Max Earp-Thomas

Max advises banks, fintechs, credit unions, digital asset companies, and other financial services providers to mitigate regulatory and enforcement risk.

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On September 24, 2026, the Federal Reserve Board requested public comment on two proposed rules implementing the Fed’s responsibilities under the GENIUS Act, establishing a regulatory framework for Board-supervised payment stablecoin issuers. The GENIUS Act, enacted in July 2025, established the first federal regulatory framework for dollar-backed cryptocurrency tokens known as stablecoins. For banks and bank holding companies evaluating whether to enter the stablecoin market, the proposals may be among the clearest signals yet of the operational, capital, and application requirements they could face.

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Federal prosecutors in the Southern District of New York have filed criminal complaints against two former Robinhood Markets, Inc. engineers, alleging they used confidential information about upcoming cryptocurrency listings on Robinhood Crypto to trade profitably on Hyperliquid, an offshore decentralized derivatives exchange. The scheme came to light after Robinhood conducted an internal investigation and referred the matter to law enforcement. The cases illustrate an emerging enforcement priority: prosecutors are extending traditional insider-trading theories to decentralized, unregistered derivatives markets.