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ASTRAEA COUNSEL

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Compliance

14 articles

Client Guide

How to Get a Crypto Exchange License: State-by-State Requirements

A 2026 guide to licensing a U.S. crypto exchange — the FinCEN MSB baseline, money transmitter licenses in 49 states, New York's BitLicense, California's DFAL, the MTMA standardization trend, and how the GENIUS Act changes the picture for stablecoin issuers. Includes a strategic state-selection framework and partner-bank alternatives.

July 20, 2026 · 36 min readRead More →
Legal Update

Federal AI Regulation Landscape: Where Things Stand in 2026

Where federal AI regulation stands in 2026. Track the live bills (Algorithmic Accountability Act, CREATE AI Act, AI Foundation Model Transparency Act of 2026), the July 2025 America's AI Action Plan and its executive orders, the December 2025 federal-preemption order, California's enacted SB 53, and what it all means for compliance.

July 20, 2026 · 30 min readRead More →
Legal Update

NFT Regulation 2025: After the SEC Enforcement Retreat

The SEC closed major NFT investigations into OpenSea and Yuga Labs in early 2025, marking a dramatic shift from its aggressive 2022-2024 enforcement strategy. Here's what changed, what it means for NFT creators and marketplaces, and how to structure compliant NFT projects going forward.

June 22, 2026 · 26 min readRead More →
Client Guide

State AI Law Patchwork: 50-State Compliance Map

With the federal AI moratorium stripped on the Senate floor, states enacted roughly 100 AI-related measures in 2025—and the federal government is now moving to preempt them. Navigate the 50-state regulatory landscape with this compliance map and a practical framework for multi-state operations.

June 22, 2026 · 43 min readRead More →
Client Guide

Crypto Banking Relationships: How to Get and Keep Bank Accounts

Practical strategies for crypto companies to secure banking relationships in 2026, navigate the aftermath of Operation Chokepoint 2.0, and maintain compliance that keeps accounts open.

June 20, 2026 · 30 min readRead More →
Client Guide

SEC Crypto Enforcement Defense: What to Do When You Get a Wells Notice

Received an SEC Wells Notice? This 2026 guide covers the response window, the Wells submission, settlement-versus-litigation frameworks, and what a Wells Notice means now that registration-theory crypto enforcement has substantially receded. By Chanté Eliaszadeh, who worked in the SEC's Cyber Unit as a summer Honors Program intern and now defends crypto companies.

June 19, 2026 · 33 min readRead More →
Client Guide

Qualified Crypto Custodians: Regulatory Requirements and Selection Guide

The GENIUS Act, California's DFAL, and OCC custody rules now define what a 'qualified custodian' must be for digital assets. This guide covers the federal and state custody-law framework, SOC 2 standards, the regulatory status of leading custodians, and how to choose one.

June 18, 2026 · 24 min readRead More →
Client Guide

GENIUS Act Stablecoin Compliance: A 2027 Roadmap for Issuers

The GENIUS Act became law in July 2025, but its compliance cliff is January 18, 2027—and the implementing rules are still in proposed form. Here is what stablecoin issuers should be doing now, and the facts the early commentary got wrong.

June 14, 2026 · 12 min readRead More →
Client Guide

Money Transmitter Licensing for Crypto Startups: A State-by-State Strategy

You do not always need a money-transmitter license in all 49 states, and after the GENIUS Act some stablecoin issuers will not need state licenses at all. Strategic state selection, the partner-bank alternative, and a precise read of federal preemption can save crypto startups substantial first-year compliance cost. Here is the framework.

June 14, 2026 · 14 min readRead More →
Legal Update

The SEC's Crypto Pivot: What the Dismissals and New Rules Mean for Your Startup

The SEC dismissed its biggest crypto cases with prejudice, issued staff guidance, and adopted an interpretive token framework. For founders, the question shifted from "will the SEC sue me?" to "what does the new framework require—and how much of it actually binds?"

June 14, 2026 · 10 min readRead More →
Client Guide

Crypto Treasury Management in 2026: Custody, Accounting, and Compliance

Three things changed how crypto treasuries work in 2025-2026—crypto is now a fair-value asset, the bank-access climate flipped open, and California's first custody regime arrives July 1, 2026. Here is where a crypto treasury sits today.

June 14, 2026 · 9 min readRead More →
Client Guide

Drafting Vendor Agreements for Claude Managed Agents: A GC's Clause Library

Standard SaaS MSAs were not written for autonomous AI agents. A former SEC Honors Program intern in the SEC's Cyber Unit provides a ready-to-redline clause library organized by the KYA Five Pillars, with the regulatory basis and plain-language rationale for each provision.

April 15, 2026 · 21 min readRead More →
Thought Leadership

What Claude Managed Agents Means for Your Compliance Stack: A KYA Framework Analysis

Anthropic's Managed Agents runtime shipped on April 8. A former SEC Honors Program intern in the SEC's Cyber Unit maps each product feature to the KYA Five Pillars governance framework—and identifies the compliance gaps deployers must close before their first production session.

April 12, 2026 · 22 min readRead More →
Thought Leadership

Not an Agent. Not a Defense: Seven Doctrines That Already Hold AI Deployers Liable

The technology industry calls them agents. The law calls them tools. Seven existing legal doctrines—from board oversight to products liability to trade secret exposure—already impose direct liability on companies deploying AI agents, without the defenses that agency law would provide.

March 18, 2026 · 48 min readRead More →
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