Here are some compliance-related stories that recently caught my attention.
2026 Crypto Crime Report
by TRM LAbs
- Illicit crypto volume reached an all-time high of USD 158 billion in 2025, up nearly 145% from 2024.
- Despite the increase in absolute illicit volume, illicit volume as a proportion of overall crypto volume fell in 2025, from 1.3% in 2024 to 1.2% in 2025.
- While illicit activity represented a small share of overall on-chain volume, illicit entities captured 2.7% of available crypto liquidity in 2025, according to a new metric released by TRM that frames risk relative to deployable capital rather than raw transaction volume.
- Sanctions-related activity in 2025 was overwhelmingly driven by Russia-linked flows, largely due to the rapid growth of the ruble-pegged stablecoin A7A5, which processed more than USD 72 billion in total volume.
- The wallet cluster associated with the Russian sanctions evasion network A7 is linked to at least USD 39 billion in 2025 — reflecting concentrated, coordinated activity closely associated with sanctions evasion and state-aligned financial infrastructure, rather than broad market usage.
FINRA Proposes Overhaul of Outside Activities Rules
by Brynn Rail, Erin M. Fredrick Conklin, SaraAnn Bannister of Ropes & Gray
The Proposal would consolidate the OBA and PST frameworks of Rules 3270 and 3280 into a single rule, new Rule 3290, reoriented around “investment‑related” outside activity. The Proposal is intended to eliminate “white noise” reporting for common non‑investment-related outside activities (e.g., driving for a car service) that are unlikely to be viewed as part of a firm’s business but are technically required to be reported under current Rule 3270, allowing firms to redeploy compliance resources to activities more likely to create risk to investors or the firm.
Statement Commenting on the SEC’s Withdrawal from the No Action Process
by Josh Zinner, Timothy Smith, and Beth-ann Roth, ICCR & Shareholder Rights Group
The recent announcement by the SECʼs Division of Corporation Finance that its staff will not, during the 2026 proxy season, “… respond to no-action requests related to any basis for exclusion other than 14a-8(i)(1)” leaves both companies and investors in uncertain, uncharted waters. The lack of staff input deprives companies and proponents of an orderly and time-honored process.
We are concerned about the Division’s new approach and believe that companies would be unwise to rely on it as a basis to unilaterally decide to omit a resolution without considering further input from proponents.