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HIPAA at 21 Years of Compliance: Why the Security Rule May Be Entering a More Prescriptive Era

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<a href="#multiple">Multiple U.S. Banks Announce Digital Asset Initiatives</a>

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<a href="#payments">U.S. Payments Companies Announce Digital Asset Products</a>

<a href="#products">New Digital Asset Products Launch in Futures, Securities and Token Markets</a>

<a href="#OCC">OCC Interpretive Letter Addresses Bank Use of Digital Assets for Network Fees</a>

<a href="#DOJ">DOJ Actions Target North Korean IT Fraud and U.S. Crypto Executive</a>

<a href="#ICIJ">ICIJ Publishes Investigation Findings on Illicit Crypto Funds</a>

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Multiple U.S. Banks Announce Digital Asset Initiatives

By <a href="https://www.bakerlaw.com/professionals/jonathan-cardenas/" target="_blank" rel="noreferrer noopener">Jonathan Cardenas</a>

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On Nov. 17, LevelField Financial Inc., a Houston-based digital assets-focused financial services company, announced that it has obtained conditional regulatory approval from the Illinois Department of Financial and Professional Regulation to acquire Burling Bank, a Chicago-based community bank. Following the closing of the planned acquisition, the company is expected to become the first FDIC-insured chartered bank that will provide banking and digital asset services for consumers and businesses across all U.S. states and territories. According to a press release, the post-acquisition bank will offer loans collateralized by bitcoin, credit and debit cards that offer bitcoin rewards, and digital asset trading and custody services, among other offerings. 

In related news, a major French bank announced that it successfully completed its first issuance of tokenized digital corporate bonds in the United States. According to a press release, the bonds were registered by the bank’s digital assets-focused subsidiary and were issued as security tokens on the <a>Canton Network</a>, which is a public blockchain network that was launched by a consortium of banks, securities exchanges and technology companies in 2023 in partnership with a New York-based digital asset services company. The digital bonds, which were reportedly purchased by a leading Chicago-based proprietary trading firm, are described as “short-term floating rate debt securities linked to SOFR.”

In more banking news, on Nov. 12, a major U.S. bank announced that its U.S. dollar-denominated deposit token, JPM Coin (ticker: JPMD), is now available for use by the bank’s institutional clients on the Ethereum Layer 2 Base network. According to a press release, the bank’s institutional clients are now able to use JPM Coin to make “near real-time peer-to-peer transfers between Ethereum Virtual Machine (EVM)-compatible wallets.”

Finally, another major U.S. bank announced the expansion of its cross-border token services offerings. According to a press release, the bank’s token services allow clients to transfer both U.S. dollars and euros on a 24/7 basis to their accounts and to third-party accounts at bank branches in the U.S., the U.K., Hong Kong and Singapore. 

For more information, please refer to the following links:

<a href="https://www.prnewswire.com/news-releases/levelfield-bank-approved-to-offer-business-and-consumer-banking-and-digital-asset-services-in-all-us-states-and-territories-302617158.html" target="_blank" rel="noreferrer noopener">LevelField Bank Approved to Offer Business and Consumer Banking and Digital Asset Services in all U.S. States and Territories</a>

<a href="https://www.societegenerale.com/en/news/press-release/first-digital-bond-united-states-blockchain" target="_blank" rel="noreferrer noopener">Societe Generale issues its first digital bond in the United States on blockchain</a>

<a href="https://www.jpmorgan.com/payments/newsroom/jpm-coin-usd-deposit-token-institutional-clients" target="_blank" rel="noreferrer noopener">First bank issues USD deposit token on a public blockchain</a>

<a href="https://www.citigroup.com/global/news/press-release/2025/citi-unveils-strategic-expansion-citi-token-services-euro-integration" target="_blank" rel="noreferrer noopener">Citi Unveils Strategic Expansion of Citi Token Services</a>

U.S. Payments Companies Announce Digital Asset Products

By <a href="https://www.bakerlaw.com/RobertAMusiala" target="_blank" rel="noreferrer noopener">Robert A. Musiala Jr.</a>

A major U.S. financial services company recently announced a partnership with Mercuryo and Polygon Labs to expand its Crypto Credential program to include self-custodial wallets. According to a press release, the Crypto Credential program “helps verify interactions among consumers and businesses using blockchain networks by offering simple aliases to replace typically long and complex addresses.” By making the solution available to self-custody wallets, the financial services firm seeks to expand the program and offer “a comprehensive solution for verified, alias-based crypto transfers” with fast, low-cost transactions.

In another development, a major U.S. fintech and payments company announced new features for its Cash App product that “will soon allow eligible customers to spend bitcoin at local businesses, convert USD into bitcoin payments, and send and receive stablecoins.” Among other features, the Cash App update will allow eligible customers “to send money over the Lightning Network without having to spend or hold bitcoin.”

<a href="https://www.prnewswire.com/news-releases/mastercard-teams-up-with-mercuryo-and-polygon-labs-to-expand-mastercard-crypto-credential-to-self-custody-wallets-making-crypto-transfers-more-accessible-302617664.html" target="_blank" rel="noreferrer noopener">[] teams up with Mercuryo and Polygon Labs to expand [] Crypto Credential to self-custody wallets, making crypto transfers more accessible</a>

<a href="https://cash.app/press/cash-unlocks-bitcoin-everyday-stablecoins" target="_blank" rel="noreferrer noopener">Cash App Unlocks Bitcoin for Everyday Payments, Adds Stablecoin Support</a>

New Digital Asset Products Launch in Futures, Securities and Token Markets

By <a href="https://www.bakerlaw.com/RobertAMusiala" target="_blank" rel="noreferrer noopener">Robert A. Musiala Jr.</a><a href="https://www.bakerlaw.com/VeronicaReynolds"></a>

A major global derivatives and securities exchange network recently announced that its new Bitcoin Continuous Futures (PBT) and Ether Continuous Futures (PET) are scheduled to begin trading Dec. 15, subject to regulatory review. The new perpetual futures products “are designed to offer traders long-term exposure to bitcoin and ether.” According to a press release, the products “will have a 10-year expiration at listing and a daily cash adjustment, effectively creating perpetual-style exposure while eliminating the need to periodically roll positions.”

In another recent press release, Figure Technology Solutions Inc. “announced the filing of a registration statement on Form S-1 with the U.S. Securities and Exchange Commission (the “SEC”) relating to the proposed offering of its Series A Blockchain Common Stock … (the “Blockchain Stock”).” According to the press release, “The Blockchain Stock will be a blockchain-native class of equity securities, will trade on Figure’s alternative trading system (“ATS”) and will be convertible into shares of Figure’s Class A Common Stock on a one-for-one basis.” The press release further notes, “Holders of the Blockchain Stock will be able to borrow against and lend the Blockchain Stock out on Democratized Prime, a blockchain-based decentralized finance (“DeFi”) protocol on the Provenance Blockchain.”

And a major U.S. cryptocurrency exchange recently announced the launch of “an end-to-end token sales platform to set a new standard, focused on creating a more sustainable and transparent way for projects to distribute tokens and decentralize.” According to a blog post by the exchange, the new token sales platform will require token issuers to make certain disclosures, and token issuers and affiliates will be limited from selling any tokens over the counter or in secondary markets for six months after a public sale on the platform. The first token sale on the platform will reportedly take place Nov. 17-22.

<a href="https://www.prnewswire.com/news-releases/cboe-futures-exchange-to-offer-trading-in-continuous-futures-for-bitcoin-and-ether-on-december-15-302617230.html" target="_blank" rel="noreferrer noopener">[] to Offer Trading in Continuous Futures for Bitcoin and Ether on December 15</a>

<a href="https://www.figure.com/newsroom/announcement/figure-announces-public-filing-of-registration-statement-for-proposed-offering-of-blockchain-native-equity-securities/" target="_blank" rel="noreferrer noopener">Figure Announces Public Filing of Registration Statement for Proposed Offering of Tradeable, Blockchain-Native Equity Securities</a>

<a href="https://www.coinbase.com/en-ca/blog/the-ideal-way-to-launch-introducing-token-sales-on-coinbase" target="_blank" rel="noreferrer noopener">The ideal way to launch – introducing token sales on []</a>

OCC Interpretive Letter Addresses Bank Use of Digital Assets for Network Fees

On Nov. 18, the U.S. Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1186 confirming that a national bank may pay network fees (sometimes referred to as “gas fees”) on blockchain networks to facilitate otherwise permissible activities and hold on the balance sheet, as principal, amounts of crypto-assets necessary to pay network fees for which the bank anticipates a reasonably foreseeable need. Interpretive Letter 1186 also confirms that a national bank may hold amounts of crypto-assets as principal necessary for testing otherwise permissible crypto-asset-related platforms, whether internally developed or acquired from a third party.

<a href="https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-actions/2025/int1186.pdf" target="_blank" rel="noreferrer noopener">OCC Interpretive Letter #1186: Authority of National Banks to Hold Crypto-Assets as Principal and Pay CryptoAsset Network Fees as Incidental to a Permissible Banking Activity</a>

<a href="https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-108.html" target="_blank" rel="noreferrer noopener">OCC Confirms Bank Authority to Hold Certain Crypto-Assets as Principal for Purposes of Paying Crypto-Asset Network Fees</a>

DOJ Actions Target North Korean IT Fraud and U.S. Crypto Executive

By <a href="https://www.bakerlaw.com/professionals/amos-kim/" target="_blank" rel="noreferrer noopener">Amos Kim</a>

The U.S. Department of Justice (DOJ) recently announced coordinated nationwide enforcement actions to disrupt illicit revenue generation schemes used by the North Korean government. These actions include five guilty pleas by four U.S. nationals and a Ukrainian identity broker, along with civil forfeiture complaints seeking more than $15 million in cryptocurrency. According to a DOJ press release, North Korean IT workers, assisted by these domestic facilitators, used stolen or false identities to obtain remote employment with U.S. companies, impacting over 136 U.S. businesses and compromising the identities of numerous U.S. persons. These workers reportedly generated approximately $2.2 million in revenue, which the DOJ alleges was funneled to North Korea’s weapons programs. The press release notes that at the same time, North Korean hacking group APT38 allegedly carried out multimillion-dollar cryptocurrency heists in 2023 to raise revenue for the North Korean government; that is now being targeted for forfeiture by the FBI. The DOJ is currently investigating these allegations, according to the press release.

A separate DOJ press release announced an enforcement action against the founder of Virtual Assets LLC, which does business as Crypto Dispensers, on one count of conspiracy to commit money laundering. The indictment alleges that Crypto Dispensers operated a cash-to-cryptocurrency exchange business, including bitcoin ATMs across the U.S. According to the DOJ press release, Crypto Dispensers and its co-conspirators were sent at least $10 million in proceeds from wire fraud and narcotics offenses, and these illicit proceeds were converted to cryptocurrency and transferred to virtual wallets to obscure their sources and ownership.

<a href="https://www.justice.gov/opa/pr/justice-department-announces-nationwide-actions-combat-illicit-north-korean-government" target="_blank" rel="noreferrer noopener">Justice Department Announces Nationwide Actions to Combat Illicit North Korean Government Revenue Generation</a>

<a href="https://www.justice.gov/usao-ndil/pr/founder-chicago-cryptocurrency-company-indicted-alleged-10-million-money-laundering" target="_blank" rel="noreferrer noopener">Founder of Chicago Cryptocurrency Company Indicted in Alleged $10 Million Money Laundering Conspiracy</a>

ICIJ Publishes Investigation Findings on Illicit Crypto Funds

On Nov. 17, the International Consortium of Investigative Journalists (ICIJ) published a series of articles titled “The Coin Laundry.” According to the ICIJ, “The Coin Laundry exposes how cryptocurrency companies have empowered a shadow economy that lavishly profits from crime.” The series reportedly “relies on a trailblazing analysis of tens of thousands of cryptocurrency transactions to expose the global financial flows behind money laundering networks, cyber heists and other criminal enterprises.”

For more information, please refer to the following link: <a href="https://www.icij.org/investigations/coin-laundry/" target="_blank" rel="noreferrer noopener">The Coin Laundry: How the crypto boom minted a shadow economy that thrives on crime — and left a trail of devastated victims.</a>

Blockchain Monitor

Blockchain Monitor - Planet earth in outer space with network connection and sunlight.

Weekly Blockchain Blog – Nov. 24, 2025

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