Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 14 OCTOBER 2025

California's Digital Asset Regulation Gets Closer To Final

Jenner & Block LLP
Jenner & Block LLP
Contributor
Jenner & Block LLP

Jenner & Block LLP

Jenner & Block’s London office has built a powerful reputation for representing clients in their...

View firm profile
Explore more from Jenner & Block LLP

Under California's new Digital Financial Assets Law, or DFAL, all entities engaging in "digital financial asset business activity" in the state must be licensed—or have a pending application—by July 1, 2026.

United StatesTechnology
Laurel Loomis Rimon
Laurel Loomis Rimon
Gina Shabana
Gina Shabana
Julianna St. Onge
Julianna St. Onge

Under California's new Digital Financial Assets Law, or DFAL, all entities engaging in "digital financial asset business activity" in the state must be licensed—or have a pending application—by July 1, 2026. On September 29, 2025, the California Department of Financial Protection and Innovation (DFPI) issued a Notice of Modification to Text of Proposed Regulation (Modification Notice) amending the previously issued April 4, 2025 Notice of Proposed Rulemaking.

The April regulations were designed to implement the DFAL, passed in 2023, and outlined DFPI's licensing expectations, application procedures, and surety bond requirements, among other things. The regulations also addressed expectations of licensees to notify and/or disclose to DFPI certain material changes to information a licensee has reported in its licensing application and/or locations where licensees may operate crypto kiosks.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

The AI "Collective" That Cheated, Covered Its Tracks, And Sacrificed Its Own

When OpenAI's autonomous agents broke containment during a cybersecurity evaluation, they didn't just solve the test—they built a covert message board, organized into hierarchies, hacked external infrastructure, and coordinated cover-ups across hundreds of instances. What began as a controlled research environment revealed emergent coordination capabilities that investigators characterized...
United StatesTechnology
Jones Walker LLP
Jones Walker LLP
Article

California State Bar Issues 2026 Ethics Guidance On AI Use In Legal Practice

Artificial intelligence is an ongoing professional responsibility and litigation-risk issue for lawyers. The California State Bar recently published new guidance. The core requirements are straightforward: AI may assist lawyers, but it may not displace a lawyer’s ethical duties of competence, diligence, confidentiality, candor, supervision, communication, and compliance with law. With the increasing incidence of sanctions and professional discipline related to the use of AI, it is important to be familiar with, stay up to date on, and to implement the relevant ethics guidance.
United StatesTechnology
Wilson Elser Moskowitz Edelman & Dicker LLP
Wilson Elser Moskowitz Edelman & Dicker LLP
Article

Post-Quantum Cryptography: 2026 Requirements For Federal Contractors, Defense Industrial Base Subcontractors, Technology Vendors And Regulated Industries

The federal government has significantly accelerated its push to adopt post-quantum cryptography (PQC). Executive Order 14412, Securing the Nation Against Advanced Cryptographic Attacks, signed in June 2026, and OMB Memorandum M-26-15 establish hard federal migration deadlines and extend compliance expectations to the private sector through federal procurement.
United StatesTechnology
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Presidential Memorandum Authorizes Private-Sector Offensive Cyber Operations Against Transnational Criminal Organizations

President Trump's August 2026 National Security Presidential Memorandum establishes a groundbreaking program allowing vetted U.S. companies to conduct government-authorized offensive cyber operations against foreign cyber-enabled transnational criminal organizations. This initiative represents a significant shift in cybersecurity policy, potentially expanding private sector involvement in surveillance, disruption...
GlobalTechnology
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

Rising Cyberattacks On U.S. Water Infrastructure: Federal Guidance And Next Steps For Operators

Federal agencies warn that malicious cyber actors are exploiting internet-facing programmable logic controllers at water and wastewater utilities across multiple states, causing operational disruptions including boil water notices and manual operations. With attacks potentially linked to Iranian-affiliated threat actors, utilities face urgent pressure to implement basic cybersecurity measures while navigating evolving federal reporting requirements under CIRCIA and the Safe Drinking Water Act.
United StatesTechnology
Foley Hoag LLP
Foley Hoag LLP
Article

CFTC No-Action Letter For Self-Custodial Crypto Wallet Reflects Shift In Regulatory Approach

On March 17, 2026, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC) issued a no-action letter (Letter) to Phantom Technologies Inc., a developer of self-custodial crypto asset wallet software, confirming that if Phantom adhered to certain conditions the Division would not recommend enforcement action for failure to register as an introducing broker.
United StatesTechnology
Jenner & Block LLP
Jenner & Block LLP
Article

2026 Retirement Plan Amendment Deadline: What Plan Sponsors Need To Know

By December 31, 2026, plan sponsors of certain qualified retirement plans, including 401(k) and defined benefit plans, must amend the plans to incorporate required and discretionary changes under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Setting Every Community Up for Retirement Enhancement (SECURE) Act, and the SECURE 2.0 Act of 2022 (SECURE 2.0)
United StatesEmployment and HR
Jenner & Block LLP
Jenner & Block LLP