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

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Cryptocurrency, Digital Assets, and Blockchain Updates

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News and Events

October 20, 2026

On-Chain Spotlight

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

Regulatory Developments

  • October 9: The CFTC proposed amending its swaps definition to expressly include event contracts tied to sports, politics, culture and weather, reinforcing the agency’s position that these products fall within its exclusive federal jurisdiction. In a separate interim final rule, the CFTC excluded casino-style wagers from the definition, distinguishing direct bets with bookmakers from tradable contracts on exchanges – read the press release and the NPRM here.
  • September 30: The UK Financial Conduct Authority has opened applications for authorization under its new crypto asset regime, which takes effect on October 25, 2027, and existing firms seeking to continue regulated activities while their applications are reviewed should apply by February 28, 2027 – read the press release here.

Market Developments

  • October 15: Stripe is partnering with Plasma to develop multi-currency stablecoin cards designed to let customers spend in the currencies they hold, reducing the need for conversions and FX costs when spending abroad – read more in this article.
  • October 15: Mastercard and BVNK launched the Mastercard Global Money Platform, combining Mastercard’s payment network with BVNK’s stablecoin infrastructure to let banks, FinTechs and businesses embed branded multi-currency accounts and manage payments, treasury and settlement. Available through BVNK, the platform supports fiat and stablecoins, real-time conversion, stablecoin-linked cards and local bank payouts, with tokenized deposits and other capabilities planned – read the press release here.
  • October 14: Solidus Labs has hired former CFTC attorney Kevin Webb to lead its policy efforts and engagement with lawmakers, regulators and industry groups on market surveillance – read the LinkedIn release here.
  • October 14: Kraken parent Payward has signed a definitive agreement to acquire Saldo Bank, a Lithuania-licensed bank with operations across several European markets, to expand its regulated banking infrastructure in the EU. The transaction is expected to close in 2027, subject to regulatory approvals, and could support deposit, lending, card, SEPA payment and banking-as-a-service offerings for Payward’s European customers and partners
    – read the press release here.
  • October 13: The SEC approved Cboe rules permitting cash-settled binary options tied to KPIs reported in the SEC filings of 23 public companies, including crypto-related measures such as Coinbase’s trading volume and MARA’s bitcoin production – read the SEC statement here.
  • October 13: Stripe-owned Privy and Ripple are extending Privy’s wallet infrastructure to the XRPL, allowing developers to create and manage wallets, sign transactions, and build payment and agentic-commerce applications using XRP, RLUSD and other digital assets. The integration will also support x402 payments with policy controls and gas sponsorship planned for a later phase – read the press release here.
  • October 13: Texas-based Bakkt selected Thredd to supply card processing, integrated credit and related payment services for a planned US credit card program issued by partner banks and designed to settle in stablecoins. The initial proof of concept is targeted for the first half of 2027, subject to bank, network and other applicable requirements and approvals – read Thredd’s announcement here.
  • October 13: Rain launched non-custodial stablecoin wallets that partners can embed in their apps and connect through one integration to cards and money-movement services, with custodial wallets and additional balance-earning features planned before year-end – read Rain’s press release here.
  • October 13: Blockchain.com has applied to the CFTC to register as an FCM and for designation as a DCM, a step toward offering US retail and institutional customers crypto derivatives and event contracts through its platform. The proposed offerings would require CFTC approval before launch, and the company says the applications are part of its broader effort to expand regulated digital asset services – read the article here to learn more.
  • October 12: Morgan Stanley now expects to support tokenized equities on its alternative trading system in the first quarter of 2027 – learn more in this article.
  • October 8: Samsung and the Solana Foundation announced that eligible US Galaxy users will be able to send cross-border USDC transfers through Samsung Wallet beginning in the last week of October 2026, with Solana operating behind the scenes and fiat conversion integrated into the service; the announced reach of 82 million US Galaxy devices refers to compatible devices, not confirmed users – read the article here and read Solana’s announcement here.
  • October 8: JPMorgan analysts estimated roughly $50 billion has flowed into digital assets this year and said improving crypto ETF flows and rising CME bitcoin and ether futures positioning have created positive momentum into Q4 after corporate treasury buying and venture funding dominated the first half – read the article here to learn more.
  • October 8: Securitize launched tokenized US equities on Solana for eligible investors in the United States, EU and other permitted jurisdictions, stating that each token is backed 1:1 by an underlying share and represents a security entitlement with applicable shareholder rights and economic benefits. Trading is initially offered through Securitize’s registered
    broker-dealer platform; potential availability on NYSE’s planned digital venue and the OKXICE Tokenized Securities Venue remains subject to launch, regulatory and operational requirements – read Securitize’s press release here.

Litigation, Enforcement, and Examination Developments

  • October 15: A New York federal judge denied a joint request by the CFTC and Gemini to vacate their January 2025 consent order resolving allegations that Gemini misled the agency during its review of a proposed bitcoin futures contract. The CFTC remains free to decide whether to enforce the order – read the opinion here.
  • October 14: The Brooklyn District Attorney’s Office and FBI disrupted a multinational crypto-investment scam by seizing 241 fraudulent domains and more than 100 servers used to target Russian-speaking US residents through fake investment websites and follow-on recovery scams. Authorities estimate the operation stole tens of millions of dollars; the DA’s Office has seized about $300,000 and says the infrastructure takedown is intended to hinder the scammers from quickly rebuilding – read the District Attorney’s Office press release here.
  • October 9: New York’s attorney general announced a settlement permanently barring former Celsius CEO Alex Mashinsky from the securities, commodities and cryptocurrency industries and providing for up to $35 million in conditional payments to New York, alongside the federal forfeiture and sentence provisions described in the agreement
    – read the New York AG announcement here.
  • October 9: Kalshi petitioned the Sixth Circuit for rehearing and rehearing en banc of its September decision permitting Ohio and Tennessee to enforce gambling laws against Kalshi’s sports event contracts, contending the panel erred on both the contracts’ classification as swaps and federal preemption and that recent CFTC rule proposals further undermine its reasoning – read Kalshi’s petition here.
  • October 8: The DOJ’s National Fraud Enforcement Division has directed prosecutors to pursue fraud cases using a broad range of criminal authorities, prioritizing early asset seizures, undercover operations, and assessing detention risks throughout a case. The guidance also calls for stronger deterrence arguments at sentencing, including seeking departures from sentencing guidelines when guideline ranges inadequately reflect the offense – read the DOJ’s memorandum here.
  • October 7: A federal judge sentenced Empire Market co-creator Raheim Hamilton to 40 years in prison and fined him $5 million after he pleaded guilty to a drug conspiracy charge involving his cryptocurrency-only dark web marketplace, which facilitated more than $430 million in transactions from 2018 to 2020. In addition, Hamilton agreed to forfeit about 1,230 bitcoin as well as other assets – read the press release here.

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GENIUS Act Tracker

As of July 16, 2026

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

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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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