Start by mapping what your business actually does—not what it calls itself—to the federal and state rules that may apply. Token issuance, trading, custody, transmission, staking, stablecoin issuance, and tax reporting can raise different obligations, and one company may have several roles at once. Separate rules and interpretations already in effect from proposals, assign an owner to each open issue, and track state requirements wherever you operate or serve customers.
This is a U.S. regulatory-readiness guide, not a determination that a particular company must register, obtain a license, or qualify for an exemption. Those answers depend on the business’s activities, products, customers, and operating footprint.
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Start with an activity map, not a token label
Build an inventory of the functions your company performs, including functions carried out by an affiliate, contractor, protocol, or product team. A token’s name or stated purpose does not settle its legal treatment. The same asset can raise different questions depending on its characteristics, how it is distributed, the promises made to buyers, and the services your business provides.
- List each product and transaction. Record whether the business issues or sells tokens, operates a trading venue, exchanges or transmits value, holds customer assets, offers staking, issues payment stablecoins, or provides software without handling assets for others.
- Identify the parties and flows. For each activity, note who controls assets or keys, who receives customer funds or tokens, who makes decisions, where customers are located, and which legal entity performs the work.
- Assess each role separately. A company can be an issuer in one product and an intermediary or service provider in another. Do not assume one conclusion covers the whole business.
- Classify the authority behind each requirement. Mark whether it is a statute, an effective agency interpretation, a final rule, or a proposal. A proposal is not a permission or an obligation that is already in force merely because an agency published it.
- Assign an owner and a review date. Give legal, compliance, product, engineering, finance, and operations teams specific questions to resolve, and tie monitoring to agency actions, statutory effective dates, and state developments.
Use the map to frame a review with qualified U.S. counsel. It is a way to find the questions that need answers, not a formula that decides legal status.
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How to assess securities questions and the SEC proposal
Use the March 2026 interpretation as a framework, not a safe harbor
A joint SEC/CFTC interpretive release took effect on March 23, 2026. It organizes crypto assets into five categories based on characteristics, use, and function: digital commodities, digital collectibles, digital tools, stablecoins, and digital securities. It also discusses investment contracts and how that relationship may end, as well as protocol mining, protocol staking, staking receipt tokens, wrapping, and airdrops. The release superseded the SEC staff’s 2019 digital-asset investment-contract framework.
The release does not replace the binding Howey test. In its words, “The interpretation in this release does not supersede or replace the Howey test, which is binding legal precedent.” For a token-related offering or service, examine both the asset and the transaction: the distribution, the issuer’s promises, and any continuing managerial efforts may matter alongside the token’s characteristics. Read the SEC/CFTC release when documenting the analysis.
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Treat Regulation Crypto Assets as proposed, not currently available relief
On August 18, 2026, the SEC announced a proposal called Regulation Crypto Assets for certain investment contracts involving crypto assets. Its proposed exemptions would allow up to $5 million over a four-year period under one exemption, or up to $75 million during each 12-month period under another. Those are conditional thresholds, not blanket fundraising permissions: the proposal includes disclosure conditions, and the larger offering exemption would include financial statements and ongoing reporting. It also proposes a conditional safe harbor and certain state-law preemption.
As of the SEC’s August 2026 materials, these are proposed terms, not exemptions a company can rely on as final law. The SEC listing gave October 20, 2026, as the comment deadline. Check the SEC announcement and its proposal page for status and documents before making an offering decision.
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- Smart backup: Use your second Tangem Wallet as your Backup keys with end‑to‑end encryption; no more papers, pictures. If one card is lost, the remaining can still restore full access, with an optional seed phrase available for advanced users.
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What payment-stablecoin businesses should track
The GENIUS Act establishes a federal framework for a defined category of payment stablecoins and permitted payment stablecoin issuers. Its scope should not be generalized to every asset marketed as a stablecoin. The March 2026 SEC/CFTC release discusses the Act’s definitions and treatment of qualifying payment stablecoins, while limiting the scope of that discussion; it also stated then that the Act was not yet effective. Consult the release and check the Act’s current effective dates separately.
Track two distinct proposed compliance areas
- AML and sanctions programs: On April 8, 2026, FinCEN and OFAC announced a proposed rule to implement GENIUS Act anti-money-laundering and sanctions-program requirements for permitted payment stablecoin issuers. See FinCEN’s announcement.
- Customer identification: On June 18, 2026, FinCEN and federal banking agencies announced a separate proposed customer-identification-program rule. That announcement says the Act directs permitted payment stablecoin issuers to be treated as financial institutions under the Bank Secrecy Act and to maintain effective customer identification programs. See the agency announcement.
Both 2026 actions described proposals. Issuers and prospective issuers should track rulemaking status and statutory effective dates independently, then identify what changes would be needed in customer onboarding, monitoring, sanctions controls, recordkeeping, and governance if requirements apply. Do not treat proposed details as final requirements.
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When MSB registration and state licensing need review
The Congressional Research Service’s April 1, 2025 overview says cryptocurrency exchanges generally must register as money services businesses (MSBs) with FinCEN and comply with Bank Secrecy Act anti-money-laundering and know-your-customer duties. It describes the MSB framework as largely state-based and notes that it encompasses many nonbank businesses, including exchanges and crypto ATMs. This is a general overview, not a conclusion about every exchange, product, or company. See the CRS overview.
For your own assessment, document whether the company exchanges, transmits, administers, or otherwise handles value for others, and how custody and customer flows work. Then review state requirements against the states connected to your activities, customers, and operating footprint. State licensing questions are activity- and jurisdiction-specific; the general federal MSB analysis does not resolve them.
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- Map the legal entity that performs each service and the role of any affiliates.
- Document custody, control of keys, movement of customer value, and who can initiate or reverse transactions.
- Identify customer locations and operating states, then obtain state-by-state advice where licensing may be implicated.
- Keep federal registration and state licensing analyses distinct; a conclusion about one does not establish the other.
Keep federal tax and reporting roles in the readiness plan
The IRS treats digital assets as property for federal income-tax purposes, so general tax principles for property transactions apply. Its definition covers cryptocurrency, stablecoins, and NFTs, and its FAQ points to rules for transactions on or after January 1, 2025. Review the IRS digital-asset FAQ with tax advisers to assess the company’s own transaction, reporting, and information-return roles. The FAQ does not by itself determine a particular business’s tax obligations.
Turn the map into an operating plan
A useful compliance plan ties each activity to a decision, an accountable owner, evidence, and a trigger for review. Keep a change log so the company can distinguish a new proposal from an effective interpretation or an applicable final requirement.
| Workstream | Prepare now | Trigger to revisit |
|---|---|---|
| Token offerings and related services | Maintain a record of token features, distribution mechanics, issuer promises, continuing managerial activity, and services provided around the asset. | Changes to the token, offering, issuer commitments, protocol role, or applicable SEC/CFTC interpretation. |
| Payment stablecoins | Determine whether the product and issuer fit the GENIUS Act’s defined terms; inventory onboarding, AML, sanctions, and operational controls. | Statutory effective dates and final agency rules replacing or changing the 2026 proposals. |
| Exchange, transmission, and custody | Map customer-asset flows, control of keys, entity roles, customer locations, and potentially relevant states. | New services, custody arrangements, customer markets, or state licensing developments. |
| Tax and information reporting | Inventory digital-asset transactions and identify the company’s role in each for review by tax advisers. | New transaction types, reporting rules, or changes to the company’s role. |
For each trigger, record who monitors it, who evaluates its effect, which teams must act, and what evidence will show the response was completed. That makes regulatory change part of product and operational governance rather than a one-time classification exercise.
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