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Crypto Currency & Digital Assets
The rules just changed. The window is open. Move now.
For the first time in US history, digital asset companies have a federal regulatory framework. The GENIUS Act is signed law. The CLARITY Act has passed the House. Defined licensing pathways, explicit BSA/AML obligations, and clear jurisdictional boundaries now exist. The companies that get their licensing and compliance stack in place first will be the ones operating at scale when their competitors are still in the application queue.
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A decade of regulatory grey zone. Two laws that end it.
US crypto regulation was built on enforcement actions, not statutes. The SEC classified assets as securities without providing registration pathways. The CFTC asserted jurisdiction without clear statutory authority. Companies operated under permanent legal uncertainty. That changed in July 2025.
The GENIUS Act
The first federal statute on digital assets. Establishes a licensing and supervisory framework for payment stablecoin issuers. Stablecoins are carved out from the Securities Act, Exchange Act, and Commodity Exchange Act. It is a distinct asset class regulated under the OCC for nonbank issuers, or the primary federal banking regulator for bank subsidiaries. BSA/AML obligations are explicit and FinCEN will issue tailored AML rules.
The CLARITY Act
The most comprehensive digital asset market structure bill ever to pass a chamber of Congress. Draws a hard jurisdictional line between SEC and CFTC. Most blockchain-native tokens are classified as digital commodities under CFTC oversight. Registration is mandated for digital commodity exchanges, brokers, and dealers. Explicit BSA/AML obligations apply at launch. Senate passage is pending. The framework is directionally set.
Only bank subsidiaries, OCC-supervised nonbanks, or state-qualified issuers may issue payment stablecoins. No licence, no issuance.
Dollar-for-dollar backing in USD cash, T-bills, or approved low-risk assets. Reserve composition disclosed and examined.
Full Bank Secrecy Act compliance required before launch. FinCEN will issue tailored AML rules for stablecoin issuers.
Issuers under $10B outstanding may elect state regulation if the state framework receives SCRC certification.
Periodic reserve composition attestations. Issuers above $50B outstanding require audited annual financial statements.
Most blockchain-native tokens become digital commodities under CFTC oversight. Registration pathway, examination framework, and fee structure all shift from SEC to CFTC.
Digital commodity exchanges, brokers, and dealers must register with the CFTC. Provisional registration available during implementation period.
New digital commodity intermediaries are explicitly subject to the Bank Secrecy Act. AML/CFT programme, OFAC screening, and SAR obligations apply from day one of operations.
Decentralised protocol activities may be exempt. Centralised intermediaries interacting with DeFi protocols face the full compliance framework.
The statutes create the obligations. We build your compliance stack.
Our founder sits on the board of the MSBA, the trade body at the table during the drafting and advocacy process for both pieces of legislation. We understand what these obligations require in practice, not just what the statutory text says.
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Multi-State MTL Portfolio
Crypto exchanges, on/off ramp providers, digital wallets, and stablecoin platforms conducting money transmission require state-level MTL coverage. We design and execute the full multi-state portfolio: NMLS filings, surety bond placement, examiner correspondence, and approval coordination across all operating states.
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BSA/AML Programme for Digital Assets
Both the GENIUS Act and CLARITY Act impose explicit Bank Secrecy Act obligations. We build AML/CFT programmes tailored to digital asset business models: blockchain analytics integration, on-chain transaction monitoring, counterparty risk classification, OFAC screening for wallet addresses, and SAR filing procedures for crypto-specific suspicious activity typologies.
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GENIUS Act Issuer Preparation
For stablecoin issuers: regulatory structure assessment (bank subsidiary vs OCC nonbank vs state-qualified issuer), reserve composition documentation, BSA/AML programme build, and the application package required for permitted issuer status.
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Public Trust Charter
Crypto custodians and digital asset platforms operating at institutional scale require a Public Trust Charter, not just an MTL portfolio. It is the licensing structure that satisfies the due diligence requirements of institutional counterparties, Tier 1 correspondent banks, and enterprise clients who will not onboard a digital asset custodian without it. It signals regulatory permanence, not just operational compliance. TransBridge has built this structure before.
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Sponsor Bank Readiness for Crypto
Digital asset companies face elevated BSA/AML scrutiny from sponsor banks. We build the compliance documentation, risk narrative, and institutional due diligence package that positions you for the correspondent banking relationships your business needs as your licensing stack matures.
Regulatory clarity accelerates competition.
Pre-GENIUS Act, no stablecoin issuer had a defined legal structure. Pre-CLARITY Act, every exchange was guessing at CFTC vs SEC jurisdiction. Now there are registration pathways, compliance obligations, and examination frameworks.
The companies that get licensed, BSA/AML-compliant, and sponsor bank-approved first will dominate the institutional segment. The ones that wait for the final Senate text will be six months behind a competitor who moved when the direction was clear.
Note: The GENIUS Act is signed law as of July 18, 2025. The CLARITY Act passed the House on July 17, 2025 and is pending Senate passage. Review CLARITY Act references upon Senate passage.
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