Attorney General and Treasury Secretary | July 18, 2026 (one year after enactment) | Pending |
§ 4(a)(6)(C) 12 U.S.C. § 5903(a)(6)(C) |
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Notification to Congress upon beginning the processing of applications from prospective permitted payment stablecoin issuers |
FDIC, Federal Reserve, OCC, and NCUA | As‑needed | Pending |
§ 5(e) 12 U.S.C. § 5904(e) |
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Annual reports to Congress on applications from prospective permitted payment stablecoin issuers that have been pending for at least 180 days |
FDIC, Federal Reserve, OCC, and NCUA | Annually | Pending |
§ 5(e) 12 U.S.C. § 5904(e) |
| Reports regarding secondary trading of a payment stablecoin issued by a foreign payment stablecoin issuer | Treasury Secretary | As‑needed within seven days after the applicable waiver or license is issued | Pending |
§ 8(c)(4) 12 U.S.C. § 5907(c)(4) |
| Report addressing illicit finance‑related recommendations, including detection, risk assessment, and legislative recommendations | Treasury Secretary | January 14, 2026 (180 days after enactment) | Report to Congress from the Secretary of the Treasury on Innovative Technologies to Counter Illicit Finance Involving Digital Assets (March 2026) |
§ 9(e) 12 U.S.C. § 5908(e) |
| Report providing findings of a study regarding insolvency proceedings of permitted payment stablecoin issuers | FDIC, Federal Reserve, OCC, and NCUA | July 18, 2028 (three years after enactment) | Pending |
§ 11(h) 12 U.S.C. § 5910 |
| Report confirming and describing regulations issued to carry out the GENIUS Act | Federal Banking Agencies (FDIC, Federal Reserve, OCC) | January 14, 2026 (180 days after enactment) | Pending |
§ 13(c) 12 U.S.C. § 5913(c) |
| Report providing findings of a study of non‑payment stablecoins, including endogenously collateralized stablecoins | Treasury Secretary | July 18, 2026 (one year after enactment) | Pending |
§ 14(a)(2) 12 U.S.C. § 5914(a)(2) |
| Report providing information on the status of the payment stablecoin industry, including trends, applications for permitted payment stablecoin issuer status, and potential financial stability risks | FDIC, Federal Reserve, OCC, NCUA, and any applicable State Payment Stablecoin Regulator | July 18, 2026 (one year after enactment) | Pending |
§ 15(a) 12 U.S.C. § 5914(a) |
| Incorporation of the above report into its annual report to Congress pursuant to the Dodd‑Frank Act | Financial Stability Oversight Council |
Annually, beginning July 18, 2026 (one year after enactment) |
Pending |
§ 15(b) 12 U.S.C. § 5914(b) |
- 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.
