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by Michele Alt, Roman Goldstein, and Patrick Haggerty To protect stablecoin holders from issuer insolvency, GENIUS: Requires an issuer to hold full and segregated reserves against all its outstanding stablecoins; Provides holders of stablecoins issued by a nonbank issue r a superpriority claim in bankruptcy on those reserves and the issuer’s other assets; and Prescribes a non-bankruptcy resolution process for any insolvent bank issuer . Congress, however, overlooked a few imp

The rapid emergence of artificial intelligence (AI) technologies creates a new pool of cyber risk, and a material commercial reason for partner banks to focus on information security.

On October 9, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) and the primary federal banking agencies issued “FAQs Regarding Suspicious Activity Reporting Requirements” to clarify four specific provisions that many financial institutions have incorporated into their Bank Security Act and anti-money-laundering (BSA/AML) programs to reduce the burdens related to SAR filings. We’ve summarized the FAQs below to help financial institutions un

In addition to Industrial Loan Companies (ILCs), Merchant Acquirer Limited Purpose Bank Charters (M-A-L-P-Bs), and Special Purpose Depository Institutions (SPDIs), National Trust Banks (NTBs), CEBA banks, and Payments National Banks (PNBs) have emerged as contenders.