LIVE WATCH

Regulatory Developments That Affect You

Curated by our compliance team. Updated monthly.

Hard Deadlines

In-Force Requirements

Regulatory Coordination

Proposals & Comment

Strategic Watch

NYDFS Part 500 — Annual Certification of Compliance LIVE NOW

All covered entities must file annual certification covering 2025 calendar year, including new MFA and asset inventory requirements. Annual certification due April 15. Non-compliance may result in significant supervisory action.

DEADLINE: APRIL 15, 2026

California DFAL — Digital Financial Assets Law PREVIEW / LIMITED

Digital asset businesses engaging in covered activities in California may require licensing by DFPI under the Digital Financial Assets Law. Applications opened March 9, 2026. Certain exemptions apply. The July 1 threshold is approaching for covered businesses.

THRESHOLD: JULY 1, 2026 · APPLICATIONS: OPEN SINCE MARCH 9, 2026

DTCC Tokenization Services Launch PLANNED / UPCOMING

DTC Participants will likely need to register wallets, implement OFAC screening, and establish compliance controls for tokenized entitlements once the service launches.

EXPECTED: H2 2026

NYDFS Part 500 — MFA for All Users LIVE NOW

Covered entities must require MFA for access to any information system by any user. NYDFS recommends phishing-resistant (FIDO2/hardware token) MFA. Top enforcement priority.

IN FORCE: NOVEMBER 1, 2025

NYDFS Part 500 — Dynamic Asset Inventory LIVE NOW

Written policies and procedures for creating and maintaining information system asset inventories. NYDFS brought enforcement action in 2024 for asset inventory failures.

IN FORCE: NOVEMBER 1, 2025

OCC IL 1183 — Bank Crypto-Custody Posture LIVE NOW

OCC rescinded the prior "non-objection" requirement for national banks providing crypto custody services. Banks may now provide digital asset custody and settlement services in a safe-and-sound manner without prior OCC approval, subject to appropriate risk management and disclosures.

IN FORCE: MARCH 2025

GENIUS Act — Payment Stablecoin Framework LIVE NOW

Comprehensive federal framework: 1:1 reserve backing, monthly CPA examination, executive certification, redemption procedures. Administered by OCC, FDIC, Fed, and state regulators.

IN FORCE: JULY 2025

SEC-CFTC Memorandum of Understanding METHODOLOGY SIGNAL

Signed March 11, 2026. Establishes coordinated oversight framework for digital asset clearing and market infrastructure. While not a binding rule source, DAC incorporates this coordination signal into our regulatory logic mapping to reflect how agencies are aligning expectations.

SIGNED: MARCH 11, 2026

SEC Tokenized Securities Joint Statement LIVE NOW

Three SEC divisions jointly issued taxonomies for issuer-sponsored and third-party tokenized securities. Existing securities laws apply regardless of format. Most comprehensive tokenization guidance to date.

ISSUED: JANUARY 28, 2026

Federal Reserve — Skinny Master Accounts PLANNED / UPCOMING

Fed targeting Q4 2026 availability for limited master accounts accessible to legally eligible digital asset institutions. Public comment period expected.

EXPECTED: Q4 2026

CLARITY Act — Digital Asset Market Structure PENDING

Passed House July 2025. Under Senate consideration. Would establish comprehensive regulatory regime for digital asset brokers, dealers, and exchanges. Could create new registration categories.

STATUS: PENDING SENATE ACTION

GENIUS Act — FinCEN/Treasury Implementation Rulemaking COMMENT PERIOD

FinCEN and Treasury issued requests for comment on identity verification, sanctions screening, Travel Rule interoperability, and analytics requirements for stablecoin compliance.

STATUS: COMMENT PERIOD THROUGH MID-2026

Nasdaq Tokenized Stock Trading Rule UNDER REVIEW

Proposed 24/7 trading of tokenized securities on-exchange with instant settlement. SEC instituted proceedings December 2025. Amendment No. 2 filed January 2026.

STATUS: SEC REVIEW IN PROGRESS

SEC Innovation Exemption / Sandbox PLANNED / UPCOMING

Expected framework allowing companies to test novel digital asset business models under principles-based safeguards rather than full compliance. Would accelerate tokenization adoption.

EXPECTED: 2026

New OCC Crypto Banking Charters LIVE NOW

Six companies received preliminary approval in 2025 (BitGo, Circle, Paxos, Fidelity Digital, Erebor, Ripple). Additional approvals expected 2026. Each will need full compliance frameworks.

ONGOING: 2025–2026

EU MiCA — Markets in Crypto-Assets Regulation PLANNED / UPCOMING

For firms with active EU solicitation. MiCA licensing and compliance framework will be available as a DAC module. Relevant for U.S. firms marketing to or serving European clients.

DAC MODULE: PLANNED

Investment Adviser AML Classification PLANNED / UPCOMING

FinCEN adopted rule reclassifying Registered Investment Advisers as financial institutions for BSA/AML purposes. Affects crypto-focused RIAs.

EFFECTIVE: JANUARY 1, 2028

HOW IT WORKS

From blind spots to exam-ready.

Three steps. One platform. Every requirement traced to the source.

Readiness Snapshot

Starting at $5,000

Board-ready gap analysis mapping your regulatory exposure with every finding cited to the source regulation — delivered in 5 business days.

DAC Platform

$2,750/mo · billed annually

Your regulatory map stays current with automated monitoring, monthly change alerts, and compliance workpapers. Your full $5,000 Snapshot fee is credited toward your first annual DAC Platform subscription if signed within 30 days of report delivery.

DAC Readiness

$5,000/mo · billed annually

Full exam preparation with risk-rated findings in MRA/MRIA format, remediation priorities, and board-ready quarterly reports.

STAGE 1: EXPOSURE PREVIEW

Map your regulatory perimeter.

Answer 12 activity-based questions. Our deterministic engine maps which of 199 requirements apply to your entity — with every finding traced to a specific CFR section, NYCRR provision, or agency guidance.

Your full $5,000 Snapshot fee is credited toward your first annual DAC Platform subscription if signed within 30 days of report delivery.

Start Your Exposure Preview → Skip to Full Snapshot

No signup required for the preview. The full Snapshot is a paid engagement delivered within 5 business days.

COVERAGE

13 regulatory anchors. 199 requirements in our database.

Your Readiness Snapshot maps only the requirements that apply to your entity, licenses, and activities. Every finding cited to a specific CFR section, NYCRR provision, or agency guidance document.

FinCEN

BSA/AML Compliance

requirements

LIVE

OFAC

Sanctions & Asset Blocking

requirements

LIVE

NYDFS

BitLicense & Part 500 Cybersecurity

requirements

LIVE

SEC

Securities & Tokenization

requirements

LIVE

CFTC

Derivatives & Commodities

requirements

LIVE

OCC

National Bank & Trust Custody

requirements

LIVE

CFPB

Consumer Financial Protection (Fiat EFT)

requirements

LIVE

State MTL

Multi-State Money Transmitter

requirements

LIVE

GENIUS Act

Payment Stablecoin Framework

requirements

LIVE

CA DFAL

California Digital Financial Assets

requirements

PREVIEW

EU MiCA

Markets in Crypto-Assets

requirements

PREVIEW

Token Taxonomy

SEC/CFTC Joint Classification (March 2026)

requirements

LIVE

SMART Act

SEC-CFTC Coordination

requirements

STRATEGIC WATCH

LIVE Fully mapped and source-cited · PREVIEW Mapped, newly enacted or pending enforcement · STRATEGIC WATCH Proposed legislation tracked for planning

PRICING

Transparent pricing. No surprises.

Start with a Snapshot. Scale into the platform when you're ready.

READINESS SNAPSHOT

$5,000+

Fixed-scope. Delivered in 5 business days.

Your regulatory exposure mapped, gaps identified, and remediation priorities delivered — all cited to the source regulation.

Board-ready report delivered in 5 business days
Practitioner-reviewed gap findings with risk ratings
Source-cited requirement map (CFR, NYCRR)
Remediation priority matrix

100% CREDITED

Your full $5,000 Snapshot fee is credited toward your first annual DAC Platform subscription if signed within 30 days of report delivery.

Start Your Readiness Snapshot → or book a call first See a sample Snapshot →

This is where most firms start. Your Snapshot fee is 100% credited toward Platform if signed within 30 days.

Why DAC

Built by compliance practitioners with Certified Crypto Auditor credentials and over a decade of experience across federally regulated financial institutions.

Every Snapshot is reviewed by a practitioner before delivery.

Fixed-scope engagement with a defined deliverable — not an open-ended consulting retainer.

Comparable outside counsel: $50,000-$150,000

DAC Snapshot: $5,000, 5 business days

DAC PLATFORM COMING SOON

$2,750/mo

Billed annually at $33,000/yr. Available after Snapshot delivery. Your full $5,000 Snapshot fee is credited toward your first annual DAC Platform subscription if signed within 30 days of report delivery.

Your regulatory map stays current. Ongoing monitoring, self-assessment tools, and compliance workpapers — built on your Snapshot baseline.

Everything in the Snapshot
Living regulatory map (client portal)
Monthly regulatory change alerts
Self-assessment framework
Compliance workpaper downloads
Gap visibility dashboard
Quarterly compliance summaries

Book a Call to Discuss →

Available after Snapshot delivery. Your full $5,000 Snapshot fee is credited toward your first annual DAC Platform subscription if signed within 30 days of report delivery.

DAC READINESS COMING SOON

$5,000/mo

Billed annually at $60,000/yr. Available after Snapshot delivery. Includes everything in Platform plus exam preparation and board reporting.

Full exam preparation. Risk-rated gap findings with remediation priorities. Mock exam findings in MRA/MRIA language. Board-ready quarterly reports.

Everything in the Platform
Risk-rated gap findings
Remediation priority matrix
Mock exam findings (MRA/MRIA format)
Document readiness checklists
Board-ready quarterly reports
Optional document review pipeline

Book a Call to Discuss →

Available after Snapshot delivery. Includes everything in Platform plus exam preparation and board reporting.

INSTITUTIONAL

Custom

For banks, exchanges, and market infrastructure.

Federal planning, stablecoin readiness, tokenization compliance, and full regulatory perimeter analysis.

Everything in Readiness
Multi-regulator perimeter mapping
Federal charter planning
Tokenized securities compliance
Custom regulatory modules
Dedicated engagement lead

What's involved after purchase? ▼

Scoping form — 2 minutes. Entity type, licenses, and key activities.

Customized questionnaire — 15-20 minutes. Tailored to your regulatory perimeter. Covers policies, operations, screening, and controls.

DAC generates your Snapshot — deterministic regulatory mapping, AI-drafted findings, 8-check CCO review, and practitioner sign-off.

Board-ready deliverable — Word document (.docx) + Excel requirement map (.xlsx) delivered within 5 business days.

Review call — Optional 30-minute walkthrough of findings and remediation priorities.

Total active time for your team: ~60 minutes. DAC handles the rest.

METHODOLOGY

How we map your regulatory logic.

DAC logic is built on a disciplined Hierarchy of Authority to ensure every finding is traceable, defensible, and exam-ready.

TIER 1

Binding Requirements

Federal statutes, federal regulations (CFR), state regulations (NYCRR), and other codified rules. These are non-negotiable. A violation is an enforcement event.

TIER 2

Supervisory Guidance

Industry letters, advisories, no-action letters, and interpretive materials. Not law, but examiners treat them as expected practice.

TIER 3

Enforcement-Informed Risk

Documented patterns from consent orders, settlements, and examination findings. Where the examiner has historically focused.

TIER 4

Emerging Frameworks

Proposed rulemakings (NPRMs), interagency MOUs, and strategic watch items. Not yet binding, but shaping the future landscape.

Read Our Full Methodology →

WHO BUILDS THIS

Practitioner-built. Designed for examination readiness.

We watched firms spend $100,000+ on law firm gap analyses that were outdated before the ink dried — and small firms get nothing because they couldn't afford the engagement. DAC was built to make regulatory mapping fast, source-cited, and accessible to every digital asset firm that takes compliance seriously.

DAC is built by compliance practitioners with Certified Crypto Auditor credentials and over a decade of experience across federally regulated financial institutions, clearinghouses, and mortgage lending. The methodology reflects how examiners actually conduct reviews — the Hierarchy of Authority, severity classifications, and MRA/MRIA-format findings come from real examination experience.

Every requirement in our database is individually validated against its primary source. If we cite 31 CFR 1022.210, we've read 31 CFR 1022.210. No secondary summaries. No third-party compilations.

DAC is a founder-led compliance firm with software leverage — not a generic SaaS platform. Every Snapshot is reviewed by a practitioner before delivery. The technology accelerates the work; human judgment guides the output.

WHAT YOU RECEIVE

A defensible regulatory map — not a compliance opinion.

The Readiness Snapshot is a fixed-scope assessment delivered as a board-ready document. Every finding is cited to a specific regulation, statute, or supervisory guidance.

Regulatory Perimeter Map

Which regulators have jurisdiction, why, and how many requirements apply — based on your entity type, licenses, and activities.

Prioritized Gap Findings

HIGH / MEDIUM / LOW severity findings, each with a regulatory citation, description, remediation path, and target timeline.

Remediation Priority Matrix

All findings ranked by severity with timelines. Formatted so your CCO can present it to the board or use it as an exam-response roadmap.

Source-Cited Methodology

Every requirement traced to its primary source (CFR, NYCRR, agency guidance). The Hierarchy of Authority classification is included so you know how examiners will weight each finding.

See a Sample Snapshot →

WHO THIS IS FOR

Built for firms that take compliance seriously.

DAC IS BUILT FOR:

Digital asset companies navigating U.S. regulatory requirements
Exchanges, custodians, payment platforms, and lending desks
Stablecoin issuers and reserve managers
Broker-dealers and investment advisers touching digital assets
Banks and trust companies with digital asset operations
Firms preparing for state or federal examination
Pre-launch companies building compliance architecture before going live
Teams that need a defensible compliance baseline — fast

DAC IS NOT FOR:

Firms looking for legal advice or legal opinions
Projects seeking a "compliance stamp" without real remediation
Pure DeFi protocols with no centralized entity or operator
Teams that want generic compliance templates
Firms already working with a full-service compliance team

DATA SECURITY

Built for compliance officers.

We built DAC for professionals who are paid to be skeptical about where their data goes.

🛡

No Document Upload Required

The Readiness Snapshot and DAC Platform use structured questionnaires and self-assessment. Your sensitive policies and internal documents never leave your environment.

🔒

Client-Side Anonymization

DAC Readiness clients who opt into document review — PII is stripped in your browser before anything is transmitted. You control what leaves your environment.

✓

Client Approval Gate

You review the anonymized version and explicitly approve before any processing begins. No data moves without your sign-off.

∅

Zero Data Retention

No sensitive policy documents are stored on our servers. Analysis is performed via deterministic intake and real-time mapping. Contractually guaranteed in our engagement letter.

Source-linked compliance mapping
for digital asset firms.

Know exactly where you stand.

Source-linked compliance mappingfor digital asset firms.

Know exactly where you stand.

Source-linked compliance mapping
for digital asset firms.