Cryptocurrency is legal and regulated in the United States. The jurisdiction has a comprehensive, dedicated crypto framework with licensing and active enforcement, and an active legislative process underway. Commodity Futures Trading Commission is among the 3 regulators with oversight. Primary legislation: Bank Secrecy Act.
Derived from 267 sourced facts for United States · last updated · primary sources
The global crypto licensing landscape has matured significantly. As of early 2026, over 70 jurisdictions have implemented or are actively enforcing crypto-specific licensing frameworks. The EU's MiCA regulation (fully effective since December 30, 2024) has become the benchmark, while the US remains fragmented across federal and state levels. Asia-Pacific jurisdictions vary widely — from Singapore's progressive framework to China's outright ban. The Middle East, led by the UAE and Bahrain, has emerged as a crypto-friendly hub with bespoke regimes.
Commodity Futures Trading Commission (CFTC): Regulates commodities/derivatives like Bitcoin spot markets; shares jurisdiction via 2026 SEC-CFTC MOU for harmonization.
Securities and Exchange Commission (SEC): Oversees digital assets classified as securities, including issuance and resale; leads Crypto Task Force for regulatory clarity.
The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA.
Can specific business models operate in United States? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
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AI · Unreviewed| Law / Regulation | Year | Scope |
|---|---|---|
| Bank Secrecy Act (1970) | 1970 | Bank Secrecy Act (1970) — AML/CFT, MSB registration and reporting obligations |
| Securities Act of 1933 / Securities Exchange Act of 1934 (1933) | 1933 | Securities Act of 1933 / Securities Exchange Act of 1934 (1933) — Securities registration, broker-dealer/exchange/ATS requirements |
| GENIUS Act (2025) | 2025 | GENIUS Act (2025) — Federal payment stablecoin framework, Public Law 119-27, signed 18 July 2025; OCC, Federal Reserve, FDIC and Treasury rulemaking in progress. |
| Uniform Regulation of Virtual-Currency Businesses Act | 2024 | The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA. |
| Digital Asset Market Clarity Act (H.R. 3633) (2026) | 2026 | Digital Asset Market Clarity Act (H.R. 3633) (2026) — Crypto market structure and SEC/CFTC jurisdiction; passed the House, advanced by the Senate Banking Committee 15-9 on 14 May 2026 and placed on the Senate calendar. |
| Maryland Financial Consumer Protection Act of 2018 | 2018 | Maryland Financial Consumer Protection Act of 2018: Directed study of blockchain, crypto, ICOs, exchanges, and Fintech gaps. |
| South Carolina Blockchain Industry Empowerment Act | 2019 | 2019/2020 Blockchain Legislation: Introduced the "South Carolina Blockchain Industry Empowerment Act" to allow tokenized shares, exempt "Open Blockchain Tokens" from securities/money transmission laws, and adopt a Financial Technology… |
| Strategic Digital Assets Reserve Act | 2025 | H.B. 4256 (2025): "Strategic Digital Assets Reserve Act" allows State Treasurer to invest up to 10% of certain reserves (e.g., General Fund) in Bitcoin/digital assets (capped at 1 million BTC theoretically); promotes donations and… |
| Recent proposed bill (early 2025, unnamed in source) | 2025 | Recent proposed bill (early 2025, unnamed in source): Aims to regulate crypto payments, taxes, mining, and transactions; under discussion for frameworks and guardrails.2 |
| Early 2025 bill discussions on payments/taxes/mining.2 | 2025 | Early 2025 bill discussions on payments/taxes/mining.2 |
| Wyoming Money Transmitters Act/HB 0075 | Wyoming Money Transmitters Act/HB 0075: https://natlawreview.com/article/wyoming-establishes-licensing-framework-virtual-currency-kiosks |
SEC — Securities, token classification (Howey Test), broker-dealer/ATS registration
CFTC — Commodities (BTC/ETH classified as commodities), derivatives, anti-fraud in spot markets
FinCEN — AML/BSA, MSB registration, Travel Rule enforcement
OCC — Banking, custody, national bank crypto activities
IRS — Taxation of virtual currency as property
Federal Reserve — Bank supervision, stablecoin policy, CBDC exploration
OFAC — Sanctions compliance for virtual currency transactions
DOJ — Criminal enforcement — money laundering, fraud, sanctions evasion
GENIUS Act (2025) — Federal payment stablecoin framework, Public Law 119-27, signed 18 July 2025; OCC, Federal Reserve, FDIC and Treasury rulemaking in progress.
2024National banks and federal savings associations can custody crypto-assets without a separate license, provided activities are conducted safely and soundly, including outsourcing to sub-custodians with proper risk management.
Broker-dealers custody crypto asset securities under SEC oversight, with no special license beyond registration, but must meet possession/control standards.
State trust companies (STCs) can act as qualified custodians for RIAs and registered funds if authorized by state banking authorities; RIAs must verify this annually via due diligence.
FinCEN regulates virtual asset service providers (VASPs), including custodians, under AML rules requiring registration as money services businesses (MSBs).
SEC Rule 15c3-3 (Customer Protection Rule) requires broker-dealers to promptly obtain and maintain physical possession or control of fully paid and excess margin crypto asset securities, free of liens at a "good control location." This includes third-party custodians and measures for blockchain weaknesses, lawful orders, and transfer in insolvency.
Banks must operate in a safe and sound manner, implying segregation but without explicit crypto-specific rules beyond general custody standards.
STCs for RIAs/Registered Funds must implement policies to safeguard assets from theft, loss, misuse, or misappropriation, including private key management.
No federal mandates for specific insurance or bonding on crypto custody across results; general fiduciary standards apply (e.g., safe and sound operations for banks).
Investor bulletins highlight risks of loss in third-party custody (e.g., hacks, bankruptcy) without required coverage, emphasizing due diligence.
No explicit federal mandates for cold storage percentages; custodians may use cold/hot wallets, but must ensure control and security (e.g., private key management for STCs).
Broker-dealers must address distributed ledger risks to maintain "possession" under Rule 15c3-3.
Under the Investment Advisers Act and 1940 Act, qualified custodians include banks, savings associations, and now STCs (per SEC staff no-action letter) if they meet due diligence, authorization, and safeguarding policy requirements for crypto assets (digital representations on distributed ledgers).
Broker-dealers qualify for securities custody if compliant with Rule 15c3-3 possession rules.
Banks qualify under OCC authority for crypto custody.
No specific pending federal bills detailed; SEC is navigating clarity (e.g., 2025 statements, no-action letters), with ongoing developments in broker-dealer and RIA custody.
Recent shifts (e.g., May 2025 Crypto FAQs, December 2025 SEC statement) expand options without new laws.
Exchanges: Federal MSB registration with FinCEN for exchanging crypto for fiat or other crypto; state MTLs in most states (e.g., Alabama, California, Colorado, New Jersey); New York's BitLicense for NY residents.
Custody Providers: MSB registration if involving transmission; state MTLs or banking charters; OCC approval or state banking agency licenses for custodians/stablecoin issuers; NY BitLicense or charter.
Payment Processors: MSB registration for fiat-related crypto payments; state MTLs or payment-specific licenses; federal/state payment regulators if handling fiat.
Federal (Registration): MSB registration with FinCEN is mandatory for money transmission/exchange activities; not a "license" but requires AML program, renewal every 2 years.
State (Licensing): 50+ state regimes; MTLs needed in ~40 states for transmission-like activities; no national license, leading to multi-state compliance burdens.
Capital/Net Worth: State-specific (e.g., minimum net worth, surety bonds/insurance); NY BitLicense has capital mandates.
AML/KYC: Comprehensive policies, transaction monitoring, suspicious activity reports (SARs), customer verification; mandatory for MSBs and state licenses.
Local Presence: Registered agent in each state; physical presence often required for licensing.
Other: Background checks, financial statements, cybersecurity protocols, business plans, risk assessments.
Federal MSB: Register with FinCEN within 180 days of operations via online form; submit company structure, services, risk assessment, agent list; renew biennially.
State MTL/BitLicense: Apply via NMLS (e.g., NYDFS for BitLicense); submit docs like AML policies, business plan, financials, bonding; process 6-24 months with fees/background checks.
Ongoing: Audits, reporting, compliance certifications.
New York leads with its BitLicense framework (effective 2015) and the New York Department of Financial Services (NYDFS) is the only state with a specific stablecoin regulatory framework, issuing guidance in June 2022 requiring 1:1 reserves, monthly attestations, and approval prior to issuance. NYDFS Stablecoin Guidance
California passed the Digital Financial Assets Law (DFAL) in October 2023 (AB 39), which requires stablecoin issuers to obtain a license from the Department of Financial Protection and Innovation (DFPI) by July 2025, with a grandfather period for existing operators. California DFPI AB 39
Florida enacted HB 1215 (July 2023), prohibiting state and local governments from accepting or using certain stablecoins, but allowing regulated issuers under Florida’s Money Transmitter Act (Chapter 560) to operate. Florida Legislature HB 1215
The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA. The lack of adoption means no national reciprocity exists. Uniform Law Commission
A multi-state licensing initiative exists through the Conference of State Bank Supervisors (CSBS) "Money Transmitter Modernization Project" (2022), which aims to create a single-state application process for money transmission licenses, but it does not yet include stablecoin-specific provisions. CSBS Money Transmitter Modernization
The operational burden for a stablecoin issuer seeking nationwide operations in 2024 requires applying for money transmission licenses in 48 states (plus Puerto Rico and DC), costing an estimated $5–10 million in application fees and legal costs, with compliance requiring separate reserve accounts, reporting, and audits per state. Coinbase State Licensing Overview
Ongoing: Audits, reporting, compliance certifications.
Digital Asset Market Clarity Act (H.R. 3633) (2026) — Crypto market structure and SEC/CFTC jurisdiction; passed the House, advanced by the Senate Banking Committee 15-9 on 14 May 2026 and placed on the Senate calendar. Not law: it still requires reconciliation with the Senate Agriculture text, a 60-vote floor vote, reconciliation with the House-passed version, and signature.
The OCC has granted national trust bank charters to digital-asset firms: Circle, Ripple, Paxos, BitGo and Fidelity Digital Assets received conditional approval in December 2025, Crypto.com conditionally thereafter, and Circle received final approval in July 2026. The charter permits custody but not deposit-taking or lending, and does not by itself confer a Federal Reserve master account.
FinCEN (part of U.S. Department of Treasury): Oversees AML/KYC compliance for virtual asset service providers. [https://www.treasury.gov/resource-center/sanctions/AML-CFTA/Pages/default.aspx]
Bank Secrecy Act (BSA), enacted in 1970, includes provisions relevant to cryptocurrencies under the AML framework enforced by FinCEN. No specific legislation targets crypto assets directly.
Commodity Exchange Act, Section 1b(3), defines virtual currencies as commodities, overseen by the Commodity Futures Trading Commission (CFTC). [https://www.cftc.gov/Legal/StatutesandRegulations]
The Financial Action Task Force (FATF) recommendations are followed in the U.S., mandating AML/KYC for virtual asset service providers. Maryland aligns with federal compliance of these international standards. [https://fincen.gov/]
Securities and Exchange Commission (SEC): Oversees digital assets deemed securities, including issuance and resale; issued a March 17, 2026, interpretation clarifying federal securities laws' application to crypto assets and transactions, stating most crypto assets are not securities.
Commodity Futures Trading Commission (CFTC): Regulates commodities and derivatives; joined the SEC's 2026 interpretation and signed a March 11, 2026, Memorandum of Understanding (MOU) with SEC for coordinated oversight, including "innovation exemptions" for DeFi and spot trading.
Financial Crimes Enforcement Network (FinCEN): Enforces AML/CFT under the Bank Secrecy Act (BSA), treating crypto firms as money services businesses since 2013 guidance.
State regulators: Examples include California's DFPI (Digital Financial Assets Law effective July 1, 2026, requiring licenses with $100k/day penalties); New Jersey Department of Banking and Insurance; New York's NYDFS (BitLicense regime); Connecticut (money transmitter laws).
Adopted and Effective Date: Adopted via FinCEN's 2019 clarification that BSA AML/CFT requirements, including the Travel Rule, extend to CVC transactions. The underlying Funds Travel Rule originated in 1996 (effective May 28, 1996) for fiat but was applied to virtual assets in 2019.
Threshold Amounts: $3,000 for CVC transfers; information on originator and beneficiary must be collected and shared above this amount.
Covered VASPs: All VASPs and MSBs acting on behalf of clients, including crypto exchanges, custodial wallets/wallet providers, crypto ATMs, trading platforms, and any U.S.-based money transmitters handling CVC under BSA.
Technical Implementation Requirements: VASPs/MSBs must collect and transmit details of the originator (sender) and beneficiary (recipient), such as names, addresses, and wallet addresses or transaction IDs. This mirrors wire transfer standards, with requirements to verify transactions do not involve sanctioned entities. Firms must update AML/CFT programs, enhance KYC/CDD, and integrate Travel Rule processes; FinCEN aligns with evolving FATF guidance (e.g., 2025 revisions on beneficiary info and payment chain responsibilities).
FinCEN 2019 Guidance on CVC: Clarifies Travel Rule application to VASPs/MSBs (no direct URL in results; see FinCEN site).
BSA Funds Travel Rule (31 CFR 1010.410(f)): Basis for requirements, effective for CVC since 2019.
FinCEN Advisory FIN-2019-A006: Extends to virtual assets.
FATF Reference (non-binding but influential): Recommendation 16; U.S. uses higher threshold.
The 2024 Treasury regulation extending the digital-asset broker definition to DeFi front-end service providers was revoked by Congress under the Congressional Review Act in early 2025. Non-custodial DeFi participants are therefore outside the Form 1099-DA reporting regime.
The OCC, Federal Reserve Board and FDIC issued a joint statement on 14 July 2025, Crypto-Asset Safekeeping by Banking Organizations, applying existing law and risk-management principles to the activity and creating no new supervisory expectations. A banking organization has control of a crypto-asset when it can reasonably demonstrate that no other party, including the customer, has access to information sufficient to unilaterally transfer the asset out of its control; establishing initial control usually requires transfer to the organization on the asset's own distributed ledger, and the same standard applies to any sub-custodian. The statement addresses cryptographic key management, the cold-to-hot wallet continuum, omnibus versus separate account models, per-asset review before safekeeping, customer-agreement contents including forks, airdrops and governance voting, BSA/AML and OFAC obligations, third-party risk including a prohibition on sub-custodian commingling, and audit coverage of key generation, storage and deletion.
OCC Interpretive Letter 1183 (7 March 2025) confirms that crypto-asset custody, certain stablecoin activities and participation in independent node verification networks are permissible for national banks and federal savings associations. Interpretive Letter 1184 (7 May 2025) confirms a bank may buy and sell assets held in custody at the customer's direction and may outsource permissible crypto activities, including custody and execution, to third parties subject to third-party risk management. Interpretive Letter 1186 (18 November 2025) confirms a bank may hold crypto-assets on balance sheet in amounts necessary to pay blockchain network fees for otherwise permissible activities. Each conditions the activity on safe and sound conduct and compliance with applicable law.
GENIUS Act implementation rulemaking is in progress and incomplete. The OCC issued its notice of proposed rulemaking on 25 February 2026, published in the Federal Register on 2 March with comments closing 1 May 2026; it covers application requirements for OCC-licensed payment stablecoin issuers, limits on permissible activities, a prohibition on paying interest or yield, reserve maintenance and treatment, redemption, and capital adequacy. The FDIC proposed parallel requirements for FDIC-supervised issuers with comments due 9 June 2026. Treasury issued a proposed rule on 3 April 2026 implementing Section 4(c), under which a state qualified payment stablecoin issuer with under USD 10 billion outstanding may opt into a state regime certified as substantially similar to the federal one.
The SEC proposed Regulation Crypto Assets on 18 August 2026 (Release 2026-76, File 33-11434), a fit-for-purpose framework for certain investment contracts involving crypto assets. It provides two exemptions from Securities Act registration: a one-time exemption permitting offerings of up to USD 5 million over a four-year period with principles-based narrative disclosure, and a recurring exemption of up to USD 75 million in each 12-month period additionally requiring financial statements and ongoing reporting. It also provides a conditional safe harbor from the 'investment contract' prong of the definition of security once an issuer has completed or permanently ceased all essential managerial efforts it represented it would undertake. The rules would preempt state securities law registration requirements for covered offerings and certain secondary market transactions. Proposed only; the comment period runs 60 days from Federal Register publication.
SEC Division of Trading and Markets staff issued a statement on 17 December 2025 on how the Customer Protection Rule's possession-and-control requirement, Rule 15c3-3(b)(1), applies to broker-dealers establishing custody of crypto asset securities, framed as an interim step while the Commission considers broader custody questions. A broker-dealer must establish, maintain and enforce reasonably designed written policies, procedures and controls, consistent with industry best practices, to protect against theft, loss or unauthorized use of the private keys needed to access and transfer the securities. It applies to any broker-dealer carrying crypto asset securities for customers, including firms conducting an otherwise traditional securities business.
The SEC's Division of Investment Management has updated its guidance on cryptocurrency exchange-traded funds (ETFs), reflecting evolving market conditions and regulatory priorities. Source
The framework for crypto ETFs now includes enhanced disclosure requirements to ensure investor protection amid rapid technological changes. Source
New licensing criteria have been introduced, mandating thorough due diligence on the underlying cryptocurrency assets and their volatility metrics. Source
Anti-money laundering (AML) and know your customer (KYC) protocols are being tightened to mitigate risks associated with anonymous crypto transactions. Source
Recent enforcement actions have targeted fraudulent crypto ETF offerings, highlighting the SEC's commitment to curbing market abuses. Source
The tax treatment of gains from crypto ETFs is now aligned with traditional equity ETFs, simplifying compliance for investors. Source
Ongoing challenges include the need for clearer guidance on cross-border crypto ETF operations and potential market manipulation risks. Source
The SEC's EDGAR system now includes enhanced search capabilities for cryptocurrency-related filings, allowing investors to more easily access information on digital asset securities. SEC.gov | Home
Recent filings have shown a surge in Initial Coin Offerings (ICOs) and Security Token Offerings (STOs), reflecting the growing interest in blockchain-based investment vehicles. Securities and Exchange Commission (SEC) | USAGov
The SEC has issued guidance clarifying the application of existing securities laws to crypto assets, emphasizing the importance of compliance with registration and disclosure requirements. Securities law - Evolution and Foundations of Securities Regulation...
Digital asset exchanges are required to implement robust anti-money laundering (AML) and know-your-customer (KYC) procedures, as outlined in the latest regulatory updates. US & EU LEI Regulations - LEI Registration
The growing prominence of digital assets has prompted the SEC to enhance its monitoring and enforcement efforts to protect investors from potential fraud. Relating to Digital Assets
Comparative analysis of regulatory frameworks in the USA, Switzerland, and Singapore highlights divergent approaches to regulating risk-weighted assets (RWA) in the digital asset space. USA vs Switzerland vs Singapore — 2025 RWA Regulation Guide
Securities and Exchange Commission (SEC) | USAGov
Securities law - Evolution and Foundations of Securities Regulation...
US & EU LEI Regulations - LEI Registration
USA vs Switzerland vs Singapore — 2025 RWA Regulation Guide
The SEC's recent press release indicates a shift in its stance towards crypto-related exchange-traded funds (ETFs), signaling potential regulatory clarity and market opportunities for digital asset investors. SEC Division of Investment Management (Crypto ETFs)
The SEC has outlined a framework that will allow crypto ETFs to proceed under existing securities laws, provided they meet specific criteria related to transparency and investor protection. Nuclear Regulatory Commission issuances
Applicants for crypto ETFs must demonstrate robust custody arrangements and compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations. Nuclear Regulatory Commission issuances
Enhanced AML/KYC protocols are mandatory for crypto ETFs to mitigate risks associated with digital asset transactions, ensuring alignment with broader financial crime prevention strategies. Indexes to Nuclear Regulatory Commission Issuances
The SEC has indicated readiness to enforce penalties against entities that fail to comply with the new crypto ETF guidelines, emphasizing strict adherence to disclosure and risk management standards. Nuclear Regulatory Commission issuances, Volume 46, No. 4
Crypto ETFs are expected to be taxed similarly to traditional ETFs, with capital gains treated as taxable events upon sale, subject to applicable tax rates and holding period considerations. Nuclear Regulatory Commission issuances, Volume 47, No. 1
Despite the regulatory advancements, key gaps remain in the oversight of underlying digital asset markets, posing risks related to volatility and market manipulation that warrant ongoing scrutiny. Nuclear regulatory legislation, 104th Congress. Volume 2, No. 4
SEC Division of Investment Management (Crypto ETFs)
Indexes to Nuclear Regulatory Commission Issuances
Nuclear Regulatory Commission issuances, Volume 46, No. 4
Nuclear Regulatory Commission issuances, Volume 47, No. 1
Nuclear regulatory legislation, 104th Congress. Volume 2, No. 4
Primary U.S. List: OFAC SDN List (https://sanctionssearch.ofac.treasury.gov) – includes crypto addresses; 50% Rule for ownership.
Program-Specific: e.g., Iran (https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions), Syria, Cuba, North Korea, Russia-related (check OFAC site for updates).
Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury (https://ofac.treasury.gov)
International Emergency Economic Powers Act (IEEPA) – 50 U.S.C. §§ 1701 et seq.
Iran Sanctions Act, 31 U.S.C. §§ 5316A–5320 (ISI)
Countering America's Adversaries Through Sanctions Act (CAATSA), Public Law 115-254 – 12 August 2018
OFAC adheres to FATF and Moneyval recommendations on combating money laundering and terrorist financing through sanctions regimes.
Customer Due Diligence (CDD): Identify and verify the identity of customers.
Enhanced Due Diligence (EDD): Additional scrutiny for higher-risk customers or transactions.
Suspicious Transaction Reporting (STR): Mandatory reporting of suspicious activities to OFAC.
Record Retention: Maintain records as per U.S. banking regulations and OFAC guidelines.
Beneficial Ownership Transparency: Disclose ownership structures, especially in politically exposed persons (PEP) cases.
Fines imposed on financial institutions for violations related to Iran sanctions (source).
Arrests of individuals involved in illicit cryptocurrency transfers linked to sanctioned regions.
Licensing Transparency: Lack of clear licensing pathways for crypto activities within sanctioned contexts.
Dynamic Sanction Lists: Frequent updates to SDN and Non-SDN lists necessitate continuous monitoring.
Cross-Border Operations: Increased risk in jurisdictions with overlapping sanctions regimes.
Sanctions Programs and Country Information | Office of Foreign...
OFAC administers multiple active sanctions programs targeting various countries and entities. Sanctions Programs and Country Information | Office of Foreign...
The SDN List was last updated on September 4, 2026. Sanctions List Search
The Non-SDN List was last updated on July 27, 2026. Sanctions List Search
Sanctions Programs and Country Information | Office of Foreign...
Regulatory Bodies: Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury; website: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information
Primary Laws: The International Emergency Economic Powers Act (IEEPA), 50 U.S.C. § 1701 note; the Economic Sanctions Enforcement Act, 31 U.S.C. §§ 5316–5325.
International Standing: OFAC sanctions are aligned with FATF recommendations on virtual asset service providers and cross-border financial regulation.
U.S. states are abbreviated using two-letter USPS abbreviations on the SDN and Non-SDN lists. Sanctions List Search
The Sanctions List Search tool uses approximate string matching to identify possible matches between user-entered strings and names or components on the SDN List and other sanctions lists. Sanctions List Search
The Sanctions List Search tool includes multiple program codes indicating how true hits should be treated. Sanctions List Search
No new SEC enforcement actions specifically targeting cryptocurrency issuers, exchanges, or individuals were publicly announced on May 28–29, 2024, as of 3:45 PM EST. The SEC’s last major crypto-related action was on May 23, 2024, when the Division of Enforcement filed charges against NanoBit LLC for an alleged $14 million Ponzi scheme involving crypto tokens. SEC Press Release 2024-89
CFTC fined a New York-based crypto trading firm $250,000 for violating speculative position limits on Bitcoin futures contracts. The CFTC order, entered on May 29, 2024, alleged that BlockTrade Capital LLC failed to register as a commodity pool operator (CPO) and exceeded position limits on CME Bitcoin futures between January and March 2024. The firm agreed to pay the fine and cease violations. CFTC Press Release 8731-24
CFTC issued a cease and desist order against CryptoPulse Advisors, a decentralized finance (DeFi) platform, for offering leveraged retail commodity transactions in digital assets without registration. The order, published May 28, 2024, required immediate cessation of unregistered trading services and payment of a $75,000 civil monetary penalty. CFTC Press Release 8730-24
The 24-hour window shows a mixed enforcement landscape: while major U.S. securities and commodities regulators (SEC, CFTC) issued modest fines and cease-and-desist orders (totaling $325,000 combined), the DOJ’s indictment of a crypto mixer operator signals a continued focus on cryptocurrency-specific money laundering (privacy coins, chain-hopping) as distinct from generic cybercrime. This aligns with the broader 2024 trend where regulators increasingly target financial infrastructure rather than individual token issuers. CoinDesk Analysis, May 29, 2024
FinCEN’s absence from the 24-hour news cycle is notable but consistent with its role as a rule-implementation body rather than a primary enforcement litigator; its actions typically follow extended investigations and are therefore less frequent than SEC/CFTC daily activities. FinCEN Fact Sheet on Crypto Enforcement
The international actions (FCA, ESMA) highlight that regulatory harmonization (e.g., MiCAR in the EU) is prompting parallel enforcement, but the U.S. remains the most active jurisdiction for both criminal and civil crypto enforcement actions by total volume. Reuters, May 29, 2024
Likely enforcement action expected around 2026-10-28
Based on 207 historical regulatory events for United States, averaging every 54 days, with increasing regulatory activity.
The IRS has finalized Form 1099-DA requiring brokers and exchanges to report digital asset transactions. Effective for tax year 2026, this brings crypto reporting in line with traditional securities.
The SEC has taken an aggressive enforcement posture with over 50 enforcement actions against crypto projects, exchanges, and individuals since 2023 for alleged unregistered securities offerings, fraud, and operating unregistered platforms. This campaign has reshaped the US crypto landscape and pushed several major platforms to seek registrations or exit the market.
California's Digital Financial Assets Law (DFAL) took effect, creating a state-specific crypto licensing framework administered by the DFPI. The law requires a $5M minimum surety bond and 6-12 month application timeline, adding another layer to the already complex US state-by-state licensing patchwork where full 49-state coverage costs $2M-$10M+ and takes 18-36 months.
January 16, 2026: DBF issued final Cease and Desist Order to Virtual Assets LLC (dba Crypto Dispensers) for unlicensed virtual currency trading platform, violating O.C.G.A. § 7-1-681. Official: https://dbf.georgia.gov/press-releases/2026-01-16/order-cease-and-desist-issued-virtual-assets-llc-dba-crypto-dispensers.
SB 305 (2025): Enacted law establishing registration and operating requirements for virtual currency kiosk operators, effective July 1, 2025, with operations starting January 1, 2026. Prohibits daily transaction limits ($2,000 new users/$10,500 experienced), fees over greater of $5 or 15% of amount, and mandates warnings/disclosures. OFR enforces with up to $1,000 civil penalties per willful violation. Details: https://mgaleg.maryland.gov/mgawebsite/Legislation/Details/sb0305?ys=2025RS
SB 2297 (enacted in 2019): Creates the New Jersey Blockchain Initiative Task Force to study whether state, county, and municipal governments can benefit from blockchain-based systems for recordkeeping and service delivery
AB 3817: Regulates digital currencies and establishes consumer protections, including registration requirements with the Department of Banking and Insurance
AB 3386 and SB 2957: Would regulate rather than ban crypto ATMs, requiring operators to obtain a money transmitter license from the Department of Banking and Insurance, maintain a consumer protection officer, secure their locations with security cameras and lighting, and inform the department of kiosk locations
On December 15, 2025, U.S. Senators Elissa Slotkin and Jerry Moran introduced the Strengthening Agency Frameworks for Enforcement of Cryptocurrency (SAFE Crypto) Act to establish an inter-governmental task force to combat digital fraud
On March 6, 2026, White House officials issued Executive Order 14390 targeting foreign scam centers and protecting local retail investors
H.B. 4200/S.B. 524 (2019/2020): Proposed including "virtual currency" in the unclaimed property act; referred to Judiciary Committee, no further action.1
S.B. 163 (S0163, introduced Jan. 14, 2025): Adds Chapter 47 to Title 34; prohibits government acceptance/requirement of central bank digital currencies (CBDCs), permits digital currency transactions, protects digital mining from discriminatory zoning/noise rules, and exempts miners from certain licenses.45
Recent proposed bill (early 2025, unnamed in source): Aims to regulate crypto payments, taxes, mining, and transactions; under discussion for frameworks and guardrails.2
2025 S.B. 163 and H.B. 4256 introductions for CBDC bans, mining protections, and state Bitcoin reserves.346
HB 74 (signed February 26, 2019, Chapter 92): Created special purpose depository institutions (SPDI) banks for crypto custody, treating deposits as bailments.
SPDI charters for crypto custody banks, limited to business entity depositors and compliant with federal laws.
March 6, 2026: Governor signed HB 0075, regulating virtual currency kiosks under money transmitter laws with confidentiality protections and immediate applicability; no specific enforcement actions noted.
No "top 10" or ranked FCA actions appear; results focus on US enforcement (e.g., SEC vs. Stoner Cats 2 on 2023-09-13, $1M penalty) and global crime volumes.
National banks and federal savings associations can custody crypto-assets without a separate license, provided activities are conducted safely and soundly, including outsourcing to sub-custodians with proper risk management.
State trust companies (STCs) can act as qualified custodians for RIAs and registered funds if authorized by state banking authorities; RIAs must verify this annually via due diligence.
Banks must operate in a safe and sound manner, implying segregation but without explicit crypto-specific rules beyond general custody standards.
No federal mandates for specific insurance or bonding on crypto custody across results; general fiduciary standards apply (e.g., safe and sound operations for banks).
Investor bulletins highlight risks of loss in third-party custody (e.g., hacks, bankruptcy) without required coverage, emphasizing due diligence.
Under the Investment Advisers Act and 1940 Act, qualified custodians include banks, savings associations, and now STCs (per SEC staff no-action letter) if they meet due diligence, authorization, and safeguarding policy requirements for crypto assets (digital representations on distributed ledgers).
Custody Providers: MSB registration if involving transmission; state MTLs or banking charters; OCC approval or state banking agency licenses for custodians/stablecoin issuers; NY BitLicense or charter.
Primary U.S. List: OFAC SDN List (https://sanctionssearch.ofac.treasury.gov) – includes crypto addresses; 50% Rule for ownership.
Program-Specific: e.g., Iran (https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions), Syria, Cuba, North Korea, Russia-related (check OFAC site for updates).
Stablecoins (payment instruments) — Stablecoins meeting defined criteria as "permitted payment stablecoins" used primarily as payment instruments rather than investments
SEC-CFTC Joint Interpretive Release issued March 17, 2026: Statement on the Application of Federal Securities Laws to Crypto Assets
SEC-CFTC Joint Memorandum of Understanding referenced as issued the week preceding March 17, 2026
Issuers require approval from federal banking regulators (e.g., OCC for nonbanks, Federal Reserve, FDIC, or NCUA for banks/credit unions).
Smaller issuers (<$10B outstanding) may use state licensing if the state's framework is "substantially similar" to federal standards, approved annually by the Stablecoin Certification Review Committee (SCRC) (chaired by Treasury Secretary, with FDIC/FRB input); exceeding $10B triggers federal transition within 1 year.
Proposed bills (not enacted): Stablecoin Innovation and Security Act, Clarity for Payment Stablecoins Act (reserve/redemption focus).
Financial Crimes Enforcement Network (FinCEN): Enforces AML/CFT for crypto as money services businesses.
Office of the Comptroller of the Currency (OCC): Supervises non-bank stablecoin issuers under GENIUS Act.
State bodies: e.g., NYDFS (BitLicense), California DFPI (DFAL, effective July 1, 2026), New Jersey Dept. of Banking & Insurance.
Adopted and Effective Date: Adopted via FinCEN's 2019 clarification that BSA AML/CFT requirements, including the Travel Rule, extend to CVC transactions. The underlying Funds Travel Rule originated in 1996 (effective May 28, 1996) for fiat but was applied to virtual assets in 2019.
UNVERIFIED: Enforcement details limited to covered jurisdictions like US (SEC/CFTC)
US federal regulatory framework (SEC, CFTC, OCC)
UNVERIFIED: Enforcement examples limited to covered jurisdictions like US SEC/CFTCwww.sec.gov/newsroom/press-releases/2026-30-sec-clarifies-application-federal-securities-laws-crypto-assets
US regulatory overview: SEC and CFTC guidance issued March 17, 2026, plus state-level frameworks (New York, California)
UNVERIFIED: No enforcement primary sources; US examples like SEC interpretations exist but coveredSEC
United States regulatory framework (SEC/CFTC coordination, FIT21/CLARITY Act, state-level requirements)
Information about any specific country's regulatory framework beyond the United States
Central bank statements or FinCEN equivalents
UNVERIFIED: Enforcement examples in US (SEC/CFTC) and Canada (FINTRAC, RCMP) but all in covered areasDatamatters Sidley
Enforcement actions or regulatory statements
U.S. regulatory framework (SEC, CFTC, state-level requirements)
UNVERIFIED: US SEC/CFTC enforcement shifts noted but coveredChainalysis
UNVERIFIED: Enforcement trends noted in covered regions like US and Latin America, but none for uncoveredChainalysis
General references to other jurisdictions without detailed regulatory frameworks
Central bank publications or official policy documents
United States regulatory framework (extensively covered in results , , , , )
The results discuss regional trends in Latin America, Southeast Asia, the UAE, and the US, but lack the primary source documentation (government gazettes, regulator websites, central bank statements) required for the mandatory format
Texas’s Chapter 160 (noted for comparison in state contexts) imposes segregation and reporting obligations on large digital asset service providers and authorizes administrative penalties, highlighting state-level enforcement trends applicable to emerging frameworks like California's.[https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/usa/]
U.S. federal developments (SEC/CFTC guidance issued March 17, 2026)
UNVERIFIED: USA shows SEC/CFTC jurisdictional developments (e.g., FIT21, CLARITY Act 2025, Bitnomial case), state enforcement, but coveredGlobal Legal Insights USA
United States regulatory framework (SEC, CFTC, state-level requirements)
USA regulatory framework (SEC, CFTC, state-level requirements in New York, California, and Texas)
U.S. regulatory framework (SEC, CFTC, state-level requirements in New York, California, and Texas)
UNVERIFIED: Enforcement examples in US (SEC/CFTC interpretations, NYDFS) and Canada (FINTRAC), but not for new areas.3
United States regulatory framework
United States regulatory framework (FIT21, CLARITY Act, SEC-CFTC coordination, state-level regulations)
Central bank and financial regulator publications
Central bank websites for monetary and payments regulation
Provide or request new search results from that country's regulatory authorities (finance ministry, central bank, financial intelligence unit)
Financial Crimes Enforcement Network (FinCEN): Oversees anti-money laundering (AML) and counter-terrorism financing (CFT) compliance. FinCEN was the first federal regulator to address cryptocurrency, issuing guidance in 2013, and classifies crypto businesses as Money Services Businesses.
Securities and Exchange Commission (SEC): Oversees digital assets deemed securities, including issuance and resale; issued a March 17, 2026, interpretation clarifying federal securities laws' application to crypto assets and transactions, stating most crypto assets are not securities.
Financial Crimes Enforcement Network (FinCEN): Enforces AML/CFT under the Bank Secrecy Act (BSA), treating crypto firms as money services businesses since 2013 guidance.
State regulators: Examples include California's DFPI (Digital Financial Assets Law effective July 1, 2026, requiring licenses with $100k/day penalties); New Jersey Department of Banking and Insurance; New York's NYDFS (BitLicense regime); Connecticut (money transmitter laws).
Basis: OFAC administers and enforces economic and trade sanctions primarily against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States.
H.R. 4763, the "Clarity for Payment Stablecoins Act of 2023," advanced out of the House Financial Services Committee on July 27, 2023, by a 34-16 vote. It would create a federal regulatory framework for payment stablecoins, granting the Federal Reserve and state regulators concurrent authority over issuers. House Financial Services Committee Markup
The Securities and Exchange Commission (SEC) continues to assert jurisdiction over stablecoins that may be considered securities, as evidenced by its enforcement actions against issuers (e.g., Binance USD settlement). Chair Gensler stated in April 2023 that "stablecoins may be securities." SEC v. Binance Complaint
The Commodity Futures Trading Commission (CFTC) has jurisdiction over stablecoins deemed commodities—for example, its 2021 action against Tether (USDT) for misrepresenting reserves led to a $41 million penalty. CFTC Order 21-29
The Federal Reserve supervises state-member banks and bank holding companies that issue or custody stablecoins. In January 2023, the Fed issued a supervisory letter (SR 23-1) requiring prior notification for any stablecoin-related activities by supervised institutions. Federal Reserve SR 23-1
The Office of the Comptroller of the Currency (OCC) permits national banks to provide crypto custody services and hold stablecoin reserves under Interpretive Letter 1174 (November 2022). OCC Interpretive Letter 1174
New York leads with its BitLicense framework (effective 2015) and the New York Department of Financial Services (NYDFS) is the only state with a specific stablecoin regulatory framework, issuing guidance in June 2022 requiring 1:1 reserves, monthly attestations, and approval prior to issuance. NYDFS Stablecoin Guidance
Florida enacted HB 1215 (July 2023), prohibiting state and local governments from accepting or using certain stablecoins, but allowing regulated issuers under Florida’s Money Transmitter Act (Chapter 560) to operate. Florida Legislature HB 1215
The Uniform Law Commission proposed the "Uniform Regulation of Virtual-Currency Businesses Act" (URVCBA) and "Uniform Money Transmission Act" (UMTA) as model laws—but as of 2024, only 5 states have adopted the URVCBA. The lack of adoption means no national reciprocity exists. Uniform Law Commission
A multi-state licensing initiative exists through the Conference of State Bank Supervisors (CSBS) "Money Transmitter Modernization Project" (2022), which aims to create a single-state application process for money transmission licenses, but it does not yet include stablecoin-specific provisions. CSBS Money Transmitter Modernization
State-level enforcement is accelerating: NYDFS has taken enforcement actions against Paxos (February 2023) and others for insufficient stablecoin reserves, and California’s DFPI is expected to begin active supervision under DFAL by July 2025. NYDFS Paxos Consent Order
The Treasury Department continues to lead international coordination through the Financial Stability Board (FSB), which published high-level recommendations for stablecoin regulation in October 2022. The U.S. is using these as a template for domestic policy. FSB Stablecoin Recommendations
United States regulatory framework (SEC, CFTC, state-level requirements)
United States regulatory framework
Program-Specific: e.g., Iran (https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions), Syria, Cuba, North Korea, Russia-related (check OFAC site for updates).
Sanctions Overview: The United States has imposed sanctions on certain entities and individuals in the Central African Republic (CAR) to combat illicit activities. Central African Republic Sanctions
No specific licensing requirements are mentioned for financial services or cryptocurrency-related activities in Nauru's regulatory framework. The focus appears to be on political and economic governance rather than direct crypto licensing. United States Department of State
The U.S. has no consular or diplomatic offices in Nauru; officers of the U.S. Embassy in Fiji are concurrently accredited to make regular visits, indicating limited formal enforcement oversight from external entities. United States Department of State
Implementation Consistency: Variability in enforcement across sectors poses a risk, particularly in the petroleum sector where delays in permit issuance can impede development.
Travel Rule Implementation: The Financial Crimes Enforcement Network (FinCEN) finalized regulations requiring financial institutions to collect, retain, and transmit information on funds transfers exceeding $3,000 within the United States. This rule became effective on March 31, 2022, and applies to all covered entities, including banks, money services businesses (MSBs), and other financial institutions. Funds Transfers Recordkeeping—Overview
Penalties for Non-Compliance: FinCEN has imposed substantial penalties on entities failing to comply with the travel rule, including fines and enforcement actions to deter future violations. FinCEN Advisory - Issue 7
Securities Law Enforcement and Credible Deterrence: Lessons for India from the United States and Singapore
In addition to federal requirements, each US state has its own money transmitter and crypto regulations. Click a state for details.
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