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1.06.26
Federal Reserve’s “Payment Accounts” Proposal: A Term Sheet for Industry Input
The Federal Reserve Board is requesting public input on a prototype for a special purpose Federal Reserve Bank account (a “Payment Account”) that eligible institutions could use to clear and settle their own payments directly. Interestingly, the Federal Reserve Board’s Payments Account proposal is structured as a term sheet, serving as a preliminary framework. This presents a critical window for industry stakeholders to influence the proposed Payment Account’s design, operational parameters, and potential use cases.
Client Highlights
11.13.25
Wilson Sonsini Advises Circle in Connection with Launch of Circle StableFX
On November 13, 2025, Circle Technology Services, LLC, a global financial technology company and stablecoin market leader, announced the launch of Circle StableFX, an institutional-grade engine for onchain stablecoin foreign exchange (FX), built on Arc. Wilson Sonsini Goodrich & Rosati advised Circle on the launch, led by Fintech and Financial Services partner Jess Cheng.
Client Advisories
10.13.25
Enhanced Protection for DeFi Lenders, Buyers, and Investors Under Recent and New UCC Amendments
One of the primary use cases for crypto and digital assets has been lending and borrowing against such crypto assets as collateral, representing billions of dollars of activity. Crypto-backed loans are offered by centralized financial institutions, crypto exchanges, and decentralized finance (DeFi) protocols. Holders of crypto assets have long sought to borrow against their digital assets as collateral to generate leveraged returns and increase yield, such as the recent wave of digital asset treasury (DAT) companies.
Alerts
10.06.25
New York Regulator Issues Updated Guidance for Virtual Currency Custodians
Recognizing the growing demand for virtual currency custodial services and the increased use of sub-custodial relationships in the digital asset space, the New York Department of Financial Services (NY DFS) announced updated Guidance on Custodial Structures for Customer Protection in the Event of Insolvency on September 30, 2025 (2025 Guidance).
Alerts
9.23.25
Defining the Future of Stablecoin Regulation: U.S. Treasury Requests Comment on GENIUS Act Implementation
The U.S. Department of the Treasury’s (Treasury’s) recently issued advance notice of proposed rulemaking (ANPRM) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act presents a critical opportunity for industry stakeholders—especially stablecoin issuers and digital asset service providers—to help define the regulatory playing field before the rules are written.
Alerts
8.26.25
Public Comment Begins Under the GENIUS Act: Treasury Department Seeks Comment on Detecting Illicit Activity Involving Digital Assets
The U.S. Department of the Treasury issued a Request for Comment required by the recently passed Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), seeking public input on the use of innovative or novel methods, techniques, or strategies to detect and mitigate illicit finance risks involving digital assets. The Request also furthers the Administration’s policy of supporting the responsible growth and use of digital assets, as set out in Executive Order 14178 on “Strengthening American Leadership in Digital Financial Technology.”
Alerts
8.08.25
The GENIUS Act Passes: Next Steps for Regulation of Payment Stablecoins
For the first time, the U.S. has passed federal legislation dedicated to establishing a regulatory framework in the cryptocurrency space, as President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into law on July 18, 2025. The Act will impose requirements surrounding the issuance and custody of “payment stablecoins,” a specific category of stablecoins defined in the Act that are intended for use as a means of payment or settlement.
Bylined Articles
7.29.25
AI in Wealthtech: Navigating the Next Era of Wealth Management
In “AI in Wealthtech: Navigating the Next Era of Wealth Management,” an article previously published in the Investment Adviser Association’s IAA Today, Wilson Sonsini partner Amy Caiazza and associate Alice Cao discuss how AI is reshaping the wealthtech space, an evolving segment of the fintech industry.
Alerts
7.25.25
A GENIUS Act Gameplan: Strategic Paths for Payment Stablecoin Issuers
The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) is a first-of-its-kind regulatory framework for “payment stablecoins” and the entities that issue them. For companies honing their stablecoin issuance strategy, the GENIUS Act presents an important decision point: how to enter the market compliantly, at what scale, and under which regulatory regime. We summarize three forward-looking payment stablecoin issuance paths available under the GENIUS Act, each allowing issuers to remain outside the maximalist regulatory regime that applies to commercial banks.
White Papers/Briefs
7.10.25
The AI in Wealthtech Field Guide
The wealthtech industry is deploying AI to create more efficient, bespoke, user-driven, and data-intensive portfolio management strategies, and to streamline analytics and administration. AI can be used in a vast number of ways, including to enhance benchmark assessments and enable novel ways of uncovering signals that may generate alpha, and it can leverage vast client and customer data to more finely tailor recommendations.
Client Highlights
5.15.25
Wilson Sonsini Advises Circle on Payments Network Launch
On April 21, 2025, Circle Internet Group, Inc., a global financial technology company and stablecoin market leader, announced Circle Payments Network (CPN) to connect financial institutions—banks, neo-banks, payment service providers, virtual asset service providers, and digital wallets—and enable real-time settlement of cross-border payments using regulated stablecoins. Wilson Sonsini Goodrich & Rosati advised Circle.