JuliannaSt. Onge

California's new licensing regime for digital financial asset businesses is no longer on the horizon, it is here. The California Department of Financial Protection and Innovation (DFPI) opened its application portal last month, and the July 1, 2026 compliance deadline is now less than three months away. For companies that anticipate serving California residents with covered digital financial assets services, there is a significant advantage to having a license application in by July 1.

Under California’s new Digital Financial Assets Law, or DFAL, all entities engaging in “digital financial asset business activity” in the state must be licensed—or have a pending application—by July 1, 2026. On September 29, 2025, the California Department of Financial Protection and Innovation (DFPI) issued a Notice of Modification to Text of Proposed Regulation (Modification Notice) amending the previously issued April 4, 2025 Notice of Proposed Rulemaking.

On April 8, 2025, the United States Department of Justice’s (DOJ) National Security Division’s (NSD) final rule (Final Rule)1regulating certain sensitive US data transfers took effect. DOJ has made clear that it will take steps to enforce these regulations. Fortunately, entities seeking to understand their obligations under the Final Rule can benefit from an additional 90-day period to come into compliance.

On February 5, 2025, in one of her first actions as the nation’s chief law enforcement official, Attorney General Pam Bondi issued several new memoranda that significantly refocus US Department of Justice (DOJ) national security investigations, resources, and enforcement priorities. With two of these memos, General Policy Regarding Charging, Plea Negotiations and Sentencing (AG Bondi’s Memo) and Total Elimination of Cartels and Transnational Criminal Organizations (Cartel Memo), the Attorney Gen