The Guiding and Establishing National Innovation for U.S. Stablecoins Act (“GENIUS Act”) establishes the first comprehensive federal framework for “payment stablecoins” in the United States. The bill’s most discussed, and debated, provision is Section 4(a)(11), which provides:
No permitted payment stablecoin issuer or foreign payment stablecoin issuer shall pay the holder of any
Corporate & Commercial
If You’re Planning to Attend the Party, You Best Be Sure Interest Rates Are Coming Down
There’s an awful lot of happy talk going around about 2026. Apparently, that’s the year we were supposed to stay alive till. I surely hope the talk is right, even if it doesn’t rhyme. 2025 was a pretty darn good year for commercial real estate but underperformed the “talk” in late 2024. We like happy talk. I keep seeing stories across…
Reverse Engineering in the Age of AI: Are Your Trade Secrets Still Safe?
SEC Division of Investment Management Director Brian Daly Signals Innovation-Forward Agenda, Positioning AI at the Forefront of SEC Strategy
On December 2, 2025, Brian Daly, Director of the Securities and Exchange Commission (the “SEC”) Division of Investment Management (the “Division”), delivered remarks to the American Bar Association outlining the Division’s top priorities under his leadership: deregulation, modernization, democratization, and artificial intelligence (“AI”).
Daly noted that the Division’s agenda will largely be driven by the…
How America’s AI Action Plan Could Shape AI Arbitration
Artificial intelligence (AI) is no longer just assisting the legal profession but transforming it – including by shaping how disputes are resolved. In arbitration, algorithms are already used to select arbitrators, analyze documents, and draft procedural orders. The essential question now is how AI will be governed in arbitration.
The America’s AI Action Plan (AAAP),…
Sullivan & Cromwell Discusses Meta Victory in FTC Case Challenging Instagram and WhatsApp Acquisitions
Summary
- In December 2020, the FTC sued Meta, alleging that Meta held a monopoly in the market for personal social networking and had illegally maintained that monopoly through a years-long course of anticompetitive conduct that included acquiring Instagram in 2012 and WhatsApp in 2014.
- On November 18, 2025, following a six-week bench trial, U.S. District
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Guest Post: FDIC Advertising Rule and Crypto Treasuries

One of the more interesting emerging phenomena involving cryptocurrencies has been the recent rise of crypto treasury companies – that is, companies whose primary purpose is acquiring and holding cryptocurrencies as part of their corporate treasury. There arguably are a host of concerns with these kinds of firms. Among other things, and as…
Artificial Intelligence Disclosure
Last week, the Securities and Exchange Commission’s Investor Advisory Committee met to discuss, among other things, whether to recommend to the SEC that it issue additional disclosure guidance related to artificial intelligence (AI). With some dissent, the Committee ultimately voted in favor of the recommendations (see Disclosure of Artificial Intelligence’s Impact on Operations),…
SEC Investor Advisory Committee Recommends AI-Related Disclosure Guidelines

Just about every company these days is grappling with the arrival of Artificial Intelligence (AI). But what should companies be telling their investors about the impact of AI deployment on their operations and financial results? At a recent meeting, the SEC’s Investment Advisory Committee recommended that the agency issue guidance requiring issuers to provide disclosures…
Expert Testimony in the Age of Generative AI: Recent Case Developments
Much has been written about the risks of lawyers relying on generative artificial intelligence (Gen. AI) to draft briefs—especially when unchecked citations turn out to be hallucinated. But lawyer briefs are not the only documents that demand scrutiny. As the cases below show, lawyers must also carefully review their experts’ affidavits, declarations, and reports before…
