Last year in September, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) final rule, which would have imposed certain anti-money laundering and combating the financing of terrorism (AML/CFT) program and other Bank Secrecy Act-related obligations on investment advisers (IA AML Rule) effective January 1, 2026.

2025 is shaping up to be a pivotal year for the regulation of digital assets in the UK. As the European Union’s Markets in Crypto-Assets is reshaping the EU’s regulatory landscape by introducing a unified framework for crypto-asset service providers, the UK Financial Conduct Authority is advancing its own agenda, guided by its Cryptoasset Roadmap, to ensure regulatory clarity while supporting innovation. 

On July 18, 2025, President Donald Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act or the Act), following its bipartisan passage by the Senate on June 17 (68–30) and the House on July 17 (308–122).