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A seasoned regulatory and compliance attorney, Carlin brings extensive experience representing financial institutions, fintechs, lenders, payment processors, neobanks, virtual currency companies, and mortgage servicers.

This article was originally published on Law360 and is republished here with permission as it originally appeared on January 22, 2026.

Since the change in administration last year, much has changed in the payments law landscape. Federal regulators have been busy rescinding agency guidance, advisory opinions, interpretive rules and policy statements.

On October 17, 52 state and territorial attorneys general, in addition to state money transmission regulators, entered into settlements amounting to more than $20 million with ACI Worldwide (ACI), to resolve claims involving a money transmission error that led to the unauthorized withdrawal of $2.3 billion from Nationstar Mortgage (also known as Mr. Cooper) customers.

In February, Massachusetts Attorney General Joy Campbell announced a $6.5 million settlement with Safe Home Security, its CEO, and affiliated companies to resolve allegations that their practices violated state consumer protection laws by “trapping Massachusetts consumers in long-term auto renewal contracts” and engaging in illegal debt collection practices, among other activities.

On April 28, bipartisan lawmakers in the U.S. House of Representatives introduced legislation, allowing the Commodity Futures Trading Commission (CFTC) to oversee cryptocurrency spot markets. The legislation intends to create a framework to fill the regulatory gaps between the CFTC and Securities and Exchange Commission (SEC) digital asset marketplace and related regimes.

According to bill

On May 4, following in the footsteps of President Biden’s recent executive order (Federal EO), California Governor Gavin Newsom issued his own blockchain-related executive order (CA EO), making California the first among the states to endorse a proactive, harmonized approach to regulate blockchain technology. The CA EO assesses how existing state and public institutions may

On April 28, the Joint Chiefs of Global Tax Enforcement (the J5), a global joint operational taxation group consisting of Australia, Canada, Netherlands, United Kingdom, and the United States, issued an intelligence bulletin (Bulletin), enumerating its perceived dangers of non-fungible tokens (NFTs).

NFTs, ERC-20, and Fungibility

Cryptocurrencies and NFTs are similar in the sense that

On May 4, the Connecticut Banking Commissioner issued a temporary order to cease and desist and order to make restitution against lead generator SoLo Funds Inc. (SoLo) for allegedly engaging in unfair, deceptive, and abusive acts and practices (UDAAPs) in violation of the Consumer Financial Protection Act of 2010, as well as for operating in

On April 6, Senator Pat Toomey (R-PA) released a draft of his proposed stablecoin legislation titled, Stablecoin Transparency of Reserves and Uniform Safe Transactions Act, or the Stablecoin TRUST Act. Toomey, the ranking member of the Senate Banking Committee, has been a vocal proponent of blockchain innovation, and his recent bill calls for a deft

On March 31, a New York federal court dismissed a proposed securities class-action lawsuit filed against Binance, the world’s largest cryptocurrency exchange. The lawsuit, one of a host of similar actions brought against cryptocurrency exchanges in 2020, was filed by token buyers who purchased cryptocurrency on Binance’s platform.

The plaintiffs asserted that Binance had violated