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  • CFTC Division of Market Oversight Issues Prediction Markets Staff Advisory, March 2026

    On March 12, 2026, the CFTC's Division of Market Oversight (DMO) issued a staff advisory addressed to Designated Contract Markets (DCMs) regarding the listing and trading of event contracts on prediction markets. The advisory is a guidance document, not a rulemaking, and does not amend existing CFTC regulations. It takes effect upon issuance and is currently operative. This action accompanied a parallel Advance Notice of Proposed Rulemaking (ANPRM) issued the same day (CFTC Press Release 9194-26). The advisory directs DCMs to their existing obligations under the Commodity Exchange Act, specifically CEA Section 5(d) and 17 CFR Part 38, DCM Core Principle 3 and the guidance in Appendix C to Part 38, and product submission requirements under Part 40. Core Principle 3 requires a DCM to list only contracts that are not readily susceptible to manipulation. The advisory also addresses specific considerations relevant to sports-related event contracts, including the potential for manipulation and the public interest assessment that DCMs must conduct before listing such contracts. DCMs that currently list or intend to list prediction market event contracts must treat this advisory as a formal signal from the DMO to review their compliance posture under CEA Section 5(d) and Part 38. DCMs should assess whether their listing procedures for event contracts satisfy Core Principle 3 and Appendix C requirements. The advisory expressly calls on DCMs to take proactive steps as "front-line regulators" to ensure their markets evolve in compliance with the CEA and Commission regulations. Non-DCM operators of prediction market platforms should note that the advisory reinforces the CFTC's position that event contracts fall within its exclusive jurisdiction. The advisory does not alter the legal standard for listing event contracts or create new obligations beyond those already in CEA Section 5(d) and Part 38. The concurrent ANPRM (91 FR 12516) may eventually result in new or amended rules that would supersede portions of this advisory's guidance. DCMs and their compliance teams should monitor ANPRM developments and submit comments by the April 30, 2026 deadline to influence any forthcoming regulatory changes. Source: CFTC Division of Market Oversight Staff Advisory, "Prediction Markets Advisory" (Mar. 12, 2026); CFTC Press Release No. 9193-26. Available at: https://www.cftc.gov/PressRoom/PressReleases/9193-26. Confirmed: March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • CFTC Issues Prediction Markets ANPRM, Opens 45-Day Comment Period, March 2026

    On March 12, 2026, the U.S. Commodity Futures Trading Commission issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking public comment on whether to amend or issue new regulations governing event contracts traded on prediction markets. The ANPRM was published in the Federal Register on March 16, 2026, as Document No. 2026-05105 (91 FR 12516). This is a pre-rulemaking stage: no proposed rule text has been issued. The Commission will use comments received to inform whether and how to proceed with a formal rulemaking. The governing statute is the Commodity Exchange Act (CEA), and the ANPRM operates under 17 CFR Chapter I (RIN 3038-AF65). The ANPRM asks questions concerning the application of statutory core principles and Commission regulations to prediction markets, the types of event contracts that may be prohibited as contrary to the public interest under CEA Section 5c(c)(5)(C), cost-benefit considerations under CEA Section 15(a), and product submission requirements under Part 40 of Commission regulations. Chairman Michael S. Selig stated that the ANPRM "begins the process of new rulemaking grounded in a rational and coherent interpretation of the Commodity Exchange Act." Prediction market operators, registered Designated Contract Markets (DCMs), Swap Execution Facilities (SEFs), and intermediaries that list or facilitate trading of event contracts should treat the ANPRM as the opening of a formal consultation process. Market participants who wish to influence how the CFTC defines permissible event contracts, applies core principles, or structures the public-interest prohibition must submit written comments. This action also signals that the CFTC asserts exclusive federal jurisdiction over these markets, potentially displacing state-level restrictions on prediction market activities. The comment period closes 45 days from the March 16, 2026 Federal Register publication date, placing the deadline on or about April 30, 2026. Comments may be submitted via the CFTC's Public Comments Portal. The ANPRM does not itself change existing rules; current Part 38 DCM core principles and the CEA Section 5(d) core principles continue to apply unchanged pending any final rulemaking. Separately, the CFTC's Division of Market Oversight issued a companion staff advisory on the same date (CFTC Press Release 9193-26) reminding DCMs of their existing regulatory obligations, particularly regarding sports-related event contracts. Source: Commodity Futures Trading Commission, Advance Notice of Proposed Rulemaking, "Prediction Markets," 91 FR 12516, Document No. 2026-05105 (Mar. 16, 2026); CFTC Press Release No. 9194-26 (Mar. 12, 2026). Available at: https://www.cftc.gov/PressRoom/PressReleases/9194-26 and https://www.federalregister.gov/documents/2026/03/16/2026-05105/prediction-markets. Confirmed: March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Ensuring National AI Policy Framework Executive Order 14365, December 2025

    On December 11, 2025, President Donald Trump signed Executive Order 14365, titled "Ensuring a National Policy Framework for Artificial Intelligence," published in the Federal Register on December 16, 2025 (90 Fed. Reg. 58499). The EO is a final, operative directive effective upon signing. It builds on EO 14179 of January 23, 2025 ("Removing Barriers to American Leadership in Artificial Intelligence") and directs federal agencies to assert primacy over state AI regulation through spending conditions and agency review mechanisms. Section 4 of EO 14365 directs the Assistant to the President for Science and Technology (APST), in consultation with the Special Advisor for AI and Crypto, to evaluate existing state AI laws and identify those that impose restrictions the administration deems onerous. Section 5(a) conditions eligibility for funding under the Broadband Equity, Access, and Deployment (BEAD) program (47 U.S.C. §§ 1702(e)–(f)) on states not maintaining such laws. A separate provision addresses state laws that would compel AI developers to engage in conduct the federal government characterizes as deceptive, directing agencies to assess whether discretionary grant programs should similarly exclude states with such requirements. For AI developers and deployers — including those building AI systems for DeFi protocols, crypto compliance tools, and automated trading infrastructure — EO 14365 signals that federal executive authority, not state legislatures, will set the primary rules for AI deployment in the United States. States that have enacted or plan to enact AI-specific disclosure, liability, or registration requirements may find those laws targeted in the Section 4 review. States with such laws on the books also face potential loss of BEAD program broadband infrastructure funding, which can reach hundreds of millions of dollars per state. No federal statute yet codifies the EO's preemption approach; the order operates through executive branch spending conditions and agency review, not through direct statutory preemption of state law. Which specific state laws will be designated "onerous" under Section 4, and what process states may use to contest such a designation, remain open questions as of March 16, 2026. The order's interaction with state AI laws already in force — including those in Colorado, California, and Texas — and with pending state legislation across dozens of jurisdictions is an active area of legal and legislative development. Source: Executive Order 14365 of December 11, 2025, "Ensuring a National Policy Framework for Artificial Intelligence," 90 Fed. Reg. 58499 (December 16, 2025), https://www.federalregister.gov/documents/2025/12/16/2025-23092/ensuring-a-national-policy-framework-for-artificial-intelligence , confirmed March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Germany Adopts Official Government Draft of AI Market Surveillance and Innovation Act, February 2026

    On 10 February 2026, the German Federal Cabinet (Bundesregierung) adopted the official government draft (Regierungsentwurf) of the AI Market Surveillance and Innovation Act (Gesetz zur Durchführung der europäischen KI-Verordnung, abbreviated KI-MIG). The draft is at the legislative proposal stage: following cabinet adoption, it must pass through the German Bundestag (lower house) and, where required, the Bundesrat (upper house) before it becomes enacted federal law. The KI-MIG serves as Germany's domestic implementing legislation for Regulation (EU) 2024/1689 — the EU AI Act — which entered into force on 1 August 2024. The EU AI Act (Regulation (EU) 2024/1689) is the directly applicable superior instrument. The KI-MIG designates national market surveillance authorities in Germany and provides domestic procedural rules for enforcement, sanctions, and coordination with EU bodies. The draft addresses which German authorities receive supervisory competence — a matter the EU AI Act leaves to member-state designation under Article 70 — and allocates responsibilities across federal and state-level bodies. The Federal Cabinet's adoption of the Regierungsentwurf on 10 February 2026 was confirmed at the government press conference (Regierungspressekonferenz) of 11 February 2026, which listed "Entwurf eines Gesetzes zur Durchführung der europäischen KI-Verordnung" as a key agenda item. AI system providers, deployers, and importers operating in Germany comply with the EU AI Act's obligations directly by virtue of that regulation's direct applicability. The KI-MIG determines which German authority will conduct market surveillance, receive complaints, and impose penalties. AI developers deploying systems in Germany — including tools used for automated risk assessment, algorithmic trading, and smart-contract compliance analysis — must identify the competent national authority and understand the domestic procedures that will govern enforcement. The act also governs Germany's designation of notified bodies for conformity assessments under the EU AI Act. The Regierungsentwurf now moves through the Bundestag's legislative process, and the passage timeline is open as of March 16, 2026. External deadlines imposed by the EU AI Act set the urgency: rules on prohibited AI practices applied from 2 February 2025; rules on general-purpose AI models apply from 2 August 2025; and most remaining provisions apply from 2 August 2026. Germany must have its national supervisory architecture in place before those application dates to avoid an enforcement gap. Source: German Federal Government (Bundesregierung), Government Press Conference of 11 February 2026, "Regierungspressekonferenz vom 11. Februar 2026," https://www.bundesregierung.de/breg-de/suche/regierungspressekonferenz-vom-11-februar-2026-2406846 , confirmed March 16, 2026. Superior instrument: Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 (EU AI Act), OJ L 2024/1689. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Trump Signs Executive Order Targeting Transnational Cybercrime and Crypto Fraud, March 2026

    On 6 March 2026, President Donald Trump signed an executive order titled "Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens." The order is immediately effective as a presidential directive. It does not require Congressional action. The order imposes mandatory review and action-plan timelines on multiple cabinet departments and expressly targets cyber-enabled fraud schemes — including ransomware, phishing, and financial fraud — many of which exploit cryptocurrency infrastructure and digital asset payment channels. Section 1 of the order states the policy of the United States to "protect Americans from, and harden our financial and digital systems against" cybercrime and predatory schemes from Transnational Criminal Organizations (TCOs). Section 2(a) directs the Secretary of State, the Attorney General, the Secretary of Homeland Security, and other named officials to complete, within 60 days, a review of existing operational, technical, diplomatic, and regulatory frameworks, and within 120 days, to submit a comprehensive action plan identifying TCOs and proposing solutions to prevent, disrupt, investigate, and dismantle them. Section 3 directs the Attorney General to submit, within 90 days, a recommendation on establishing a Victims Restoration Program funded by clawbacks, forfeitures, and seizures from TCOs. For crypto and Web3 market participants, the order signals heightened federal law-enforcement focus on crypto-facilitated fraud. Ransomware operators, scam-center operators that use cryptocurrency payment rails, and entities enabling cybercrime through digital asset platforms face a stated policy of "commensurate response that includes law enforcement, diplomacy, and potential offensive actions." Section 2(e) directs the CISA Director to partner with a new National Coordination Center operational cell to provide training and technical assistance to state, local, tribal, and territorial partners, and to share threat intelligence with those partners. Section 4 directs the Secretary of State to engage foreign governments demanding enforcement against TCOs and to impose consequences — including sanctions, visa restrictions, and trade penalties — on nations that tolerate such activity. Section 5(a) contains a standard non-impairment clause preserving existing agency authority. The order does not amend any statute or create privately enforceable rights. The key deadlines are: interagency review by approximately May 5, 2026 (60 days); Victim Restoration Program recommendation by approximately June 4, 2026 (90 days); and full action plan by approximately July 4, 2026 (120 days). No implementing regulations or guidance have been issued as of March 16, 2026. Source: Executive Order of March 6, 2026, "Combating Cybercrime, Fraud, and Predatory Schemes Against American Citizens," The White House, https://www.whitehouse.gov/presidential-actions/2026/03/combating-cybercrime-fraud-and-predatory-schemes-against-american-citizens/ , confirmed March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • California DFPI Opens Digital Asset License Applications Under DFAL, March 2026

    On 9 March 2026, the California Department of Financial Protection and Innovation (DFPI) began accepting license applications under the Digital Financial Assets Law (DFAL), Cal. Fin. Code §§ 3200–3272 (enacted as Assembly Bill 39 and Senate Bill 401, signed October 13, 2023, and subsequently amended by Assembly Bill 1934, signed September 29, 2024). The DFAL license requirement becomes mandatory on July 1, 2026, by which date any entity engaging in digital financial asset business activity serving California residents must hold a DFPI license or have submitted a completed application. The opening of the application portal on March 9, 2026 gives applicants approximately four months to prepare and file before the hard deadline. The controlling authority is Cal. Fin. Code § 3201, which prohibits any entity from engaging in "digital financial asset business activity" without a DFPI license. Section 3200(k) defines that term to include exchanging, storing, or transferring a digital financial asset, including a crypto asset. The DFPI holds rulemaking authority under Section 3260 and has issued implementing regulations addressing application procedures, capital requirements, and consumer protection standards. AB 1934 extended the original July 1, 2025 deadline by one year to July 1, 2026. Crypto exchanges, custodians, wallet providers, kiosk operators, and other entities that exchange, store, or transfer crypto assets for California residents must obtain a DFAL license before July 1, 2026 or submit a completed license application by that date. Entities already operating in California without a license must cease serving California residents by July 1, 2026 unless a completed application is on file with the DFPI. Crypto kiosk operators face additional obligations that took effect earlier: since January 1, 2025, they are prohibited from collecting more than the greater of $5 or 15% of the transaction value in fees from any single customer transaction. Entities whose activities are limited to trading digital financial assets solely for their own accounts fall outside the DFAL licensing requirement. The DFPI's rulemaking process under Section 3260 remains ongoing, and prospective licensees should monitor the DFPI regulations homepage for updates. The DFPI accepts inquiries at crypto@dfpi.ca.gov . No transitional grace period beyond the July 1, 2026 deadline has been announced as of March 16, 2026. Source: California Department of Financial Protection and Innovation, Digital Financial Assets Law, Cal. Fin. Code §§ 3200–3272 (AB 39 / SB 401, enacted October 13, 2023; amended by AB 1934, enacted September 29, 2024), https://dfpi.ca.gov/regulated-industries/digital-financial-assets/ , confirmed March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • OECD Publishes Due Diligence Guidance for Responsible AI, February 2026

    On February 19, 2026, the Organisation for Economic Co-operation and Development (OECD) published the OECD Due Diligence Guidance for Responsible AI, a 61-page report providing practical guidance to enterprises for implementing OECD standards on responsible business conduct (RBC) and the OECD AI Principles when developing and using artificial intelligence systems. The publication is non-binding but represents an authoritative interpretive instrument adopted by OECD member governments in their shared commitment to trustworthy AI governance. The Guidance draws on two OECD instruments: the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (MNE Guidelines), which set expectations for enterprise-level due diligence across value chains, and the OECD AI Principles (Recommendation of the Council on Artificial Intelligence, OECD/LEGAL/0449), which establish five principles for trustworthy AI — inclusive growth and well-being; human-centred values and fairness; transparency and explainability; robustness, security and safety; and accountability. The Guidance applies these instruments specifically to the AI system value chain, from design and development through deployment and operation to decommissioning. Chapter 1 introduces the concept of responsible business conduct due diligence; subsequent chapters apply due diligence steps to AI-specific adverse impact categories including privacy violations, bias, safety failures, and labour-market displacement. Enterprises that develop or deploy AI systems — including technology companies, financial services firms, healthcare providers, and organizations that procure AI-powered products — are the primary audience for the Guidance. Companies operating in OECD member states will face increasing pressure from regulators, investors, and counterparties to demonstrate AI due diligence processes aligned with the OECD standards. The Guidance promotes policy coherence and interoperability between OECD AI risk management standards and other national or international frameworks, including the EU AI Act. AI-enabled financial services firms and Web3 platforms with global operations should assess how the Guidance maps onto their existing compliance programmes, particularly regarding transparency obligations, risk assessment procedures, and third-party due diligence for AI vendors across the supply chain. The Guidance is non-binding and does not independently impose legal obligations separate from the national laws or regulations in jurisdictions that have incorporated the OECD AI Principles into binding rules. No formal implementation deadline applies at the OECD level. The document targets interoperability with the EU AI Act, ISO/IEC 42001, and the NIST AI Risk Management Framework, meaning enterprises already compliant with those frameworks may find substantial overlap. Open questions include the extent to which national regulators in OECD member states will reference the Guidance in supervisory expectations or enforcement actions, and how it applies to open-source AI systems where the developer, deployer, and end-user are distinct entities with different responsibility profiles. Source: OECD, "OECD Due Diligence Guidance for Responsible AI," Report, 19 February 2026, 61 pages. Available at: https://www.oecd.org/en/publications/oecd-due-diligence-guidance-for-responsible-ai_41671712-en.html . Cross-reference: OECD AI Principles, Recommendation of the Council on Artificial Intelligence, OECD/LEGAL/0449. Confirmed March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • OCC Proposes Stablecoin Regulations Under the GENIUS Act, March 2026

    On March 2, 2026, the Office of the Comptroller of the Currency (OCC) published a Notice of Proposed Rulemaking (NPRM) in the Federal Register to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) for entities subject to the OCC's jurisdiction. The proposed rule is at the notice-and-comment stage; the public comment period closes on May 1, 2026. The NPRM proposes amendments to 12 CFR Parts 3, 6, 8, 15, and 19, under Docket ID OCC-2025-0372 and RIN 1557-AF41, published at 91 FR 10202. The GENIUS Act requires OCC-supervised entities — including national banks and federal savings associations — that wish to issue payment stablecoins to comply with prescribed reserve, capital, redemption, and disclosure standards. The proposed rule implements those statutory requirements in 12 CFR Parts 3, 6, 8, 15, and 19, primarily addressing capital adequacy (Part 3), prompt corrective action (Part 6), assessment of fees (Part 8), securities offering disclosures (Part 15), and activities and operations of federal savings associations and federal savings banks (Part 19). The OCC invites written comments on all aspects of the proposal through its electronic and paper submission channels by May 1, 2026. For stablecoin issuers operating through OCC-chartered institutions, the practical effect is substantial. Any national bank or federal thrift that seeks to issue payment stablecoins will need to hold qualifying reserve assets in an amount equal to or greater than the outstanding stablecoin value, maintain adequate capital buffers adjusted for stablecoin-related exposures, and provide prescribed disclosures to holders regarding redemption rights and reserve asset composition. Non-bank stablecoin issuers already operating in the market without an OCC charter would need to obtain one — or cease activities subject to OCC jurisdiction — once the final rule takes effect. DeFi protocols and wallet providers that are not themselves OCC-supervised are not directly regulated by this NPRM, but the rule shapes the counterparty requirements those entities face when integrating OCC-chartered issuers. The NPRM covers only the OCC's jurisdictional slice of the GENIUS Act. The Federal Reserve and FDIC are expected to publish parallel rulemakings for state member banks and FDIC-supervised institutions, respectively. Open questions in the NPRM include the treatment of algorithmic stablecoins (not addressed), interoperability standards, and the interaction between OCC requirements and state money-transmission licensing regimes. The May 1, 2026 comment deadline gives market participants approximately two months to submit input on reserve composition requirements, capital treatment, and the scope of permissible stablecoin-related activities. Source: Office of the Comptroller of the Currency, "Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency," 91 FR 10202, Docket ID OCC-2025-0372, RIN 1557-AF41, published March 2, 2026. Available at: https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the . Confirmed March 16, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK Civil Justice Council Opens Consultation on AI Use in Court Documents, February 2026

    On 17 February 2026, the Civil Justice Council launched an eight-week consultation examining whether rules are needed to govern the use of artificial intelligence by legal representatives in preparing court documents in England and Wales. The consultation closes on 14 April 2026. The CJC is an advisory body whose statutory functions include keeping the civil justice system under review and considering how to make it more accessible, fair, and efficient. The CJC established a Working Group chaired by Lord Justice Birss, Deputy Head of Civil Justice, with Mrs Justice Joanna Smith as Deputy Chair. The Working Group's terms of reference, approved by the CJC's Executive Committee, direct it to produce a consultation paper followed by a final report. The scope covers AI use by legal representatives in preparing pleadings, witness statements, and expert reports. No specific statutory rule or Civil Procedure Rule has been amended as of the consultation launch date; the consultation precedes any formal rule change. Law firms, barristers' chambers, AI tool developers, and litigants who use AI-generated or AI-assisted pleadings and witness statements in England and Wales civil proceedings are within the consultation's scope. Solicitors and barristers who prepare court documents using AI tools should review the consultation paper and consider responding before 14 April 2026. The outcome of the consultation may result in new Civil Procedure Rules or Practice Directions governing AI-assisted document preparation. Responses must be submitted in PDF or Word format, accompanied by the CJC's cover sheet, and sent to CJC.AI.consultation@judiciary.uk by 14 April 2026. The Working Group will proceed to a final report after the consultation period closes. No mandatory disclosure or certification requirements for AI-assisted documents are in force in England and Wales as of 13 March 2026; any such rules would require amendment to the Civil Procedure Rules 1998. Source: Civil Justice Council, "Use of AI in Preparing Court Documents," consultation launched 17 February 2026, closing 14 April 2026. URL: https://www.judiciary.uk/related-offices-and-bodies/advisory-bodies/cjc/current-work/use-of-ai-in-preparing-court-documents/ . Confirmed 13 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK Gambling Commission Opens Exploration of Crypto Payment Route for Licensed Operators, February 2026

    On 26 February 2026, UK Gambling Commission Executive Director Tim Miller announced at the Betting and Gaming Council Annual General Meeting that the Commission has initiated a review to examine whether a regulated path could be created for cryptoassets as a consumer payment option for licensed gambling operators in Great Britain. The announcement is pre-consultation; the Commission has not issued a formal consultation paper or proposed any amendment to its licence conditions. The Commission's authority to impose licence conditions derives from the Gambling Act 2005. Any requirement that licensed operators accept or refuse specific payment methods would need to be introduced as an amendment to the Licence Conditions and Codes of Practice issued under that Act, following a formal public consultation. Miller's speech also referenced the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025, laid before Parliament in December 2025, which are expected to bring cryptoasset payment firms within FCA authorisation requirements by 25 October 2027. The Commission indicated it treats that incoming FCA regime as a prerequisite for any licensed gambling operator accepting cryptoasset payments. For cryptoasset businesses, licensed gambling operators, and payment service providers operating in Great Britain, the announcement signals that the Commission has placed this question on its regulatory agenda. The Commission asked its Industry Forum to consider how to progress the question of cryptoasset payments in line with the licensing objectives set out in section 1 of the Gambling Act 2005. Businesses seeking to offer cryptoasset payment rails to gambling operators will need FCA authorisation under the incoming cryptoasset regime before the Commission is likely to permit their use. No timeline has been set for any formal consultation or rule change. As of 13 March 2026, no consultation paper is open. Any eventual licence condition permitting cryptoasset payments would also need to satisfy obligations under the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as well as the forthcoming FCA cryptoasset authorisation rules. Source: UK Gambling Commission, "BGC AGM 2026 — Tim Miller speech," 26 February 2026. URL: https://www.gamblingcommission.gov.uk/news/article/bgc-agm-2026-tim-miller-speech . Confirmed 13 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • Scotland Passes Digital Assets Bill Recognising Crypto as Property, March 2026

    On 5 March 2026, the Scottish Parliament passed the Digital Assets (Scotland) Bill at Stage 3 by a unanimous vote of 114 for, 0 against, and 0 abstentions, making Scotland the first part of the United Kingdom to legislate expressly that digital assets — including cryptocurrency — constitute property under Scots private law. The Bill now awaits Royal Assent before it becomes an Act of the Scottish Parliament. The Bill's operative provisions confirm that certain digital assets can be objects of property under Scots private law, clarify the rules for acquiring and owning those assets, and direct that general principles of Scots private law apply to them. Introduced to Parliament on 30 September 2025 as a Scottish Government bill, the legislation passed Stage 1 on 22 January 2026, completed Stage 2 amendments on 18 February 2026, and cleared Stage 3 on 5 March 2026 under motion reference S6M-20944 lodged by Minister for Business Richard Lochhead. For cryptocurrency holders, DeFi protocol operators, digital asset custodians, and tokenised asset issuers whose dealings are governed by Scots law, the Bill removes critical legal uncertainty. Before enactment, no Scottish court had ruled on whether digital assets qualify as property, leaving owners, lenders, and counterparties without clear recourse in disputes over ownership, security interests, or transfers. Once Royal Assent is granted, parties will have a firm property-law foundation to grant and enforce security over crypto holdings, pursue proprietary claims in insolvency, and structure custody arrangements under recognised Scots law principles. The Bill's transfer provisions favour a good-faith acquirer over the original owner of a digital asset — an approach debated during the parliamentary process but retained as passed. The Bill applies to Scots private law only and does not alter regulatory requirements applicable to crypto-asset service providers under UK financial services legislation, which are being developed by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2025 laid before UK Parliament in December 2025. Royal Assent timing has not been announced and depends on the standard process. Source: Digital Assets (Scotland) Bill as passed, Scottish Parliament, Session 6, Stage 3, motion S6M-20944, 5 March 2026. Official bill page and bill as passed document available at: https://www.parliament.scot/bills-and-laws/bills/s6/digital-assets-scotland-bill . Confirmed 13 March 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

  • UK Supreme Court Rules Artificial Neural Networks Are Patentable, February 2026

    On February 11, 2026, the Supreme Court of the United Kingdom issued its judgment in Emotional Perception AI Limited v Comptroller General of Patents, Designs and Trade Marks, case UKSC/2024/0131, neutral citation [2026] UKSC 3. The Court allowed the appeal, holding that an artificial neural network (ANN) implementing a media recommendation system does not constitute a "program for a computer...as such" within the meaning of section 1(2)(c) of the Patents Act 1977 and is therefore not excluded from patentability on that ground. The decision reverses the Court of Appeal's earlier ruling and overturns the original rejection by the UK Intellectual Property Office (UKIPO). The controlling provision is section 1(2)(c) of the Patents Act 1977, which excludes from the definition of an "invention" a "program for a computer...as such." The Supreme Court's reasoning focused on the nature of an ANN as a system that, once trained, operates through weights and connections rather than as a traditional software program executing explicit coded instructions. The justices (Lord Briggs, Lord Hamblen, Lord Leggatt, Lord Stephens, and Lord Kitchin) held that the computer-program exclusion must be interpreted in light of what is actually technical about the invention, not merely whether it runs on digital hardware. Developers and owners of AI systems based on ANNs — including machine learning models used in recommendation engines, image recognition, natural language processing, and predictive analytics — may now seek patent protection in the United Kingdom where the ANN provides a technical contribution beyond running on standard computer hardware. The UKIPO must process patent applications for ANN-based inventions in accordance with the Supreme Court's analysis. Applicants whose prior applications were rejected solely on the computer-program exclusion ground should consider whether to file fresh applications or pursue reinstatement. The decision addresses only the computer-program exclusion under section 1(2)(c) of the Patents Act 1977. ANNs must still satisfy all other patentability requirements — novelty, inventive step, industrial applicability, and the remaining exclusions under section 1(2) — to obtain a granted patent. The judgment also does not address how the European Patent Office, which applies the European Patent Convention, will treat equivalent ANN applications; alignment between UK and EPO approaches on this point is not guaranteed following the UK's departure from the EU patent framework. Source: Emotional Perception AI Limited (Appellant) v Comptroller General of Patents, Designs and Trade Marks (Respondent), [2026] UKSC 3, UKSC/2024/0131, judgment delivered February 11, 2026. Official URL: https://www.supremecourt.uk/cases/uksc-2024-0131 — Confirmed March 12, 2026. The information provided is not legal, tax, investment, or accounting advice and should not be used as such. It is for discussion purposes only. Seek guidance from your own legal counsel and advisors on any matters. The views presented are those of the author and not any other individual or organization. Some parts of the text may be automatically generated. The author of this material makes no guarantees or warranties about the accuracy or completeness of the information.

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