Editor’s note: Our Regulatory Updates series highlights the latest regulatory, legal, and policy happenings relevant to the crypto industry, curated by the a16z crypto regulatory team.
Regulatory Update: October 27 – November 24, 2025
tl;dr
- U.S. Senate Committee on Agriculture, Nutrition, and Forestry Chairman John Boozman (R-Ark.) and Senator Cory Booker (D-N.J.) released a digital asset market structure legislation draft.
- The IRS issued a revenue procedure that describes a safe harbor for trusts that otherwise qualify as investment trusts under § 301.7701-4(c) and as grantor trusts to stake their digital assets without jeopardizing their tax status as investment trusts and grantor trusts for federal income tax purposes.
- Chairman Paul S. Atkins discussed the SEC’s approach to digital assets and “Project Crypto,” focusing on three themes: (1) the importance of a clear token taxonomy, (2) how Howey applies in a way that recognizes the fact that investment contracts can come to an end, and (3) what that could mean in practice for innovators, intermediaries, and investors. He also addressed three categories of tokens that are not securities, including: (1) digital commodities, or “network tokens,” (2) digital collectibles, and (3) digital tools.
Federal
🌽 Commodity Futures Trading Commission
- Acting Chair Caroline D. Pham discussed the CFTC’s Crypto Sprint and other issues at the FIA EXPO.
🦅 Congress
- As mentioned in “tl;dr,” U.S. Senate Committee on Agriculture, Nutrition, and Forestry Chairman John Boozman (R-Ark.) and Senator Cory Booker (D-N.J.) released a digital asset market structure legislation draft.
- House Representative Warren Davidson (R-Ohio) introduced the Bitcoin for America Act, which would “allow Americans to pay federal taxes in Bitcoin and direct all such payments into the Strategic Bitcoin Reserve.”
- Senator Elizabeth Warren (D-Mass.) and others sent a letter to Attorney General Pamela Bondi and Treasury Secretary Scott Bessent requesting “information on how President Trump’s pardon of former Binance CEO Changpeng Zhao will impact [their departments’] ability to hold criminals accountable.”
- Senators Elizabeth Warren (D-Mass.) and Jack Reed (D-R.I.) sent a letter to Attorney General Pamela Bondi and Treasury Secretary Scott Bessent to inquire about actions that their departments are “taking to investigate national security risks posed by the U.S. crypto platform, World Liberty Financial, Inc.”
⚖️ Department of Justice
- A federal judge sentenced the CEO and CTO of crypto mixer Samourai Wallet to five and four years in prison, respectively, after they pleaded guilty to participating in a conspiracy to operate an unlicensed money transmitting business.
- A federal judge declared a mistrial in the DOJ’s case against two MIT-educated brothers who had been accused of fraudulently obtaining approximately $25 million worth of cryptocurrency by exploiting a flaw in MEV-Boost.
- An Oklahoma man was sentenced to 60 months in prison and ordered to forfeit more than $1 million and pay more than $170,000 in restitution for his leading role in a cryptocurrency investment fraud conspiracy.
- A former D.C. lobbyist was sentenced to three years probation and ordered to pay $2.2 million in restitution to victims for his involvement in the “AML Bitcoin” scheme.
- A software startup’s former CFO was found guilty of wire fraud for taking and secretly transferring approximately $35 million from his employer to a cryptocurrency platform he controlled as a side business and then losing the funds after the value in his cryptocurrency investments declined to nearly zero.
- A California resident pleaded guilty in connection with his role in a multi-state conspiracy that used social engineering to steal hundreds of millions of dollars in cryptocurrency from victims throughout the United States.
- The founder of a crypto company that operated cryptocurrency ATMs at various locations throughout the United States was indicted for an alleged $10 million money laundering conspiracy.
- The DOJ filed two civil forfeiture complaints against more than $15 million in USDT that the FBI seized from a North Korean military hacking group known as “Advanced Persistent Threat 38.” Four U.S. nationals and one Ukrainian also pleaded guilty in connection with assisting North Korean actors to obtain remote IT employment with U.S. companies.
- The DOJ released its “Annual Report to Congress on Department of Justice Activities to Combat Elder Fraud and Abuse,” which details the Department’s progress in protecting older Americans and holding perpetrators of elder fraud accountable, and discusses cryptocurrency scams.
- The U.S. Attorney for the District of Columbia, together with the Criminal Division of the DOJ, the FBI, and the USSS, established a Scam Center Strike Force, which has tasked agents and attorneys from offices across these agencies to “investigate, disrupt, and prosecute the most egregious Southeast Asian scam centers and their leaders, with a focus on Burma, Cambodia, and Laos.”
🏦 Department of the Treasury
- As mentioned in “tl;dr,” the IRS issued a revenue procedure that describes a safe harbor for trusts that otherwise qualify as investment trusts under § 301.7701-4(c) and as grantor trusts to stake their digital assets without jeopardizing their tax status as investment trusts and grantor trusts for federal income tax purposes.
- OFAC sanctioned eight individuals and two entities for their role in laundering funds derived from a variety of illicit North Korean schemes, including cybercrime and information technology worker fraud. Two of the sanctioned individuals are North Korean bankers who have helped manage funds, including $5.3 million in cryptocurrency, on behalf of OFAC-designated First Credit Bank.
- The IRS updated its frequently asked questions on digital asset broker reporting.
💰 Federal Reserve
- The Court of Appeals for the Tenth Circuit affirmed a district court decision to reject Custodia Bank’s claim that it is entitled to a “master account” and ruled that the relevant statutes grant Federal Reserve Banks discretion to reject master account access requests from eligible entities.
- Governor Stephen I. Miran discussed the implications of stablecoins for monetary policy, stating, in part, that “stablecoins are already increasing demand for U.S. Treasury bills and other dollar-denominated liquid assets by purchasers outside the United States and that this demand will continue growing,” and that “stablecoins may become a multitrillion dollar elephant in the room for central bankers.”
🏦 Office of the Comptroller of the Currency
- The OCC published an Interpretive Letter, confirming that a national bank may pay network fees, i.e., “gas fees,” on blockchain networks to facilitate otherwise permissible activities and hold, as principal, amounts of cryptoassets on balance sheet necessary to pay network fees for which the bank anticipates a reasonably foreseeable need.
📈 Securities and Exchange Commission
- As mentioned in “tl;dr,” Chairman Paul S. Atkins discussed the SEC’s approach to digital assets and “Project Crypto,” focusing on three themes: (1) the importance of a clear token taxonomy, (2) how Howey applies in a way that recognizes the fact that investment contracts can come to an end, and (3) what that could mean in practice for innovators, intermediaries, and investors. He also addressed three categories of tokens that are not securities, including: (1) digital commodities, or “network tokens,” (2) digital collectibles, and (3) digital tools.
- SEC Director of Division of Trading and Markets Jamie Selway discussed “Trust and Trustless Assets” at the SIFMA Market Structure Conference.
🏛️ White House
- President Donald Trump sat for an extended interview with news program “60 Minutes” during which he discussed crypto and his pardon of Binance founder Changpeng Zhao.
State
🐻 California
- The California Department of Financial Protection and Innovation announced that it has taken action against multiple crypto kiosk operators, including Nevada-based LSGT Services, LLC (Coinhub), which must pay a total of $675,000.
International
🇦🇺 Australia
- The Australian Securities and Investments Commission (ASIC) issued updated guidance clarifying how existing laws apply to digital assets.
- ASIC Chair Joe Longo said that “[d]istributed ledger technology that facilitates asset tokenisation could fundamentally transform our capital markets,” and he warned Australia to “innovate or stagnate – to evolve or become extinct.”
🏦 Basel Committee on Banking Supervision
- The chair of the Basel Committee on Banking Supervision told the Financial Times that the “strong increase in stablecoins and how much assets are in that system calls for a different approach” to the global rules on banks’ crypto holdings.
🇧🇷 Brazil
- The Banco Central do Brasil (Brazil’s Central Bank) released a regulatory framework for the provision of virtual asset services and other issues.
🇨🇿 Czech Republic
- The Czech National Bank announced the creation of a $1 million test portfolio that includes bitcoin, a USD stablecoin, and a tokenized deposit.
🇪🇺 European Union
- In a statement to the European Parliament’s Economic and Monetary Affairs Committee, ESMA Chair Verena Ross said that ESMA’s position “has always been crystal clear: crypto-assets remain very risky,” and she advocated for EU-level supervision for “newly supervised markets such as for large crypto-asset service providers.”
- Eurojust announced that nine suspects were arrested in connection with allegedly setting up a cryptocurrency money laundering network that scammed victims out of more than €600 million. Authorities also seized €800,000 in bank accounts, €415,000 in cryptocurrencies, and €300,000 in cash.
- AMINA Bank AG’s newly established subsidiary received a license from Austria’s Financial Market Authority under the Markets in Crypto-Assets framework.
🇭🇰 Hong Kong
- The Hong Kong Monetary Authority announced the pilot phase of “Project Ensemble” to support real-value transactions in tokenized deposits and digital assets.
🇮🇪 Ireland
- The Central Bank of Ireland fined Coinbase Europe Limited €21,464,734 for “breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025.”
🇯🇵 Japan
- Japan’s Financial Services Agency announced that it would support a proof-of-concept regarding a joint stablecoin project that includes multiple major bank groups.
🇸🇬 Singapore
- Monetary Authority of Singapore Managing Director Chia Der Jiun discussed AI adoption, tokenization, and stablecoins at the Singapore FinTech Festival.
🇬🇧 United Kingdom
- The Bank of England published a consultation paper proposing a regulatory framework for sterling-denominated systemic stablecoins.
- A Chinese national was sentenced to 11 years and eight months in prison after pleading guilty to possessing illegally obtained cryptocurrency and money laundering. The Metropolitan Police also seized more than 60,000 bitcoins.
***
The views expressed here are those of the individual AH Capital Management, L.L.C. (“a16z”) personnel quoted and are not the views of a16z or its affiliates. Certain information contained in here has been obtained from third-party sources, including from portfolio companies of funds managed by a16z. While taken from sources believed to be reliable, a16z has not independently verified such information and makes no representations about the current or enduring accuracy of the information or its appropriateness for a given situation. In addition, this content may include third-party advertisements; a16z has not reviewed such advertisements and does not endorse any advertising content contained therein.
This content is provided for informational purposes only, and should not be relied upon as legal, business, investment, or tax advice. You should consult your own advisers as to those matters. References to any securities or digital assets are for illustrative purposes only, and do not constitute an investment recommendation or offer to provide investment advisory services. Furthermore, this content is not directed at nor intended for use by any investors or prospective investors, and may not under any circumstances be relied upon when making a decision to invest in any fund managed by a16z. (An offering to invest in an a16z fund will be made only by the private placement memorandum, subscription agreement, and other relevant documentation of any such fund and should be read in their entirety.) Any investments or portfolio companies mentioned, referred to, or described are not representative of all investments in vehicles managed by a16z, and there can be no assurance that the investments will be profitable or that other investments made in the future will have similar characteristics or results. A list of investments made by funds managed by Andreessen Horowitz (excluding investments for which the issuer has not provided permission for a16z to disclose publicly as well as unannounced investments in publicly traded digital assets) is available at https://a16z.com/investments/.
The content speaks only as of the date indicated. Any projections, estimates, forecasts, targets, prospects, and/or opinions expressed in these materials are subject to change without notice and may differ or be contrary to opinions expressed by others. Please see https://a16z.com/disclosures for additional important information.
