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The Weekly Hill Update

Robert Musiala Takes Part in Panel at BankTech Conference

Blockchain Monitor

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Weekly Blockchain Blog – November 10, 2025

ADventures in Law

Insights from FTC Commissioner Holyoak at Recent ANA Conference

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<a href="#digital">US Digital Asset Companies Announce Stablecoin Initiatives, TradFi Integrations</a>

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<a href="#crypto">2025 Crypto Adoption Report Published</a>

<a href="#usbank">US Bank Groups Ask OCC To Reject Digital Asset Trust Charter Applications</a>

<a href="#circuit">Circuit Court Upholds Denial of Master Account for Crypto-Focused Bank</a>

<a href="#ofac">OFAC Adds 53 Crypto Addresses to SDN List Related to DPRK IT Worker Fraud</a>

<a href="#defi">DeFi Protocol Hacked for $116M</a>

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US Digital Asset Companies Announce Stablecoin Initiatives, TradFi Integrations

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

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On Nov. 5, Ripple, a U.S. fintech and digital asset infrastructure provider, announced its newly established collaboration with a multinational payment card services corporation, an issuer of consumer and commercial credit products, and a global crypto services provider. According to a press release, the collaboration is designed to explore the use of the company’s stablecoin, RLUSD, for stablecoin-based settlement of fiat payment card transactions. Subject to regulatory approvals, Ripple and the collaborating companies intend to begin planning the integration of RLUSD with the collaborators’ existing settlement processes over the coming months. 

Ripple also recently announced the launch of its digital asset spot prime brokerage for its U.S.-based institutional clients. According to a Ripple blog post, the prime brokerage will allow institutional clients to execute and cross-margin over-the-counter spot transactions across a variety of digital assets. 

In other news, the operator of a major U.S. digital payments network announced plans to leverage stablecoins for cross-border money transfers to and from the U.S. According to a statement by the network operator’s CEO, the initiative is designed to build on the network’s success in the U.S. payments market and will address its customers’ growing demand for money movement across borders. 

Finally, a multinational investment bank and a major U.S. cryptocurrency exchange recently announced their intention to collaborate on the introduction of digital asset payment capabilities for the bank’s clients. According to a press release, the collaboration is designed to bridge traditional finance with decentralized finance (DeFi) and will initially focus on fiat pay-ins and payouts as well as payments orchestration.

For more information, please refer to the following links:

<a href="https://www.businesswire.com/news/home/20251103651890/en/Ripple-Launches-Digital-Asset-Spot-Prime-Brokerage-for-the-United-States-Market">Ripple Launches Digital Asset Spot Prime Brokerage for the United States Market</a>

<a href="https://ripple.com/ripple-press/ripple-teams-up-with-mastercard-webbank-and-gemini/">Ripple Teams up with Mastercard, WebBank, and Gemini to Bring Stablecoin Settlement with RLUSD to Improve Fiat Payments</a>

<a href="https://www.prnewswire.com/news-releases/zelle-goes-international-early-warning-expands-1t-payments-network-with-stablecoin-initiative-302593440.html">Zelle® Goes International: Early Warning Expands $1T Payments Network with Stablecoin Initiative</a>

<a href="https://www.citigroup.com/global/news/press-release/2025/citi-coinbase-join-forces-boost-digital-asset-payment-capabilities-global-clients">Citi and Coinbase Join Forces to Boost Digital Asset Payment Capabilities for Global Clients</a>

2025 Global Crypto Adoption Report Published

Chainalysis, a blockchain analytics company, recently published The 2025 Geography of Crypto Report, which analyzes global crypto adoption trends. According to the report, the Asia-Pacific region, led by India, is the “global hub of grassroots crypto activity,” while the North America region, led by the U.S., ranks as the second-most-active region in the world as a result of its “regulatory momentum.” In addition, the report notes that several countries in Eastern Europe, including Ukraine, Moldova and Georgia, rank among the highest adopters of crypto in the world relative to the size of their populations as a result of a combination of factors including, but not limited to, war, economic uncertainty and strong technical literacy. The report also provides a list of countries ranked on the basis of their crypto adoption levels, which is referred to as the 2025 Global Crypto Adoption Index Top 20. In order of rank, the top 20 countries are (1) India, (2) U.S., (3) Pakistan, (4) Vietnam, (5) Brazil, (6) Nigeria, (7) Indonesia, (8) Ukraine, (9) Philippines, (10) Russia, (11) United Kingdom, (12) Ethiopia, (13) Bangladesh, (14) Türkiye, (15) South Korea, (16) Yemen, (17) Thailand, (18) Venezuela, (19) Japan and (20) Argentina.

For more information, please refer to the following link:

<a href="https://www.chainalysis.com/wp-content/uploads/2025/10/the-2025-geography-of-crypto-report-release.pdf">The 2025 Geography of Crypto Report</a>

US Bank Groups Ask OCC To Reject Digital Asset Trust Charter Applications

By <a href="https://www.bakerlaw.com/RobertAMusiala">Robert A. Musiala Jr.</a>

Two major U.S. bank advocacy organizations recently published letters addressed to the U.S. Office of the Comptroller of the Currency (OCC) in which the organizations urged the OCC to reject a total of six pending limited-purpose national trust company charter applications submitted by digital assets firms.

The Bank Policy Institute (BPI) submitted five separate letters to the OCC, individually addressing the BPI’s request that the OCC reject the applications of Ripple, Circle, Paxos, Wise and National Digital Trust Co. According to a BPI press release, “[t]hese applications reflect a growing trend of nonbank financial companies seeking limited-purpose national trust bank charters, despite not planning to operate genuine trust companies.” In the press release, BPI notes that the OCC’s trust charter authority is limited to institutions predominantly engaged in trust and fiduciary activities. BPI then argues that the applicants propose to engage in activities that “closely mirror core banking functions” such as managing stablecoin reserves, facilitating payments and taking deposits.

In a separate letter, the Independent Community Bankers of America (ICBA) urged the OCC to deny the national trust charter application of a subsidiary of the largest U.S. cryptocurrency exchange. In a press release, the ICBA argues that the application should be denied because the applicant company proposes to rely on flawed risk and control functions, operates under a governance structure that prevents independent oversight, would struggle to maintain profitability during crypto bear markets, and would pose challenges in a receivership scenario, particularly with respect to crypto custody. The U.S. crypto exchange’s chief legal officer publicly disputed the ICBA’s action in a social media post, calling it “protectionism.”

<a href="https://bpi.com/bpi-urges-occ-to-preserve-the-integrity-of-national-trust-charters/">BPI Urges OCC to Preserve the Integrity of National Trust Charters</a>

<a href="https://www.icba.org/newsroom/news-and-articles/2025/11/04/icba-urges-occ-to-deny-coinbase-s-national-trust-bank-charter-application">ICBA urges OCC to deny Coinbase’s national trust bank charter application</a>

<a href="https://www.icba.org/advocacy/letter-details/letter-urging-occ-to-deny-coinbase-s-application-for-a-national-trust-bank-charter">RE: ICBA LETTER IN OPPOSITION TO COINBASE NATIONAL TRUST COMPANY’S CHARTER APPLICATION (2025-CHARTER-343449)</a>

<a href="https://cointelegraph.com/news/banking-group-coinbase-national-trust-charter-application">Coinbase exec criticizes banks’ pushback against crypto charter application</a>

<a href="https://bpi.com/wp-content/uploads/2025/11/BPI-comment-letter-re-Coinbase-NTB-Application-11-3-25.pdf">Re: Coinbase National Trust Company, Charter Application (2025-Charter-343449)</a>

<a href="https://bpi.com/wp-content/uploads/2025/10/BPI-comment-letter-re-OCC-application-re-Paxos-Trust-Company-Conversion-to-NTB-10-14-25.pdf">Re: Paxos Trust Company, LLC, Charter Conversion Application (2025-Conversion-342828)</a>

<a href="https://bpi.com/wp-content/uploads/2025/10/BPI-comment-letter-re-OCC-NTB-application-re-First-National-Digital-Currency-Bank-Circle-10-14-25.pdf">Re: First National Digital Currency Bank, N.A., Charter Application (2025-Charter--342299)</a>

<a href="https://bpi.com/wp-content/uploads/2025/10/BPI-comment-letter-re-OCC-NTB-application-re-National-Digital-Trust-Company-10-14-25.pdf">Re: National Digital Trust Company, N.A., Charter Application (2025-Charter-342009)</a>

<a href="https://bpi.com/wp-content/uploads/2025/10/BPI-comment-letter-re-OCC-NTB-application-re-Ripple-National-Trust-Bank-10-14-25.pdf">Re: Ripple National Trust Bank, N.A., Charter Application (2025-Charter--342347)</a>

<a href="https://bpi.com/wp-content/uploads/2025/10/BPI-comment-letter-re-OCC-NTB-application-re-Wise-Trust-Company-10-14-25.pdf">Re: Wise National Trust, N.A., Charter Application (2025-Charter-342106)</a>

Circuit Court Upholds Denial of Master Account for Crypto-Focused Bank

On Oct. 31, the U.S. Court of Appeals for the 10th Circuit issued an opinion upholding an earlier U.S. district court’s decision and finding that the U.S. central bank has discretion to reject master account access requests from eligible entities. The circuit court’s opinion rejected a claim by Custodia Bank, a crypto-focused bank, that it was entitled to a master account. The court cases arose from Custodia Bank’s challenge to a <a href="https://www.theblockchainmonitor.com/blogs/zero-knowledge-evms-launch-u-s-central-bank-publishes-custodia-denial-order-cftc-charges-binance-exchange-sec-doj-bring-enforcement-actions/#US">2023 order</a> issued by the U.S. central bank denying the application of Custodia Bank to hold a master account and become a member of the U.S. central bank.

<a href="https://www.law360.com/fintech/articles/2406322?nl_pk=269c598f-8e37-49e3-bf43-b88e05d4215b&amp;utm_source=newsletter&amp;utm_medium=email&amp;utm_campaign=fintech&amp;utm_content=2025-11-03&amp;read_main=1&amp;nlsidx=0&amp;nlaidx=0">10th Circ. Rules Fed Can Reject Master Account Access</a>

OFAC Adds 53 Crypto Addresses to SDN List Related to DPRK IT Worker Fraud

On Nov. 4, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned eight individuals and two entities for their role in laundering funds derived from a variety of illicit schemes performed on behalf of the Democratic People’s Republic of Korea (DPRK), including cybercrime and information technology (IT) worker fraud. As part of the action, OFAC added 53 cryptocurrency addresses to its Specially Designated Nationals (SDN) List. According to the OFAC press release, “DPRK IT workers … earn hundreds of millions of dollars per year by engaging in a wide range of IT development work by obfuscating their nationality with false or stolen identities when they seek employment contracts and create accounts on freelance work websites.” A report by a blockchain analytics company noted that many of the crypto addresses designated by the OFAC action receive funds directly from several centralized cryptocurrency exchanges, including one from which they have received $5.4 million since February 2024. 

<a href="https://home.treasury.gov/news/press-releases/sb0302">Treasury Sanctions DPRK Bankers and Institutions Involved in Laundering Cybercrime Proceeds and IT Worker Funds</a>

<a href="https://ofac.treasury.gov/recent-actions/20251104">Cyber-related Designations; North Korea Designations and Designation Update; Belarus Designations Removals; Issuance of Belarus General License</a>

<a href="https://www.elliptic.co/blog/ofac-lists-53-crypto-addresses-of-sanctioned-north-korean-cheil-credit-bank">OFAC lists 53 crypto addresses of sanctioned North Korean Cheil Credit Bank</a>

DeFi Protocol Hacked for $116M

According to reports, Balancer, a decentralized exchange and automated market maker, recently lost more than $116 million in a hack. Initial reports attributed the hack to smart contract issues involving a “faulty access check allowing the attacker to send a command to withdraw funds.” Other reports noted that the hack was a sophisticated attack in which “[t]he attackers bypassed access control layers to manipulate asset balances directly, a critical failure in operational governance rather than core protocol logic.” The Balancer team has published a preliminary report with their analysis of the incident.

<a href="https://cointelegraph.com/news/balancer-suspected-70m-exploit-staked-ether-new-wallet">Balancer exploit swells to $116M in outflows as team offers 20% bounty</a>

<a href="https://cointelegraph.com/news/116m-balancer-hack-insiders-sophisticated-hacker-months-preparation">Balancer hack shows signs of months-long planning by skilled attacker</a>

<a href="https://cointelegraph.com/news/balancer-post-mortem-report-116m-hack">Balancer releases preliminary post-mortem report after $116M hack</a>

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