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Global Digital Assets Digest: February 2025

19 February 2025

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    Welcome to this month's Global Digital Assets Digest. In this edition, we have communications from the ESAs in relation to MiCA, as well as the finalisation of supporting legislation. In the UK, there are communications from the FCA on financial promotions. In APAC, there are important updates for virtual asset trading platform operators. Stateside, the new administration has signalled a significant shift in approach to regulation with an Executive Order.

    1. BIS: Speech by Burkhard Balz: Envisioning tomorrow - the role of CBDCs in Europe's digital financial ecosystem

    2. BIS: Speech by Christopher J Waller: Reflections on a maturing stablecoin market

    3. BIS: Interim report on Project Rialto

    4. MiCA: Delegated Regulations published in the Official Journal

    5. European Commission legislative proposal for shortened settlement cycle in the EU

    6. BIS: Remarks by Ms Derville Rowland, Deputy Governor of the Central Bank of Ireland: Innovation and technology in financial crime

    7. ECB decision on non-bank PSPs' access to central bank operated payment systems and central bank accounts published in OJ

    8. MICA: EBA Opinion on Conflicts of Interest for issuers of ARTs

    9. MICA: ESMA factsheets on crypto lending and on DeFi

    10. MICA: ESMA Opinion on RTS concern conflicts of interest for cryptoasset service providers

    11. FSB: Work Programme for 2025

    12. ECB: Report on 15th T2S Harmonisation Progress Report

    13. MICA: ESMA Statement on the provision of certain cryptoasset services in relation to non-MiCA compliant ARTs and EMTs

    14. ECB: Slides on the role of central bank money in digital payments and digital finance

    15. ECB: Call for expression of interest: TIPS cross-currency service

    16. Joint UK-EU Financial Regulatory Forum: Statement on third meeting

    17. FCA: Financial Promotions update

    18. BoE: Financial Market Infrastructure (FMI) regulation in a changing world: our priorities for 2025 − speech by Sasha Mills

    19. Accelerated Settlement Taskforce UK: UK Implementation Plan for first day of trading for T+1 settlement

    20. HM Treasury: Policy paper: UK-Japan Financial Regulatory Forum Joint Statement 2025

    21. The Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025 (SI 2025/93)

    22. BoE: Minutes: CBDC Academic Advisory Group – December 2024

    23. FMLC: Minutes for the FMLC Committee Meeting in December 2024

    24. BIS: Speech by, Governor of the National Bank of the Republic of North Macedonia, at the Workshop on Technical and Legal Aspects of Joining SEPA Payment Schemes

    25. AMF & ACPR: Consultation on smart contract certification in DeFi

    26. AMF: Amendments to the General Regulation reflecting MiCA

    27. BaFin-Publication: "Crypto asset service providers: the simplifications and challenges that now exist

    28. AMF awarded by International Association for Trusted Blockchain Application (INATBA) for its innovative approach to digital asset regulation

    29. HKMA: Targets for 2025

    30. SFC: Findings and expected standards for VATP operators

    31. SFC: Details announced on new licensing process for new VATP applicants

    32. Singapore: MAS publishes details of Global-Asia Digital Bond Grant Scheme (G-ADBGS)

    33. HKMA: Consultation on the prudential treatment of cryptoasset exposures

    34. House Financial Services Committee: Hearing on the future of digital assets

    35. House Financial Services Committee: Discussion Draft for Stablecoins

    36. House of Representatives: Oversight Committee hearing on regulatory approach to digital assets

    37. US Senate: Hagerty: Stablecoin framework

    38. US Senate: Proposed legislation on US CBDC

    39. FDIC: Release of documents on cryptoassets supervision

    40. SEC: Recission of SAB 121

    41. White House: Executive Order - Strengthening American Leadership in Digital Financial Technology

    42. SEC: Cryptoassets Taskforce launched

    43. Regulatory agencies: Changes to leadership

    44. US Senate: Tim Scott announces Banking Committee Priorities for the 119th Congress

    45. FT: Article on launch of memecoins

    Updates and Guidance: International Bodies

    1. BIS: Speech by Burkhard Balz: Envisioning tomorrow - the role of CBDCs in Europe's digital financial ecosystem

    On 13 February 2025, BIS published a speech by Burkhard Balz, Member of the Executive Board of the Deutsche Bundesbank, at the Frankfurt Digital Finance Conference. The speech looks at the challenges posed to central banks by the emergence of new forms of payments and the work that the Eurosystem is undertaking to mould Europe's digital financial ecosystem. The also speech explores key motivations behind a retail CBDC in Europe. Turning to wholesale CBDC, Balz refers to a recent initiative undertaken by the Eurosystem testing new technologies for wholesale central bank money settlement. Balz confirms the Bundesbank's participation, which involved a "Trigger solution" bridge between DLT platforms and the TARGET payments system. The speech also confirms that in relation to wholesale CDBC, the current focus is on a short-term wholesale solution to respond to immediate demands of the market. Lastly, Balz, summarises the work that the ECB has undertaken in relation to B2B payments.

    2. BIS: Speech by Christopher J Waller: Reflections on a maturing stablecoin market

    On 13 February 2025, BIS published a speech by Mr Christopher J Waller, Member of the Board of Governors of the Federal Reserve System, at A Very Stable Conference, San Francisco, California. The speech looks at the use cases of stablecoins and challenges that need to be overcome in order for stablecoins to meet their full potential. Waller also explores the issue of fragmentation, noting that many blockchain networks appear distinct from one another, with firms looking for technical solutions to achieve cross-chain interoperability. Waller notes the absence of a regulatory framework for stablecoins in the US, adding that regulatory fragmentation could impede efforts by U.S. dollar stablecoin issuers to operate at a global scale. Waller also notes that different regulatory regimes appear to be imposing separate reserve asset and redemption requirements for stablecoin issuers, arguing that this would lead to stablecoin issuers having to issue the same stablecoin under various regimes with separate reserve asset and redemption requirements in order to be able to operate on a global scale. The speech also notes that the MiCA regime enables stablecoin issuers to earn interest on their reserve assets, whereas some regulatory models would require reserves for stablecoins deemed systemically important to be held as non-interest-bearing central bank deposits.

    The speech also refers to efforts in the US to regulate stablecoins, noting that most efforts in this regard have been at the state level and the potential for state regulation to conflict and therefore reduce stablecoin scalability. The speech calls for consistency at the federal level to allow federal authorities to coordinate effectively with foreign counterparts.

    3. BIS: Interim report on Project Rialto

    On 13 February 2025, the BIS Innovation Hub published an interim report on Project Rialto, an initiative examining FX and settlement-related frictions in retail cross-border payments. The project aims to show how an automated FX conversion layer with settlement in central bank money can help simplify the payment chain and reduce a number of risks (e.g. liquidity, credit and settlement), possibility reducing the cost of retail cross-border payments. The report looks at the main features and challenges in the retail cross-border payments market, as well as the main policy and technical aspects. The final report will look at proof pf concept as well as findings from the experiment.

    4. MiCA: Delegated Regulations published in the Official Journal

    On 13 February 2025, a number of Delegated Regulations under MiCA were published in the Official Journal:

    The Delegated Regulations will enter into force in March 2025.

    5. European Commission legislative proposal for shortened settlement cycle in the EU

    On 12 February 2025, the European Commission published a legislative proposal for a Regulation amending the maximum settlement cycle on transferable securities from two business days after trading takes place (T+2) to one business day (T+1). This will be done via an amendment to Article 5(2) of the EU CSDR.

    The proposal follows a November 2024 ESMA report, which recommended that the EU move to T+1 no later than 11 October 2027.

    6. BIS: Remarks by Ms Derville Rowland, Deputy Governor of the Central Bank of Ireland: Innovation and technology in financial crime

    On 6 February 2025, the ECB published remarks by Derville Rowland, Deputy Governor of the Central Bank of Ireland, on how EU legislation will address innovation and technology in financial crime. The speech looks at aspects of the EU AML package finalised in July 2024 see Global Digital Assets Digest July 2024 edition), such as Information Sharing Partnerships and provisions concerning virtual IBANs. Referring to other pieces of EU legislation such as SEPA 2 and the EU Recast Wire Transfer Regulation, Ms Rowland stresses the importance of a holistic approach, as well as avoiding overreliance on traditional supervisory tools.

    7. ECB decision on non-bank PSPs' access to central bank operated payment systems and central bank accounts published in OJ

    On 6 February 2025, Decision (EU) 2025/222 of the ECB on access by non-bank payment service providers to ECB operated payment systems and central bank accounts was published in the EU Official Journal. The decision gives effect to a July 2024 policy paper (see Ashurst Global Digital Assets Digest August 2024 edition) on a harmonised approach to access by non-bank payment service providers (NB-PSPs) to all central bank operated payment systems (i.e. TARGET and retail payment systems operated by euro-area national central banks).

    The development follows the entry into force of SEPA 2, which among other things, amended the Settlement Finality Directive to widen the scope of entities eligible to participate in designated payment systems to include non-bank PSPs.

    The decision will enter into force on 26 February 2025 and will apply in member states from 9 April 2025, the date on which amendments to the Settlement Finality Directive and the revised PSD2 introduced by SEPA 2 are to be transposed.

    8. MICA: EBA Opinion on Conflicts of Interest for issuers of ARTs 

    On 6 February 2025, the ECB announced that Norges Bank was looking into joining

    T2. The ECB's Market Infrastructure Board states that it will work with Norges Bank to look at the feasibility of T2 payments in Norwegian Kroner. In November 2024, Norges Bank and the ECB signed an agreement for Norway to join the TARGET Instant Payment Settlement (TIPS) to settle instant payments in Norwegian kroner.

    On 5 February 2025, the EBA published an opinion (dated 24 January 2025) on the European Commission's proposed amendments to its draft regulatory technical standards (RTS) on conflicts of interest for issuers of ARTs under MiCA.

    This follows the European Commission publishing a set of amendments to the proposed RTS published by the EBA in June 2024.

    9. MICA: ESMA factsheets on crypto lending and on DeFi

    On 5 February 2025, the EBA published an opinion (dated 24 January 2025) on the European Commission's proposed changes to its draft RTS on conflicts of interest for issuers of ARTs under MiCA. These were submitted to the European Commission in a June 204 final report. The EBA confirms no concerns in relation to the majority substantive changes made by the European Commission, with the exception of the proposed deletion of the reference to "risk alignment mechanisms" for remuneration in Article 5.

    The amended draft RTS have been submitted to the Commission for endorsement and will be reviewed by EU co-legislators.

    10. MICA: ESMA Opinion on RTS concern conflicts of interest for cryptoasset service providers 

    On 24 January 2025, ESMA published: a factsheet on recent developments in cryptoassets: crypto lending and staking; and a factsheet on DeFi. The first factsheet summarises the key findings on crypto lending, borrowing and staking outlined in the 2025 joint EBA-ESMA report on recent developments in cryptoassets. The factsheet on DeFi summarises the key findings of the 2025 joint EBA-ESMA report on recent developments in cryptoassets. Areas covered include: the size of DeFi use in the EU and exposure of traditional financial institutions; potential risks associated with DeFi; and the nature of Maximal Extractable Value and its impact on DeFi markets.

    11.  FSB: Work Programme for 2025  

    On 23 January 2025, the FSB published its Work Programme for 2025. The Programme seeks to address challenges that are global in impact, with the FSB confirming that it will focus on (among other areas): the benefits of digital innovation and containing associated risks; and enhancing cross-border payments.

    The FSB plans to continue monitoring the financial stability implications of cryptoassets, tokenisation to promote the implementation of its standards on cryptoasset markets and global stablecoin arrangements. In relation to cross-border payments, the FSB plans to: review progress on addressing frictions related to legal, regulatory and supervisory matters; and carry out deep dives into challenges to achieving the goals of the G20 Roadmap on Cross-Border Payments, including regional-specific issues.

    The FSB has also published an indicative timeline for planned FSB reports, including a thematic peer review of the implementation of its cryptoassets standards (October 2025); and a progress report on G20 Roadmap on Cross-Border Payments and KPI monitoring report (October 202

    12. ECB: Report on 15th T2S Harmonisation Progress Report

    On 22 January 2025, the 15th progress report on the harmonisation of European securities settlement by the Eurosystem’s Advisory Group on Market Infrastructures for Securities and Collateral (AMI-SeC) was published. The report is an update of the 14th T2S Harmonisation Progress Report, published by AMI-SeCo in January 2024, detailing compliance with T2S harmonisation standards across 26 markets (served by 24 T2S CSDs). Harmonisation of post-trade processes is considered to be especially important for financial market integration in Europe.

    13. MICA: ESMA Statement on the provision of certain cryptoasset services in relation to non-MiCA compliant ARTs and EMTs

    On 17 January 2025, ESMA published a Statement on the provision of certain cryptoasset services in relation to ARTs and EMTs with issuers not authorised in the EU (non-MiCA compliant ARTs and EMTs). The statement seeks to promote coordinated actions at the national level and avoid potential disruptions.

    NCAs are expected to ensure compliance by CASPs regarding non-compliant ARTs or EMTs as soon as possible and no later than the end of Q1 2025. CASPs operating a trading platform for cryptoassets are expected to stop making all ARTs and EMTs with issuers not authorised in the EU (non-MiCA compliant ARTs and EMTs) available for trading. CASPs are permitted to maintain cryptoasset services for these products on a “sell only” basis for a longer period, so as to allow conversion/liquidation by EU investors.

    ESMA advises CASPs to raise awareness among EU investors about provisions of MICA concerning non-MiCA compliant ARTs and EMTs and the possibility for best execution to be compromised for investors maintaining holdings in these cryptoassets.

    Comment: Relevant CASPs to note key guidance and dates set out in statement.

    14. ECB: Slides on the role of central bank money in digital payments and digital finance

    On 17 January 2025, the ECB published slides for a presentation delivered by ECB board member, Piero Cipollone, at Crypto Asset Lab conference 2025. The presentation notes the impact of digitalisation and fragmentation on payments and focused on the following areas: the changing retail payment landscape and the ECB’s response; and innovation in wholesale and cross-border payments. In relation to cross border payments, the speech confirms that the ECB will be looking at how TIPS can support the use of the SEPA one-leg out instant payment scheme with selected partners, to allow for instant payments to payees outside the euro area.

    15. ECB: Call for expression of interest: TIPS cross-currency service

    On 17 January 2025 the ECB issued a call for expression of interest for parties interested in supporting the implementation of the TIPS cross-currency service. The TIPS cross-currency service is a joint initiative by the ECB, Sveriges Riksbank and Danmarks Nationalbank and aims to allow participants of TIPS EUR, RIX-INST and TIPS DKK3 to settle cross-currency payments instantaneously on accounts with their central banks. Participants are encouraged to consider taking part in: discussions on ways that the TIPS cross-currency service can meet the market requirements; testing activities; and discussions about future enhancements to the TIPS cross-currency service.

    Updates and Guidance: UK

    16. Joint UK-EU Financial Regulatory Forum: Statement on third meeting

    On 13 February 2025, HM Treasury published a statement in relation to the third meeting of the joint UK-EU Financial Regulatory Forum held in February 2025.

    Notable points

    • Cryptoassets regulation. Participants acknowledged the importance of implementing the FSB's regulatory framework for cryptoasset markets and activities, and global stablecoin arrangements.
    • T+1 securities settlement cycle. Parties agreed that it would be beneficial to coordinate given increasing consensus of a T+1 implementation date of 11 October 2027. The chairs of the EU and UK industry taskforces are to participate in their counterpart's taskforce as observers to encourage sharing of information and progress.

    17. FCA: Financial Promotions update

    On 7 February 2025, the FCA published a webpage containing its financial promotions quarterly data for Q4 2024. This summarises the impact of a number of rules in relation to the UK financial promotions regime (the new gateway for regulated firms approving the financial promotions of unregulated firms; the end of the FCA's transitional period in respect of the regime for the financial promotion of cryptoassets; and increased action on finfluencers). The FCA also sets out how it has intervened in relation to authorised and unauthorised firms.

    Comment: Webpage contains useful key messages as well as reference to guidance that the FCA has issued for crypotassets firms which firms may wish to gap against existing processes.

    18. BoE: Financial Market Infrastructure (FMI) regulation in a changing world: our priorities for 2025 − speech by Sasha Mills

    On 10 February 2025, the BoE published a speech by Sasha Mills, Executive Director, Financial Market Infrastructure at the BoE, on priorities for FMI regulation in 2025. Ms Mills states that the BoE's priorities in respect of FMIs are: ensuring FMI services are operationally resilient; safe and sustainable innovation; and financial resilience.

    The speech notes a step change in opportunities and risks arising from technological advances and calls for FMIs and regulators to respond accordingly. FMIs are advised to adapt their risk management strategies and business models in order to manage the new environment.

    Ms Mills also refers to the DSS and plans for a digital gilt instrument (DIGIT), noting the balancing act of enabling innovation, whilst being mindful of other considerations (such as driving growth and protecting financial stability). The speech confirms that the BoE is implementing international standards for systemic stablecoins and will support innovation and enhancements within existing FMI services.

    19. Accelerated Settlement Taskforce UK: UK Implementation Plan for first day of trading for T+1 settlement

    On 6 February 2025, the Accelerated Settlement Technical Group (ASTG) published the implementation plan for the first day of trading for T+1 settlement.

    The implementation plan:

    • recommends that the first day of UK cash securities trading for settlement on a T+1 cycle should be 11th October 2027;
    • sets out the nature of changes that need to be made to the UK CSDR to accommodate transition to T+1; and
    • contains details of a UK T+1 Code of Conduct on recommended actions to enhance market practices and a set of expected behaviours.

    Comment: Movement in the UK and in the EU on the issue of shortening the settlement cycle, with UK and EU appearing aligned on dates. In the UK, the terms of reference for the taskforce on shortening the settlement cycle discussed the case for the UK moving to T+0 and eventually to atomic settlement/instantaneous settlement (noting the impact of blockchain and other technology).

    20. HM Treasury: Policy paper: UK-Japan Financial Regulatory Forum Joint Statement 2025

    On 31 January 2025, HM Treasury and the Japan Financial Services Agency published details about the third meeting of the UK-Japan Financial Regulatory Forum held on Thursday 30 January 2025. Areas discussed include capital markets and digital finance, including an update from the UK and Japan on progress being made in respect of T+1 settlement. The FSA gave an update on cryptoasset developments, with both sides noting the importance of the FSB regulatory framework for cryptoasset markets and activities, and stablecoin arrangements.

    21. The Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025 (SI 2025/93)

    On 30 January 2025, the Financial Services and Markets Act 2023 (Digital Securities Sandbox) (Amendment) Regulations 2025 (SI 2025/93) were published. The Regulations amend the Financial Services and Markets Act 2023 (Digital Securities Sandbox) Regulations 2023 (“the DSS Regulations”), temporarily disapplying aspects of the MLRs applicable to cryptoassets for activities in scope of the DSS. The MLRs would continue to apply to firms outside of the DSS as appropriate.

    Under the current regime, DLT used in relation to activity related to the DSS could be deemed as a cryptoasset service under the MLRs and so require FCA registration.

    For more on the DSS, please see our briefings here and here.

    22. BoE: Minutes: CBDC Academic Advisory Group – December 2024

    On 30 January 2025, the BoE published the minutes of the CBDC Academic Advisory Group (AAG) held in December 2024. The Group noted the publication of the Government's National Payments Vision (see our briefing here) and details contained in the document in relation to the digital pound (see our briefing here). The Group also discussed the BoE/MIT research paper studying the application of privacy-enhancing technologies to a potential digital pound.

    During the meeting, the AAG proposed the setting up of subgroups to consider academic literature on issues relevant to a digital pound. The following presentations were delivered: Payment Initiation and Transaction Costs (Professor Alistair Milne); and Navigating the Future of Money: Case of CBDC (Pinar Ozcan). Pinar argued that many central banks appeared to be waiting for a "second mover advantage" in order to avoid costs of being the first to implement a CBDC.

    A roundtable discussion was also held on the following issues: the recent and future technological innovations likely to improve or disrupt the retail payments industry; the digital pound design features that would best promote innovation in payments and digital finance; and the role innovation in money and payments can play in supporting economic growth.

    23. FMLC: Minutes for the FMLC Committee Meeting in December 2024

    On 2025, the FMLC Committee issued the minutes of the meeting held in December 2024. Issues discussed in the meeting include the FCA timeline for the implementation of the regulatory regime for cryptoassets (see our briefing here) and the Digital Assets Bill.

    Updates and Guidance: Europe

    24. BIS: Speech by, Governor of the National Bank of the Republic of North Macedonia, at the Workshop on Technical and Legal Aspects of Joining SEPA Payment Schemes

    On 6 February 2025, BIS published a speech by Ms Anita Angelovska Bezhoska, Governor of the National Bank of the Republic of North Macedonia, at the Workshop on Technical and Legal Aspects of Joining SEPA Payment Schemes, Skopje. The speech focuses on the importance of cross border payments for advanced and emerging economies and sets out the benefits and challenges posed by the accession of the Western Balkan region to SEPA. This follows North Macedonia submitting an application to join SEPA in July 2024.

    Key points

    • Compliance with SEPA's regulatory and operational requirements requires investment in infrastructure, staff training, and system upgrades.
    • Close cooperation between regulators, financial institutions and all other relevant stakeholders will be needed for SEPA adherence.
    • The banking sector wants to ensure integration with SEPA payment systems by October 2025.

    25. AMF & ACPR: Consultation on smart contract certification in DeFi

    On 3 February 2025, the AMF and the Autorité de contrôle prudentiel et de résolution (ACPR) launched a public consultation on the certification of smart contracts in decentralised finance (DeFi). The consultation follows the publication of a report by the joint working group created under the ACPR-AMF Fintech Forum in 2024, which includes experts from the cryptoasset sector, financial industry representatives, and academics.

    The report explores the feasibility of a smart contract certification framework to reduce user risks, enhance trust, and promote an orderly development of DeFi. The group’s findings focus on technical and operational aspects, including potential certification standards and audit practices. This initiative aims to contribute to European-level discussions on future DeFi regulation, complementing the MiCA framework.

    Stakeholders are invited to submit feedback before 10 March 2025. Contributions will inform the ongoing reflection, with results to be shared later in 2025.

    26. AMF: Amendments to the General Regulation reflecting MiCA

    On 3 February 2025, an order was published approving amendments to the General Regulation of the AMF. The changes affect Books III and VII, notably aligning terminology with the MiCA regulation, which came into force on 30 December 2024, and reflecting updates to the French Monetary and Financial Code from Ordinance No. 2024-936 of 15 October 2024 on crypto-asset markets.

    The transition from the national PACTE regime to MiCA regime involves inter alia replacing references to Digital Asset Service Providers (DASPs) with references to MiCA Crypto-Asset Service Providers (CASPs). These changes to the General Regulation of the AMF will take effect on 30 June 2026, marking the end of the transitional period.

    27. BaFin-Publication: "Crypto asset service providers: the simplifications and challenges that now exist

    On 22 January 2025, the Federal Financial Supervisory Authority (BaFin) published an article (available only in German) outlining the MiCA rules for the authorisation and supervision of CASPs, which came into force at the end of 2024. The article explains the simplifications and challenges faced by crypto-asset service providers operating in Germany, as well as those looking to enter the sector in the future.

    CASPs operating within Germany are obligated to apply to BaFin for a MiCA licence. Upon successful application, the licence holder is permitted to offer their services throughout the European Union without the need for individual member state licences, a privilege facilitated by the EU passporting mechanism. The MiCA authorisation procedure is streamlined for CASPs that are already authorised under the German Banking Act (Kreditwesengesetz - KWG). These service providers may continue to operate under their existing license while awaiting a decision on their MiCA application; however, they can only use the EU passport after they have received the MiCA authorisation. BaFin has conducted a gap analysis comparing MiCA and KWG requirements so that these institutions can focus on new or amended requirements under MiCA. This simplified procedure is advantageous as it reduces the preparation and review effort for these institutions, which have already gained relevant knowledge over the years.

    Conversely, new applicants for MiCA authorisation face several challenges, as they are required to prepare their applications in a thorough manner to meet the stringent requirements of MiCA. It should be noted that any application that is incomplete or inconsistent may be rejected due to the short review periods prescribed by MiCA.

    28. AMF awarded by International Association for Trusted Blockchain Application (INATBA) for its innovative approach to digital asset regulation

    On 15 January 2025, the Autorité des Marchés Financiers (AMF) was awarded the 2025 INATBA Award for the Most Innovative Approach to Regulation of Digital Assets. The award, presented during the INATBA Awards Gala on 29 January 2025 in Brussels, recognises the AMF's efforts to promote a secure and innovative digital asset ecosystem through open consultations on decentralised finance (DeFI) (further detailed below) and its comprehensive licensing approach.

    According to INATBA, this award highlights the AMF’s leadership in balancing investor protection with technological progress, setting a benchmark for forward-thinking regulation in France, Europe, and globally.

    Updates and Guidance: APAC

    29. HKMA: Targets for 2025

    On 22 January 2025, the HKMA announced its 2025 targets, which include prudential work amidst growing digitalisation, for instance Suptech and Fintech promotion by supporting responsible innovation, tech maturity assessment and data-driven, technology-empowered supervision.

    30. SFC: Findings and expected standards for VATP operators

    On 16 January 2025, the SFC published a circular which sets out their findings from inspections on deemed-to-be-licensed virtual asset trading platform (VATP) applicants and the expected standards of conduct for VATP operators. The standards supplement the requirements under the VATP guidelines and cover cybersecurity, client virtual assets and access to platform operators' services.

    31. SFC: Details announced on new licensing process for new VATP applicants

    On 16 January 2025, the SFC published a circular which extends the swift licensing process to new VATP applicants and announced the revamped external assessment model which apply to VATP applicants submitting licence applications after 18 December 2024.

    32. Singapore: MAS publishes details of Global-Asia Digital Bond Grant Scheme (G-ADBGS)

    On 15 January 2025, MAS published details in relation to the Global-Asia Digital Bond Grant Scheme. The initiative seeks to encourage the issuance and adoption of digital bonds in Singapore. MAS states that funding under the scheme will be provided for up to two qualifying digital bond issuances. Elements of a "qualifying issuance " include: issuance on a designated digital asset platform in Singapore; listing on the Singapore Exchange (SGX) /designated digital asset platform; "substantially arranged" by licensed entities in Singapore; and alignment with internationally-recognised digital bond standards.

    This scheme follows developments in Hong Kong, where HKMA launched its Digital Bond Grant Scheme (Hong Kong DBGS)

    For more further details on Digital Bond Grant Schemes in this region, please see our briefings here and here.

    33. HKMA: Consultation on the prudential treatment of cryptoasset exposures

    On 13 January 2025, HKMA issued a letter to consult the banking industry on implementation of the prudential treatment of cryptoasset exposures held by authorised institutions.

    Updates and Guidance: Australia

    Updates and Guidance: North America

    34. House Financial Services Committee: Hearing on the future of digital assets

    On 11 February 2025, the Subcommittee on Digital Asset, Financial Technology, and Artificial Intelligence of the Committee on Financial Services held a hearing. Notable testimonies included that of Timothy Massad, former chairman of the CFTC and Research Fellow at Harvard University in which Massad provides an overview of his involvement in the cryptoasset sector, starting with the CFTC characterising Bitcoin as a commodity. Massad calls for a strong regulatory framework for digital assets and also considers the House's proposed legislation to regulated stablecoins.

    The hearing considered existing use cases for digital assets and blockchain technology, as well as legislation on digital assets, including: the Securing Innovation in Financial Regulation Act (Lucas), an initiative to establish the Securities and Exchange Commission (SEC) Strategic Hub for Innovation and Financial Technology (FinHub); the New Frontiers in Technology (NFT) Act (which clarifies that a covered NFT is not an investment contract nor a transaction in a security; and the Bridging Regulation and Innovation for Digital Global and Electronic (BRIDGE) Digital Assets Act, which sets up a Joint CFTC-SEC Advisory Committee on Digital Assets.

    35. House Financial Services Committee: Discussion Draft for Stablecoins

    On 6 February 2025, House Financial Services Committee Chairman French Hill and Digital Assets, Financial Technology, and Artificial Intelligence Subcommittee Chairman Bryan Steil issued a discussion draft of a bill on a framework for the issuance and operation of dollar-denominated payment stablecoins in the United States. The Stablecoin Transparency and Accountability for a Better Ledger Economy Act of 2025’’ (STABLE Act 2025) builds on work by the former House Financial Services Committee Chair, Patrick McHenry, who tabled the Clarity for Payment Stablecoin Act of 2023. Under the STABLE Act 2025, the OCC would have the authority to approve and supervise federally qualified non-bank payment stablecoin issuers. As part of the Working Group on Digital Assets (further details below), the Committee will work with Senate Banking Committee Chairman Tim Scott and Senators Hagerty and Cynthia Lummis to pass federal payment stablecoin legislation.

    36. House of Representatives: Oversight Committee hearing on regulatory approach to digital assets

    On 6 February 2025, the Subcommittee on Oversight and Investigations of the Committee on Financial Services held a hearing on the approach of regulators to the digital assets sector and access to banking services by crypto firms during 2022-2024 period.

    37. US Senate: Hagerty: Stablecoin framework

    On 4 February 2025 , Senators Bill Hagerty, Tim Scott, Kirsten Gillibrand, and Cynthia Lummis introduced the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This sets out a framework for regulating payment stablecoins. The regime: defines a payment stablecoin as a digital asset used for payment or settlement that is pegged to a fixed monetary value; includes reserve requirements and regulatory standards for stablecoin issuers; applies the Federal Reserve’s regulatory framework to depository institutions and the OCC's framework for non-bank issuers in respect of issuers of more than $10 billion of stablecoins; and allows for state regulation of issuers under $10 billion in market capitalisation.

    38. US Senate: Proposed legislation on US CBDC

    In February 2025, Senator Mike Lee reintroduced legislation, co-sponsored by Senators Ted Cruz and Rick Scott, banning the creation of a US CBDC (No CBDC Act). This follows the Executive Order on digital financial technology signed by President Trump in January 2025 (further details below). The proposed legislation prohibits the Federal Reserve, Treasury Department, or any agency of the federal government from minting or issuing a CBDC; and prohibits the Federal Reserve from holding a CBDC on its balance sheet.

    39. FDIC: Release of documents on cryptoassets supervision

    The FDIC has released documents related to the supervision of financial institutions engaged in crypto-related activities. This follows the release of 25 "pause letters" sent by the FDIC to certain financial institutions in relation to crypto-related activity.

    Chairman of the FDIC, Travis Hill, also issued a statement accompanying the release of the documents. Hill also indicated that the FDIC may replace a 2022 letter requiring notification from FDIC-supervised institutions of crypto-related activity.

    Hill also signalled the FDIC's readiness to engage with President's Trump's Working Group on Digital Asset Markets set up by the Executive Order on Digital Assets Regulatory Framework (further details below).

    40. SEC: Recission of SAB 121

    On 23 January 2025, the SEC published Staff Accounting Bulletin 122 in the Federal Register. This rescinds the guidance in SAB 121. SAB 121, issued in March 2022, required an entity to record a liability on its when obliged to safeguard a cryptoasset.

    In February 2024, a letter from US banking associations (including the American Bankers Association and Bank Policy Institute) called for amendments to the rule. In May 2024, the White House vetoed H.J.Res 109, the joint resolution proposing to nullify SAB 121 (see Global Digital Assets June 2024 edition). In a letter to the SEC, Republicans on the House Financial Services and Senate Banking, Housing, and Urban Affairs Committees, also requested that SAB 121 be rescinded (see Global Digital Assets October 2024 edition).

    41. White House: Executive Order - Strengthening American Leadership in Digital Financial Technology

    On 23 January 2025, the Whitehouse published details on an Executive Order (EO) "Strengthening American Leadership in Digital Financial Technology signed by President Donald Trump. The EO sets out the Trump administration's plans to "to support the responsible growth and use of digital assets, blockchain technology, and related technologies across all sectors of the economy". Measures planned include: safeguarding access and use by citizens and private-sector entities of open public blockchain networks (for lawful purposes); promoting and protecting the sovereignty of the US dollar including via legitimate dollar-backed stablecoins; and encouraging regulatory clarity.

    The EO also bans federal agencies from creating a CBDC and also provides for a Working Group on Digital Asset Markets to set up charged with (among other things): a federal regulatory framework governing the issuance and operation of digital assets, including stablecoins; and possibly creating and maintaining a national digital asset stockpile. The EO also provides for the revocation of the Department of the Treasury’s “Framework for International Engagement on Digital Assets,” issued in July, 2022.

    Comment: This development combined with leadership changes in various agencies signals a significant shift in approach to the regulation of digital assets in US and foreshadows significant activity in relation to the regulation of cryptoassets.

    42. SEC: Cryptoassets Taskforce launched

    On 21 January 2025, the SEC launched a Cryptoassets Taskforce to develop a regulatory framework for crypto assets. The taskforce is to be led by Commissioner Hester Peirce, who noted in a statement that the SEC's previous approach relied on enforcement actions and was reactive, leading to a lack of clarity about the scope of the regulatory framework. The Taskforce will seek to assist the SEC in designing a regulatory framework, providing information on registration and creating appropriate disclosure frameworks. Coordination between the Taskforce and federal departments and agencies (including the CTC, and state and international counterparts) is also envisaged.

    Comment: Following the departure of Gary Gensler, agency will be adopting a new approach to regulating the sector.

    43. Regulatory agencies: Changes to leadership

    On 23 January 2025, the SEC announced that Mark T. Uyeda had been designated as Acting Chairman of the SEC. On 20 January 2025, the CFTC announced that Commissioner Caroline D. Pham had been elected as Acting Chairman of the CFTC. The OCC announced in February 2025 that Robin Hood had been appointed as Acting Comptroller of the Currency following the departure of Michael J. Hsu.

    On January 20, 2025, Travis Hill became Acting Chairman of the FDIC, issuing a statement on his approach to supervision. Among other things, Hill confirmed a review of regulations, guidance, and manuals, as well as more openness to innovation and technology adoption. The statement also confirmed more transparency towards fintech partnerships and to digital assets and tokenisation.

    According to a number of sources, Jonathan McKernan will lead the Consumer Financial Protection Bureau (who would replace Acting Director, Russell Vought), following the departure of Rohit Chopra in January 2025.

    44. US Senate: Tim Scott announces Banking Committee Priorities for the 119th Congress

    On 15 January 2025, Chairman Tim Scott published the US Senate Committee on Banking, Housing, and Urban Affairs legislative and oversight priorities for the 119th Congress. Chairman Scott sets out plans for a regulatory framework for the trading and custody of digital assets. The statement confirms that the committee will promote "an open-minded environment for new, innovative financial technologies". Details of a Senate Banking Subcommittee on Digital Assets in the 119th Congress were also announced, with Senator Cynthia Lummis expected to serve as chair. Areas of focus for the subcommittee include passing bipartisan digital asset legislation; and oversight over Federal financial regulators to prevent regulatory overreach.

    Updates and Guidance: Middle East

    Press/Articles

    45. FT: Article on launch of memecoins

    This article reports on reception to the launch of a meme coin by President Trump ($TRUMP) and the launch of $Melania. The article reports that this against the backdrop of a more crypto friendly stance in comparison to the previous administration. The article notes an attempt by the cryptoassets industry to build trust and also reports on reaction to the launch of coins in political circles.

    Contributors: Francesco Assi, Senior Associate;  Tobias Bauerfeind, Senior Associate; Anne He, Associate; Anson Chan, Associate; Cornelius Hille, Associate; Sasha Sawant, Trainee; Joeil Lorimier Benkada, Trainee;  Laura Wagner, Trainee

    The information provided is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to.
    Readers should take legal advice before applying it to specific issues or transactions.

    Key Contacts