AI-Crypto Interplay
Legal work where AI products meet digital assets: token classification, stablecoins, agent wallets and smart contracts. For wallet licensing and registration across the EU, the UK, Switzerland, the US and Canada, see our crypto and digital-assets practice.
Token and Digital Asset Structuring
Whether an instrument is a security, a payment stablecoin, an e-money token, an asset-referenced token, or a utility or governance instrument determines everything downstream: who may issue it, how it may be distributed, what must be published, and who supervises it. We run that analysis before the instrument is designed, and record the reasoning in a form that can be produced later.
- →Classification under US securities law, the MiCA token categories, and the UK regime
- →Distribution structured to match the classification, including the jurisdictions deliberately excluded
- →White papers, disclosures and marketing communications in the form the applicable regime prescribes
- →A written record of the reasoning, which is the first thing a regulator asks to see
SourcesMiCA·ESMA on MiCA
Stablecoins
From January 18, 2027 at the latest, the GENIUS Act makes it unlawful to issue a payment stablecoin in the United States without a federal or state license. The statutory rulemaking deadline of July 18, 2026 passed without final rules, so the eighteen-month trigger governs the effective date. Treasury is separately consulting on what it means to issue, and to offer or sell, a payment stablecoin in US markets, which is the question that decides whether a non-US issuer is caught. In the UK, issuing a qualifying stablecoin becomes a regulated activity when the authorisation regime made by SI 2026/102 comes into force on October 25, 2027; the FCA's application window runs from September 30, 2026 to February 28, 2027.
- →The licensing route and its timing, which for a January 2027 effective date is a 2026 decision
- →Reserve composition, redemption rights and attestation requirements
- →Whether Treasury's pending definitions reach a non-US issuer serving US users
- →The UK position for qualifying stablecoins, including where joint supervision applies
SourcesGENIUS Act·Treasury consultation·FCA policy statements·SI 2026/102
Agent Wallets and Autonomous On-Chain Activity
When an AI agent holds keys, moves value or trades, the custody, authority and accountability questions arrive together. The legal position is not that autonomy is prohibited. It is that someone must remain accountable, and the record has to show who authorized what. We design the mandates, limits and oversight points that make autonomous activity defensible, and align them with the agent's contractual authority.
- →Custody analysis: whether holding keys for a user makes you a custodian in each relevant jurisdiction
- →Mandates and value limits that bind the agent and are visible to the counterparty
- →Recorded human oversight for the transactions that warrant it
- →Alignment with the provider and deployer duties the AI Act places on the same system
Smart Contracts and Tokenized Assets
A smart contract is code, and also an instrument someone will eventually try to enforce. Part of the property question now has a statutory home: the 2022 UCC amendments introduce Article 12 on controllable electronic records and treat control as the functional equivalent of possession, and more than thirty states have adopted them. We make sure the code, the written terms and the property analysis point in the same direction.
- →Review of contract logic for the legal exposure it creates, not only the technical exposure
- →Written terms that anchor on-chain behavior, with a defined authoritative version
- →Upgradeability and admin key structures, and disclosure of who holds them
- →Incident response for exploits and governance attacks, prepared before it is needed
SourcesUCC (2022 amendments)
Key Questions We Help You Answer
- ?Is our token a security, a payment stablecoin, an e-money token, or something else?
- ?Does the GENIUS Act reach us, and what has to be in place before January 18, 2027?
- ?Can an AI agent hold or move funds without making us a custodian?
- ?Who is accountable when an autonomous on-chain transaction goes wrong?
Project-based legal advice
Scoped engagements on token classification, MiCA and FCA authorization, GENIUS Act stablecoin licensing, agent wallets and smart-contract review across the US, EU and UK.
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