This Week in Crypto Law (October 4, 2026)

ICBA seeks to have those actions set aside and to prevent further charter approvals under the challenged rule and interpretation. These are the plaintiff’s allegations and requested remedies; filing the complaint does not itself invalidate the framework.

For crypto custodians and other businesses considering a national trust charter, the practical concern is planning uncertainty. Charter-dependent financing, product launches, and commercial agreements should account for the possibility of litigation affecting the proposed regulatory route. Businesses should also distinguish a conditional approval from permission to commence particular activities when describing their status to customers and counterparties.

2. Treasury Targets the A7 Network, Including Its Digital-Asset Infrastructure

On October 1, Treasury announced coordinated action against the A7 Network, which it describes as a sanctions-evasion network connected to Russia and used by Iran. OFAC designated the network as a significant transnational criminal organization. Separately, FinCEN proposed restrictions on funds transfers involving its sub-agents and issued an alert to financial institutions. Treasury identifies the ruble-backed A7A5 token as part of the network’s infrastructure.