Policy
Policy
FinCEN Wants Banks to Block a List of Companies It Won't Publish
FinCEN's proposed rule against Russia's A7 Network, scheduled for the Federal Register on October 5, names six Dubai trading firms and then says the operative list of banned “Sub-Agents” will reach 347,926 covered institutions only through its secure FI-Portal, because publishing it would let the network swap in new companies. The two earlier section 9714 actions were orders against single exchanges; this one is a notice-and-comment rule against a class of transactions, and it counts the ruble stablecoin A7A5 as convertible virtual currency.
Policy
Two Days Before It Shrank to Two Commissioners, the SEC Made One a Quorum
Hester Peirce's last day was October 2. The same day, a rule dated September 30 took effect letting a single commissioner constitute a quorum on any matter from which every other sitting commissioner is disqualified, a step the Commission said in 1995 it did not think necessary. It was adopted without notice or comment. The agency now has two members, three vacancies, no nominee, a crypto custody proposal one day old and a crypto offering rule whose comments close October 20.
Policy
Tokenized Stocks and Treasuries Are Defined Out of the SEC's October 20 Crypto Rule
Regulation Crypto Assets, whose comment period closes October 20, covers only investment contracts tied to crypto assets that are not themselves securities. Tokenized stocks, Treasuries and funds are excluded by definition; whether on-chain venues may trade more than tokenized stock is a question the SEC asked in a separate order, File No. 4-927, with no closing date stated.
Policy
'No Problem': Kelp Takes LayerZero's 2024 Answer to a Vancouver Court
Evercrest, the company behind KelpDAO, is suing LayerZero and Bryan Pellegrino in British Columbia over April's $292 million rsETH exploit, citing a 2024 message and LayerZero's own May admission that it made a mistake. Pellegrino calls the claim meritless.
Market structure
Tokenize a Treasury at DTCC and It Stops Counting as Collateral
DTC's tokenization service launches in October on the authority of a December 2025 SEC staff letter rather than a statute — and the letter withdraws itself three years after launch. Its conditions also say that a tokenized entitlement carries no collateral value and no settlement value for Net Debit Cap or Collateral Monitor purposes, which is the sharpest limit on the pilot and the one the press releases do not mention.
Ratings and risk
S&P Global Is Buying the Auditor Behind $37 Trillion in Transfers
S&P Global signed an agreement on September 17 to acquire OpenZeppelin, whose Contracts libraries have underpinned more than $37 trillion in value transferred and whose audits function as the industry's seal of approval. The firm keeps its name and chief executive, who will report to the president of S&P Global Ratings. The libraries are MIT-licensed — the one commitment in the deal that nobody needs permission to enforce.
Enforcement
Two Robinhood Engineers' Hyperliquid Wallets Led Back to Exchange Accounts in Their Names
The Southern District of New York unsealed complaints on September 15 charging Robinhood engineers Hefu Chai and Huaisong Xiang with commodities fraud and wire fraud. Prosecutors say the two used a confidential listings Slack channel to trade Hyperliquid perpetuals ahead of Robinhood Crypto announcements, each making more than $50,000. The complaints say the FBI linked Chai's three wallets to an exchange account he opened in 2017, and that Xiang funded his wallet with 18 ether from his own account the day before a POPCAT listing.
Market structure
Tillis Voted No to Keep a Second CLARITY Vote Possible
Senate roll call vote 234 rejected cloture on the motion to proceed to H.R. 3633, 49 to 50, with all 49 yes votes from Republicans and Collins, Hawley, Moran and Tillis voting no. The Senate Press Gallery log records that Tillis voted no in order to make a motion to reconsider, and made it at 3:01 p.m. Under the practice CRS describes, that allows a second cloture vote without a new petition, though it still needs 60.
Sanctions
Fifteen Months From Tether's Freeze to a Forfeiture Filing
The Southern District of New York filed on September 14 to forfeit 61,192,367.59 USDT it says came from black-market Iranian oil, moved through Hong Kong firms Blessed Trust and Hexa Whale trading on Binance. The complaint's own table shows Tether froze all ten TRON addresses on June 15 and July 26, 2025. It alleges the wider "Entity A" cluster moved more than $1.5 billion and that Company-1 wired $443.49 million to Blessed Trust through a New York correspondent account.
Market structure
Three Clauses Now Decide What Counts as Decentralized
The 630-page CLARITY Act substitute posted on September 10 defines a "non-decentralized finance trading protocol" by three tests — control, off-code operation, or the power to restrict users — and writes that definition in twice, once for SEC rulemaking and once for the CFTC. The text directs rules on how controlling persons comply "including with respect to registration," bars treating code itself as a registrant, and exempts security-council emergency measures only if they are disclosed in advance. The ethics section is largely unchanged; cloture is Tuesday.
Standards
Visa and Mastercard Will Accept an Agent That Ant Already Cleared
Ant International, Visa and Mastercard said in São Paulo on September 10 that they would build a Know Your Agent interoperability framework, so an AI agent vetted by one participant need not be vetted again by the next. Each arrives with its own scheme already running — Visa's Trusted Agent Protocol, Mastercard's Verifiable Intent, Ant's Agentic Mobile Protocol. No specification, governance body or timeline was published, and liability went unmentioned.
Charters
Block Wants a Bank That Takes No Deposits and Makes No Loans
Block filed with the OCC on September 8 to establish Builders Bank & Trust, N.A., an uninsured national trust bank that would custody bitcoin and stablecoins without accepting deposits or lending. It is the fortieth de novo application the agency has received since 2025 — against 48 across the whole of 2011 to 2024 — of which 21 have been approved and 2 denied.
Stablecoins
Twenty-One Banks Have a Stablecoin Plan, a Launch Window, and No Name
Bank of America, Citi, Goldman Sachs, Deutsche Bank, UBS and sixteen others say a dollar token arrives in the first half of 2027 — timed to the GENIUS Act switching on. The company does not exist yet, the chain is unchosen, the reserve model is unsettled, and the only named parties are the two consultancies, which cannot bind anyone.
Cryptography
Nobody Said 'Blockchain' in the G7's Quantum Warning
The G7 Cybersecurity Working Group's September 3 call to action tells governments to inventory their cryptography and start migrating off public-key schemes. It never mentions cryptocurrency — and it does not have to, because the exposure it describes is the signature math every chain runs on. Bitcoin's answer has no activation date; Ethereum's has a 2029 target; Solana already has a hash-based vault in production.
Bank charters
OpenReserve Needs $210 Million by September 2027 to Open Its Approved Bank
The OCC gave a blockchain settlement startup preliminary approval for a full-service insured national bank — then required $210 million in paid-in capital, roughly eight times its seed round, and a 12% Tier 1 leverage ratio for three years against an ordinary expectation near 5%. The stablecoin subsidiary that carries the business case has not filed an application at all.
Market structure
The Vote Is Set. The Text Isn't Finished
The Senate takes its first procedural vote on the CLARITY Act on September 15. Cloture needs sixty, at least seven of them from outside the majority — and the ethics, illicit-finance and stablecoin provisions that stalled the bill in July are still open.
Proposed Monday
Forty Years On, the SEC Reopens the Record of Who Owns What
Transfer agents keep the official list of who owns which share, under rules untouched since the Carter administration. The SEC’s rewrite names blockchain directly — and asks whether a distributed ledger can be the register itself.
In court Tuesday
The Two Firms That Count Crypto Crime Are Suing Each Other
ICE decided in fifteen days that only one company could trace blockchains for it. Chainalysis is asking the Court of Federal Claims to call that unlawful — and the fight exposes how the government buys its picture of the chain.
Legislation
California Wrote a Meme Coin Ban It Can Only Half Enforce
AB 2409 passed 40-0 and 78-0 and sits with the governor. The reported "TRUMP exemption" is not in the text — what is there is a state mapping the edge of its own jurisdiction.
Policy · Analysis
The Ninth Circuit Read Kalshi's Marketing Back to It
A published opinion says sports event contracts are sports bets no matter what a federally regulated exchange calls them — and three things the headlines missed.
Regulation
The Bank of England Gets a Second Job: Making Stablecoins Work
Payments and stablecoin innovation become a statutory objective, reported annually to Parliament; systemic regime live 2027.
The Ledger
H1 2026 by the Numbers: 207 Hacks, $972M, and a Rising Machine Tempo
The worst half-year in TRM's dataset — before AI-scaled attacks fully arrive. Expect the enforcement and regulatory response to follow the loss curve.