Crypto due diligence has changed: three questions advisors should revisit
Advisors should update due diligence for three areas in 2026: client cash management, disclosure of regulatory assumptions, and liability when AI executes crypto trades. Digital cash alternatives such as stablecoins and tokenized money market funds may offer faster settlement, transparency, and yield, but recommendations should reflect fees, conflicts, suitability, and product controls. Regulatory risk remains fluid, so advisors should clearly disclose assumptions about legislation, enforcement, and political shifts instead of promising certainty. AI and crypto convergence raises added questions about security, validation, supervision, accountability, and privacy when AI tools touch client data or place trades. On the GENIUS Act, stablecoins are still operating under the current state money-transmitter regime until the law takes effect, which will be the earlier of January 18, 2027, or 120 days after final federal implementing regulations. Related rulemaking is due by July 18, 2026.
