DSG FINTECH UPDATE — SEPTEMBER 2025
United States
U.S. CFTC Approves Polymarket’s New Exchange, QCX: On September 4, the Commodity Futures Trading Commission (CFTC) issued a no-action letter to QCX, the derivatives exchange acquired by prediction market firm Polymarket in July. The letter exempts QCX from certain disclosure and recordkeeping requirements, allowing it to operate in specifically defined ways without drawing enforcement attention from the regulator. QCX had received its license to begin operations in July before being acquired by Polymarket later that month. More here.
Representative Joyce Introduces Bill to Require Treasury Report on Strategic Bitcoin Reserve: On September 5, Representative David Joyce (R-OH) introduced a House appropriations bill to require the Treasury Department to submit, within ninety day,s a report on the feasibility, custody, legal authority, cybersecurity, and accounting treatment of a Strategic Bitcoin Reserve. It would also direct Treasury to assess interagency transfer processes, contractor involvement, and potential impacts on the Treasury Forfeiture Fund. More here.
Offshore Crypto Exchange Will Not Use FBOT Framework for US Operations: On September 6, legal experts indicated that the CFTC’s recent advisory on offshore exchanges serving U.S. residents under the Foreign Board of Trade (FBOT) framework is unlikely to facilitate the return of offshore crypto exchanges to U.S. operations. Eli Cohen, General Counsel at real-world asset (RWA) tokenization company Centrifuge, explained that the settlement, clearing, and regulatory requirements under the FBOT framework are designed for traditional financial systems and present significant implementation challenges for crypto exchanges. The CFTC guidance specifies that only Licensed Futures Commission Merchant (FCM) exchanges and other highly regulated entities qualify to apply under the FBOT framework, requiring applicants to already operate under an existing regulatory framework in their home jurisdiction. More here.
Nasdaq Submits Application to SEC for Tokenized Stock Trading: On September 8, Nasdaq filed a rule change request with the Securities and Exchange Commission (SEC) seeking approval to list and trade tokenized stocks on its exchange platform. The request asked the SEC to amend certain rules, including the definition of a security, to allow tokenized stocks to trade under the same execution and documentation frameworks as traditional securities, provided the tokenized versions are deemed equivalent to their conventional counterparts. More here.
SEC Extends Review Period for Franklin and BlackRock Crypto ETF Applications: On September 10, the SEC extended review periods for several cryptocurrency exchange-traded fund (ETF) applications, utilizing maximum allowable extensions under federal securities law. The SEC set a new deadline of November 13 for Franklin Templeton’s Ethereum staking amendment and November 14 for the firm’s proposed Solana and XRP ETFs, which were originally filed with Cboe BZX in mid-March. Additionally, BlackRock’s proposal to permit staking in its iShares Ethereum Trust received a deadline extension to October 30, after Nasdaq submitted the amendment on July 16. The SEC filings did not indicate the agency’s position on the applications, stating only that additional time was needed for evaluation. More here.
Treasury Advances GENIUS Act Implementation for Stablecoin Regulations and Opens Public Comment Period: On September 19, the Treasury Department opened a second public comment period for implementing the GENIUS Act, providing a 31-day window for stakeholder input on the legislation signed by President Trump in July. Treasury issued an advance notice of proposed rulemaking seeking feedback on regulatory implementation issues including issuer prohibitions, sanctions obligations, anti-money laundering compliance, federal-state oversight balance, and reserve asset custody requirements. The GENIUS Act is expected to take effect either 18 months after enactment or 120 days after Treasury and Federal Reserve finalize implementing regulations. More here and more here.
US-UK Establish Digital Asset Task Force for Regulatory Coordination: On September 22, the U.S. Treasury and His Majesty’s Treasury announced the formation of a transatlantic task force to explore short-to-medium term collaboration on digital assets regulation and policy coordination. The new initiative, called the Transatlantic Taskforce for Markets of the Future, will operate through the existing U.K.-U.S. Financial Regulatory Working Group and is mandated to release a report with recommendations within 180 days. The task force will examine cryptocurrency laws and regulations while exploring opportunities for collaboration on wholesale digital markets innovation, with officials stating they will seek input from leading industry experts to ensure recommendations address key industry concerns. More here.
International Bodies
Japanese Regulator Proposes Comprehensive Crypto Regulation Reform: On September 3, Japan’s Financial Services Agency (FSA) presented a comprehensive proposal to significantly reform cryptocurrency regulation by transferring oversight from the Payment Services Act to the Financial Instruments and Exchange Act (FIEA). The FSA report recommends treating cryptocurrencies under the securities regulation framework to strengthen investor protection and align crypto oversight with traditional financial instruments regulation. The agency identified several persistent issues in cryptocurrency investment that parallel problems traditionally addressed under FIEA, including unclear white papers, inaccurate disclosures, unregistered operations, investment scams, inadequate risk management, and security vulnerabilities within exchanges. The FSA concluded that applying FIEA mechanisms and enforcement tools may be appropriate for addressing cryptocurrency-related challenges, given the similarities to traditional securities issues. More here.
ECB President Lagarde Recommends Enhanced Safeguards for Foreign Stablecoins: On September 4, European Central Bank (ECB) President Christine Lagarde addressed EU lawmakers at a European Systemic Risk Board conference in Frankfurt, recommending that foreign stablecoins be subject to stringent requirements and safeguards before operating within EU jurisdiction. ECB President Lagarde warned that during a stablecoin run, investors would likely seek redemption in jurisdictions with stronger consumer protections, such as the EU where Markets in Crypto-Assets (MiCA) regulation prohibits redemption fees, potentially creating liquidity imbalances that could deplete local reserves. More here.
South Korea Prohibits Leveraged Crypto Lending Sets Twenty Percent Rate Cap: On September 5, South Korea’s Financial Services Commission (FSC) implemented new cryptocurrency lending regulations that establish a twenty percent interest rate cap and prohibit leveraged lending practices. The new framework restricts crypto lending to the top twenty tokens by market capitalization or those listed on at least three won-based exchanges, creating eligibility criteria for permissible lending assets. Under the new rules, exchanges must ensure that first-time borrowers complete online training programs and suitability assessments administered by the Digital Asset eXchange Alliance (DAXA), the industry’s local self-regulatory organization. More here.
Kazakhstan’s President Proposes Crypto Reserve, Digital Asset Legislation by 2026: On September 8, Kazakhstan President Kassym-Jomart Tokayev outlined comprehensive plans for the country’s digital asset development during his annual address, including the establishment of a strategic cryptocurrency reserve and comprehensive digital asset legislation. President Tokayev directed the government to create a “full-fledged ecosystem of digital assets as soon as possible” as part of broader efforts to maximize the return of bank funds to the national economy. He proposed that Kazakhstan’s Agency for Regulation and Development of the Financial Market draft legislation to establish this framework, with passage targeted before 2026. More here.
Vietnam Initiates 5-Year Crypto Market Pilot Program: On September 9, Vietnam launched a five-year cryptocurrency market pilot program implementing comprehensive regulatory requirements for digital asset operations within the country. Deputy Prime Minister Ho Duc Phoc signed a resolution establishing a framework for cryptocurrency trading and issuance, taking effect immediately. The pilot program mandates that all cryptocurrency transactions, including issuance, trading, and payments, must be conducted in Vietnamese dong, establishing the national currency as the exclusive medium for crypto operations. Under the new framework, cryptocurrency issuers must be Vietnamese enterprises registered as either limited liability companies or joint stock companies under the Law on Enterprises. More here.
South Korea Removes Restriction on Crypto Firms’ Venture Status Applications: On September 9, South Korea’s Ministry of SMEs and Startups announced the removal of restrictions preventing cryptocurrency businesses from obtaining venture company status, granting them access to tax incentives and financing support previously unavailable to the sector. During a cabinet meeting, the ministry passed a partial revision to the Enforcement Decree of the Venture Business Act that eliminates restrictions on virtual asset trading and brokerage businesses. The regulatory change, scheduled to take effect on September 16, will enable cryptocurrency firms to apply for venture certification and access associated benefits, including tax reductions, research and development grants, credit guarantees, and financing support. More here.
UK Petition for Blockchain Innovation Advances Following Industry Support: On September 11, a public petition calling for the UK to develop a comprehensive pro-innovation strategy for blockchain technology and stablecoins gained momentum following promotional support from cryptocurrency exchange Coinbase. The petition requests the establishment of a framework encompassing stablecoin regulation, blockchain adoption initiatives, and the appointment of a dedicated blockchain policy coordinator. More here.
UK Trade Groups Request Blockchain Inclusion in US Technology Agreement: On September 12, a coalition of twelve UK trade organizations representing finance, technology, and cryptocurrency industries submitted a joint letter to UK Business Secretary Peter Kyle and Economic Secretary to the Treasury Lucy Rigby, requesting the inclusion of blockchain technology in the UK-US “Tech Bridge” collaboration agreement. The trade groups, including the UK Cryptoasset Business Council (UKCBC), UK Finance, and TheCityUK, argued that distributed ledger technology should constitute a “core strand” of the bilateral technology partnership ahead of President Trump’s scheduled visit. More here.
ASIC Grants Licensing Exemptions to Stablecoin Issuers and Distributors: On September 18, the Australian Securities and Investments Commission (ASIC) introduced licensing exemptions for intermediaries involved in stablecoin distribution through the newly published ASIC Corporations (Stablecoin Distribution Exemption) Instrument 2025/631. The exemption allows intermediaries distributing stablecoins issued by licensed Australian Financial Services (AFS) entities to operate without requiring their own AFS, market, or clearing and settlement facility licenses. The exemption applies specifically to stablecoins classified as financial products under the Corporations Act and issued by eligible AFS-licensed entities, providing regulatory clarity for distribution networks while maintaining oversight of primary issuers. More here and here.
EU Regulators Disagree on MiCA Passporting Framework as France Considers Restrictions: On September 19, EU regulators faced growing tensions over the implementation of the MiCA framework as France’s securities regulator warned it may block cryptocurrency companies operating locally under licenses obtained in other EU member states. Marie-Anne Barbat-Layani, Chair of France’s Autorité des Marchés Financiers (AMF), said AMF is concerned about potential enforcement gaps and may refuse to recognize MiCA “passports” from other jurisdictions. The AMF expressed concerns that cryptocurrency companies are seeking licenses in more lenient EU jurisdictions to avoid stricter regulatory requirements, undermining MiCA’s promise of unified market access across the 27-nation bloc. More here and here.
EU Finance Ministers Establish Digital Euro Holdings Limits: On September 19, EU finance ministers reached consensus on establishing procedures for setting holding limits on digital euro balances, advancing the bloc’s central bank digital currency development during the Economic and Financial Affairs Council meeting in Copenhagen, Denmark. The agreement covers both the framework for determining individual holding ceilings and the broader issuance process for the digital euro, though officials clarified that specific limit amounts were not determined during the discussions. The procedural agreement follows previous ECB progress reports from late 2024 that identified holding limits as a significant design consideration for the EU’s CBDC implementation. More here.
UAE Signs OECD Agreement on Cryptocurrency Tax Information Sharing: On September 22, the United Arab Emirates Ministry of Finance announced its commitment to international cryptocurrency tax transparency by signing the Multilateral Competent Authority Agreement on the Automatic Exchange of Information under the Crypto-Asset Reporting Framework (CARF). The agreement formalizes the UAE’s participation in the Organization for Economic Cooperation and Development’s global digital asset reporting regime, which establishes mechanisms for automatic exchange of tax-related cryptocurrency information between participating jurisdictions to enhance international cooperation on transparency and tax compliance. The UAE plans to implement the framework beginning in 2027, with initial information exchanges scheduled to commence in 2028, joining fifty other jurisdictions that have committed to CARF adoption. More here.
Australia Proposes Legislation to Enhance Crypto Exchange Oversight: On September 24, Australian Assistant Treasurer Daniel Mulino announced draft legislation extending financial sector regulations to cryptocurrency exchanges, describing the measure as “the cornerstone” of the government’s digital asset roadmap released in March. The proposed legislation would create two new financial product categories under the Corporations Act: “digital asset platforms” and “tokenized custody platforms,” requiring service providers to obtain Australian Financial Services Licenses and register with the Australian Securities and Investments Commission. More here.