On Oct. 13, 2023, California Governor Gavin Newsom signed CA AB39, the Digital Financial Assets Law (DFAL), which is the first comprehensive framework to regulate the digital asset market in the state of California. As such, California joins New York and Louisiana as the third state to have a virtual currency specific regulatory licensing framework. While this GT Alert focuses on California, it is also worth noting that the Consumer Financial Protection Bureau is also considering using the Electronic Fund Transfer Act to protect consumers from fraudulent crypto transfers, showing that the desire to step up consumer protection in the virtual currency space is not limited to just California or even the states at large. The DFAL takes effect July 1, 2025.

Continue reading the full GT Alert.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Hilary R. Sledge-Sarnor Hilary R. Sledge-Sarnor

Hilary R. Sledge-Sarnor represents businesses and financial institutions in a range of legal matters. Hilary has over 15 years of experience representing financial institutions, corporate borrowers, funds and fund sponsors in a broad range of syndicated cross-border and domestic financings. Hilary is experienced…

Hilary R. Sledge-Sarnor represents businesses and financial institutions in a range of legal matters. Hilary has over 15 years of experience representing financial institutions, corporate borrowers, funds and fund sponsors in a broad range of syndicated cross-border and domestic financings. Hilary is experienced in a wide range of industries, including technology, fund finance retail and entertainment. She regularly provides counsel on secured transactions and UCC Article 9.

Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office…

Marina Olman-Pal, Co-Chair of the firm’s Financial, Regulatory & Compliance Practice, advises foreign and U.S. financial institutions on a broad range of regulatory matters including licensing, acquisitions, divestitures, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, and compliance with Office of Foreign Assets Control (OFAC) sanctions programs. Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, gaming companies, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies and digital payment companies. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including private and public financings, dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. She serves as a trusted advisor to public and private company boards of directors on governance matters and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and public and private companies in emerging technology, life sciences and biotechnology, defense and security, blockchain and digital assets, telecommunications, information technology, energy (traditional and renewable), mining, media, entertainment and sports. Barbara also represents Olympic and professional athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 1997 with Sullivan & Cromwell, LLP, and headed the international capital markets practice of Kirkland & Ellis LLP from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters, strategic alternatives, and digital asset structures. She serves on the Government of Bermuda’s Global FinTech Advisory Board.

Photo of Steven T. Cummings Steven T. Cummings

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial…

Steven T. Cummings focuses his practice on the regulation of financial services providers, including virtual currency companies, money transmitters, payment processors, and fintech companies.

In his prior role as the Virtual Currency Applications Team lead for the New York State Department of Financial Services, Steven supervised the virtual currency team in evaluating virtual currency applications for regulatory compliance with anti-money laundering, cybersecurity, and consumer protection requirements.