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08/24/2026|6 minute read

In this issue:

U.S. Bank Announces Digital Asset Custody; Tether Completes ‘Big Four’ Audit

By Robert A. Musiala Jr.

A major U.S. bank recently announced the launch of its Custody+ product, which is described in a press release as “a comprehensive suite of near- and real-time solutions to meet always-on industry demand.” According to the press release, as part of the new Custody+ product, the bank “expects to go live with digital asset custody later this year, starting with the custody of Bitcoin.” The press release further notes that with the new product, the bank’s clients “will access traditional and crypto custody capabilities within the same framework for an integrated experience.”

In another recent press release, Tether, the issuer of the USDT stablecoin, announced “the successful completion of a full independent audit of Tether International, S.A. de C.V.’s financial statements for the year ended December 31, 2025” by a U.S. “Big Four” accounting firm. According to the press release, the Big Four accounting firm “issued an unqualified audit opinion of Tether’s financial statements, meaning in [the firm’s] opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of December 31, 2025, and the results of its operations and its cash flows for the year ended in accordance with U.S. generally accepted accounting principles.”

For more information, please refer to the following links:

Crypto Companies Announce New Products; Solana Q2 Report Published

By John E. Robertson

A major blockchain payments company, Polygon Labs, recently announced it was joining Phase 2 of the Bank of England’s Digital Pound Lab. Reports indicate the Lab allows participants to test blockchain infrastructure against a simulated digital pound without the cost, risk, or regulatory oversight of a live pilot. Polygon Labs stated it joined the Lab in order to test whether a stablecoin and a digital pound can settle the same cross-border payment, in the same flow, without either side waiting on the other. The company is said to be developing the stablecoin settlement leg to the transaction and the smart contract infrastructure while the Lab will settle the digital pound.

In other news, a major U.S. cryptocurrency exchange announced the launch of its new debit card in the United States. According to a company blog post, the debit card offers users 2% cashback in either USD or BTC on everyday spending. The exchange also announced the launch of U.S.-listed stocks for its European customers. A company blog post notes the stocks will be available as tokenized U.S. equities backed 1:1 by underlying stock. According to the blog post, the tokenized equities will be tradable during hours when the public market is closed while still maintaining the full 1:1 backing.

Finally, a major U.S. digital assets company recently published a report analyzing activity on the Solana blockchain during Q2 2026. Key findings from the report include:

  • Median slot duration remained at the 400-millisecond target for the entirety of Q2 with zero downtime for the ninth consecutive quarter.
  • Block compute limits were increased from 60 million to 100 million compute units.
  • A major client grew from 28% to 33% of the Block Assembly marketplace by enabling the use of plugins for applications to control transaction ordering and enabling the same functionality on the general-purpose blockchain.
  • DEX volume fell 45% quarter-over-quarter, although June DEX volume rebounded 20% month-over-month.

Solana recorded as high as 95%+ of total tokenized equity trading throughout the quarter.

For more information, please refer to the following links:

SEC Proposes Exemptions for Investment Contracts Involving Crypto Assets

By Robert A. Musiala Jr.

On Aug. 18, the U.S. Securities and Exchange Commission (SEC) published a 402-page proposed rule titled Regulation Crypto Assets (Reg Crypto). According to a fact sheet, Reg Crypto would create “a tailored offering regime for certain investment contracts involving crypto assets” (covered investment contracts) with four key parts:

  1. Startup Exemption: The Startup Exemption would be a one-time, non-exclusive exemption from the registration requirements of the Securities Act of 1933 (Securities Act) during a four-year period for offerings of up to $5 million of covered investment contracts. To qualify, issuers would have to satisfy certain conditions, including making public filings and investor disclosures.
  2. Fundraising Exemption: The Fundraising Exemption would be a non-exclusive, two-tier exemption from Securities Act registration requirements, modeled in part on Regulation A. Issuers would be permitted to conduct offerings of up to $20 million (Tier 1) and $75 million (Tier 2) of covered investment contracts in a 12-month period. Issuers would be required to publicly file (i) offering materials consisting of the same narrative disclosures required under the Startup Exemption, (ii) a discussion of the issuer’s financial condition, and (iii) financial statements (audited for Tier 2). Issuers also would be subject to ongoing reporting modeled on analogous provisions in Regulation A.
  3. Investment Contract Safe Harbor: The Investment Contract Safe Harbor would provide a conditional safe harbor from the term “investment contract” in the definitions of “security” in the Securities Act and the Securities Exchange Act of 1934. If the safe harbor conditions are met, the SEC would take the position that a crypto asset subject to the investment contract does not constitute or represent and is not subject to such investment contract for purposes of the statutory definition of a “security.” The Investment Contract Safe Harbor would be satisfied if the issuer of a covered investment contract has (i) completed or otherwise permanently ceased all essential managerial efforts that it represented or promised it would engage in under the covered investment contract and is not making and does not intend to make any new representations or promises to engage in essential managerial efforts with respect to the underlying crypto asset, and (ii) made a public filing certifying that it has satisfied the conditions of the safe harbor and providing an analysis supporting that certification.
  4. Qualified Purchaser Definition: Reg Crypto would add a Qualified Purchaser definition under the Securities Act that would preempt state securities law registration and qualification requirements with respect to offers and sales of covered investment contracts issued pursuant to Reg Crypto. With respect to secondary market transactions by any person other than an issuer, underwriter, or dealer, the proposed amendments would preempt state securities law registration and qualification requirements for covered investment contracts that were initially sold by the issuer pursuant to an exemption in Reg Crypto. This secondary market preemption would continue for the period during which the issuer continues to satisfy the applicable Reg Crypto information and filing and/or periodic reporting requirements.

Comments on the proposed rule are due 60 days from the date the proposed rule is published in the Federal Register.

For more information, please refer to the following links:

GENIUS Act Proposed Rule Addresses Stablecoin Issuance, Offers, Sales

By Ariana Dindiyal

On Aug. 18, the U.S. Department of the Treasury (Treasury) published an 87-page proposed rule that would implement Section 3 of the GENIUS Act regarding the statutory prohibitions and limitations on payment stablecoin issuance, offer, and sale in the United States.

In a press release, Treasury outlined the new proposed rule, which would define what counts as stablecoin issuance, restrict the offering and sale of stablecoins from unauthorized issuers, and clarify how foreign stablecoin issuers may serve customers in the U.S. or steer clear of its regulatory perimeter. The proposal specifically seeks to clarify topics such as the circumstances under which a company would be deemed to “issue” a stablecoin, when a foreign issuer would qualify as a U.S. issuer, a potential pathway for foreign issuers to serve U.S. customers, and limits for crypto exchanges, crypto custodians, and other digital asset service providers, which are barred under the GENIUS Act from offering or selling unregistered stablecoins to U.S. customers.

The proposed rule additionally calls for codifying certain exemptions from the GENIUS Act, including for direct peer-to-peer transfers of stablecoins and transfers between a customer’s U.S. and foreign accounts within a single corporate family. 

“Treasury welcomes input from stakeholders as we work to provide the regulatory certainty businesses need to innovate and grow in America, cement the role of the U.S. dollar as the world’s reserve currency, and keep America the crypto capital of the world,” Secretary of Treasury Scott Bessent commented in a recent statement announcing the proposal. The proposed rule includes 87 specific questions on which Treasury is seeking public comment. The draft rules will be open for 60 days of public comment after the Aug. 18 Federal Register publication date.

For more information, please refer to the following links:

FASB Proposes Accounting Standards Update Addressing Digital Assets

By Robert A. Musiala Jr.

The Financial Accounting Standards Board (FASB) recently published a proposed Accounting Standards Update (ASU) “intended to clarify how the current definition of cash equivalents applies to certain digital assets, such as stablecoins, and to increase transparency about the significant components of cash equivalents.” According to a FASB press release, the proposed ASU would not change the current definition of “cash equivalents” but would “provide illustrative examples to promote more consistent application of that definition and improve comparability among entities that elect to present qualifying digital assets as cash equivalents.” The proposed ASU would also “require all entities to provide enhanced disclosures of significant components and related amounts of cash equivalents, regardless of whether any of those assets are digital assets.”

For more information, please refer to the following link:


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