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<a href="#crypto">Crypto Firms Announce New Licenses, Products; USDT Stability Rating Lowered</a>

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<a href="#stablecoin">Major U.S. Bank Announces Stablecoin Pilot on Stellar Network</a>

<a href="#efts">U.S. Digital Asset Firms Announce ETFs, RWA Initiatives, Acquisitions</a>

<a href="#ethereum">Ethereum Foundation Activates Fusaka Network Upgrade</a>

<a href="#sec">SEC No-Action Letter Allows Offers/Sales of ‘Fuse’ Tokens Without Registration</a>

<a href="#chokepoint">U.S. House Financial Services Committee Publishes Report on ‘Choke Point 2.0’</a>

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Crypto Firms Announce New Licenses, Products; USDT Stability Rating Lowered

By <a href="https://www.bakerlaw.com/professionals/jonathan-cardenas/">Jonathan Cardenas</a>

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On Nov. 25, MoonPay, a crypto payments company, announced that its newly established trust company obtained a trust charter from the New York State Department of Financial Services (NYDFS). According to a press release, the trust charter enables the trust company to provide its client base with digital asset custody and over-the-counter trading services. With its approval from NYDFS, the trust company becomes one of a handful of digital asset companies that have obtained both a New York State BitLicense and a New York Limited Purpose Trust Charter.

In other news, the issuer of the USDC stablecoin announced that it has launched a new smart contract that enables stablecoin interoperability. The smart contract reportedly allows third parties “to launch their own interoperable, USDC-backed stablecoins with onchain reserves held in a Circle-deployed smart contract” and enables 1:1 transfers between USDC and USDC-backed stablecoins across supported blockchains. According to a press release, the smart contract utilizes an attestation service that verifies cross-chain transfers, which enables users to reduce their reliance on third-party bridging services.

Finally, a major U.S. credit rating agency recently published a report in which it downgrades its assessment of the ability of the USDT stablecoin to maintain its peg to the U.S. dollar. According to the report, the credit rating agency changed its stablecoin stability assessment rating of USDT from a rating of 4 (constrained) to a rating of 5 (weak) on the basis of several factors, which include, but are not limited to, increased USDT reserve exposure to high-risk assets and “persistent gaps” in governance-related disclosures. The report notes that Bitcoin represents the assets backing approximately 5.6% of USDT in circulation, which exceeds the stablecoin’s 3.9 percent overcollateralization margin, thereby implying that a drop in the value of Bitcoin would potentially lead to an under-collateralization of USDT. The report also notes that the issuer of USDT “continues to provide limited information on the creditworthiness of its custodians, counterparties, or bank account providers.”&nbsp;

For more information, please refer to the following links:

<a href="https://www.prnewswire.com/news-releases/moonpay-secures-new-york-trust-charter-to-expand-regulated-financial-infrastructure-302625161.html">MoonPay Secures New York Trust Charter to Expand Regulated Financial Infrastructure</a>

<a href="https://www.circle.com/blog/introducing-circle-xreserve?utm_source=substack&amp;utm_medium=email">Introducing [] xReserve: Enabling Interoperable USDC-Backed Stablecoins for Blockchains</a>

<a href="https://www.spglobal.com/ratings/en/regulatory/delegate/getPDF?articleId=3486415&amp;type=COMMENTS&amp;defaultFormat=PDF&amp;utm_source=substack&amp;utm_medium=email">Stablecoin Stability Assessment: Tether (USDT)</a>

Major US Bank Announces Stablecoin Pilot on Stellar Network

By <a href="https://www.bakerlaw.com/RobertAMusiala">Robert A. Musiala Jr.</a>

A recent press release announced that one of the largest U.S. banks is “testing custom stablecoin issuance on the Stellar network.” According to the press release, the bank is working on the stablecoin pilot with a Big Four accounting and consulting firm and the Stellar Development Foundation. In a quote from the press release, an executive from the bank noted that the bank selected the Stellar network for the pilot in part due to the Stellar platform’s “ability at their base operating layer to freeze assets and unwind transactions.”

For more information, please refer to the following link:

<a href="https://stellar.org/blog/ecosystem/u-s-bank-is-testing-custom-stablecoin-issuance-on-the-stellar-network">U.S. Bank is testing custom stablecoin issuance on the Stellar Network</a>

US Digital Asset Firms Announce &nbsp;ETFs, RWA Initiatives, Acquisitions

By <a href="https://www.bakerlaw.com/professionals/amos-kim/">Amos Kim</a><a href="https://www.bakerlaw.com/VeronicaReynolds"></a>

A major digital asset investment manager recently launched an exchange-traded fund (ETF) focused on LINK, the native token of Chainlink, a decentralized oracle network that enables smart contracts to securely interact with real-world data. According to the press release, the ETF is now trading on NYSE Arca, providing investors with regulated exposure to LINK. The press release described Chainlink as delivering verifiable data and cross-chain connectivity that supports tokenization and decentralized finance across public blockchains.

Separately, Plume, a real-world asset (RWA) tokenization platform, announced a partnership with Securitize. The announcement stated that the collaboration will enable Securitize to launch institutional-grade tokenized assets on Plume’s RWA staking protocol. According to the announcement, “This partnership connects the largest onchain RWA holder community to the most established tokenization platform in the world.”

In another development, Paxos, a blockchain infrastructure provider, announced that it has acquired Fordefi, an institutional self-custody wallet company. According to the press release, the acquisition will create a unified platform for clients to issue stablecoins, tokenize assets, and manage complex payment flows, while incorporating “deep decentralized finance integrations.”

<a href="https://etfs.grayscale.com/glnk">[] Chainlink Trust ETF</a>

<a href="https://plume.org/blog/securitize-to-launch-on-plume?utm_source=LinkedIn&amp;utm_medium=Social&amp;utm_campaign=Securitize_Solv&amp;utm_content=Securitize_LI">Securitize to Launch on Plume, Connecting Institutional Assets to 280K+ RWA Holders</a>

<a href="https://www.paxos.com/newsroom/paxos-acquires-fordefi-to-build-the-custody-infrastructure-layer-to-power-the-on-chain-economy">Paxos Acquires Fordefi to Build the Custody Infrastructure Layer to Power the On-Chain Economy</a>

Ethereum Foundation Activates Fusaka Network Upgrade

On Dec. 3, the Ethereum Foundation activated the Fusaka network upgrade to the Ethereum Network. According to a blog post by the Ethereum Foundation, key features of the Fusaka upgrade include the following:

EIP-7594: Increases blob throughput resulting in increased scalability for L2s.

EIP-7823 &amp; EIP-7883: Ensures that resource-intensive cryptographic operations are properly priced and support potential future block gas limit increases.

EIP-7825: Implements a protocol-level transaction gas limit cap, preventing individual transactions from consuming excessive block gas and protecting against DoS attacks.

EIP-7917: Introduces deterministic proposer lookahead, allowing validators and users to know which validator is proposing which block ahead of time.

EIP-7918: Introduces a blob fee floor for L2 transactions.

EIP-7934: Implements a block size limit resulting in increased network security.

EIP-7939: Reduces gas costs for certain operations, including ZK-proofs.

EIP-7951: Improves Ethereum’s integration with mobile infrastructure and enables more responsive Layer 2 experiences.

<a href="https://blog.ethereum.org/2025/11/06/fusaka-mainnet-announcement">Fusaka Mainnet Announcement</a>

<a href="https://www.crowdfundinsider.com/2025/12/256157-ethereum-eth-fusaka-upgrade-now-live/">Ethereum (ETH) Fusaka Upgrade Now Live</a>

<a href="https://www.fidelitydigitalassets.com/research-and-insights/fusaka-upgrade-scaling-meets-value-accrual">The Fusaka Upgrade: Scaling Meets Value Accrual</a>

SEC No-Action Letter Allows Offers/Sales of ‘Fuse’ Tokens Without Registration

By <a href="https://www.bakerlaw.com/KeithRMurphy">Keith R. Murphy</a>

On Nov. 24, the U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance (Division) published a statement in response to a request for no-action relief (No-Action Letter) concerning certain proposed tokens (Tokens) that would reward smarter energy behavior by consumers. According to the No-Action Letter filed on behalf of Fuse Crypto Limited (Fuse), the company is registered in Jersey and is a “vertically integrated energy technology group focused on accelerating the decentralization of electricity grids, optimizing energy delivery, and empowering consumers to lower their electricity related costs.”

The Tokens are intended “to reward consumers for their contributions within the Fuse Network, and so to support smarter energy behavior such as shifting demand to align with grid needs or generating and storing energy for peak times – not to serve as an appreciating or investment asset,” according to the No-Action Letter. The No-Action Letter seeks assurance that the Division will not recommend that the SEC take enforcement action if Fuse offers and sells the Tokens without registration under Section 5 of the Securities Act of 1933 and Section 12(g) of the Securities and Exchange Act of 1934.&nbsp;

The No-Action Letter provides a detailed description of the proposed formula for awarding Tokens and the limits of their use, and among other points argues that the Tokens would not satisfy the fourth prong of the “Howey test,” including because (i) the Tokens are utilized in the Fuse Network for purposes of receiving discounts on Fuse Goods and Services; (ii) the Tokens are not and will not be marketed as an investment or otherwise in a manner that would result in a purchaser having an expectation of profit; and (iii) any upside for earning, holding, redeeming and selling the Token does not have anything to do with the success of Fuse or the Fuse Network, and therefore it would not cause a reasonable purchaser to have an expectation of profit based on such success and efforts.

The SEC granted the No-Action Letter’s request, stating in the Division’s response that “[b]ased on the facts presented, the Division will not recommend enforcement action to the Commission if, in reliance on your opinion as counsel, Fuse offers and sells the Tokens in the manner and under the circumstances described in your letter without registration under Section 5 of the Securities Act and does not register the Tokens as a class of equity securities under Section 12(g) of the Exchange Act.”

<a href="https://www.sec.gov/rules-regulations/no-action-interpretive-exemptive-letters/division-corporation-finance-no-action/fuse-crypto-limited-112425">Fuse Crypto Limited</a>

<a href="https://www.sec.gov/files/corpfin/no-action/fuse-incoming-final-conformed-111925.pdf">Re: Fuse Crypto Limited</a>

US House Financial Services Committee Publishes Report on ‘Choke Point 2.0’

On Dec. 1, the U.S. House of Representatives Committee on Financial Services released a 53-page final staff report titled Operation Choke Point 2.0: Biden’s Debanking of Digital Assets. According to the report, “Committee Republicans identified a pattern of Biden Administration prudential regulators abusing their regulatory, supervisory, and enforcement authorities to push entities involved in the digital asset ecosystem out of the U.S. financial system.” Among its many findings, the report finds, “Lack of regulatory clarity, uncertain access to financial services, and rampant, exstatutory enforcement activity against the digital asset ecosystem created a broad chilling effect across the banking industry that resulted in the debanking of at least 30 entities and individuals engaging in digital asset-related activities.” The report concludes, “By utilizing the banking system to enforce ideological goals, the Administration bypassed Congress, undermined due process, and threatened the principles of a free market economy.”

The report provides recommendations for future actions “to establish long lasting clarity in the digital asset markets. These include modernizing the securities laws to oversee the digital asset markets where appropriate; effectively implementing the GENIUS Act; formal notice and comment rulemaking to provide clarity to financial institutions engaging in digital asset activities; reforming the CAMELS rating system; enacting digital asset market structure legislation; and passing various pending bills addressing the financial services industry.

<a href="https://financialservices.house.gov/uploadedfiles/2025-11-30_--_fsc_debanking_report_final_1.pdf">OPERATION CНОКЕ POINT 2.0: BIDEN’S DEBANKING OF DIGITAL ASSETS Final Staff Report</a>

<a href="https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-114.html">Comptroller Issues Statement on Congressional Debanking Report</a>

Weekly Blockchain Blog – December 8, 2025