Sidley Discusses “Project Crypto” and the Next Phase of Digital Asset Oversight

On November 12, 2025, SEC Chairman Paul Atkins delivered remarks (the November Remarks) revisiting his announcement of “ Project Crypto,” the Commission-wide initiative launched earlier this year to promote blockchain innovation in U.S. financial markets. Chairman Atkins laid out plans for the next phase of the initiative, describing how the SEC intends to bring greater legal clarity to crypto assets through a formal token taxonomy, a refined application of the Howey investment-contract framework, and a forthcoming “Regulation Crypto” proposal aimed at establishing tailored disclosures, exemptions, and safe harbors for digital asset distributions. Chairman Atkins also reaffirmed the Commission’s intent to coordinate closely with Congress as lawmakers consider new market structure legislation.

As the federal government emerges from its shutdown, we take stock of the SEC’s progress under Chairman Atkins’ ProjectCrypto initiative, examining what has been achieved, what is still in progress, and where further action or rulemaking may lie ahead.