Xsolla Legal Digest: Key global regulatory updates

As part of our ongoing legal updates, we are sharing a new edition of Xsolla’s Legal Digest, highlighting selected global legal and regulatory developments, industry cases, and enforcement trends that we actively monitor.

The purpose of this Digest is to provide high-level visibility into developments we consider noteworthy based on our global regulatory monitoring and experience as a Merchant of Record, and to help you stay informed about changes that may be relevant to your business in an evolving regulatory environment.

This Digest is shared for general informational purposes only. Should your legal or compliance team wish to discuss any of the topics highlighted below, our legal team would be happy to connect and provide additional context.

Below is a brief overview of selected global legal developments and illustrative industry cases from April.
1. App stores and platform distribution
Apple and Epic head to the U.S. Supreme Court
The latest developments in Apple v. Epic are the most significant for the external payment strategy in years. The Ninth Circuit denied Apple’s requests for rehearing, then granted Apple a temporary stay of its mandate, only to reverse that stay on April 28, 2026, after Epic successfully challenged it. With no further relief available in the Ninth Circuit, Apple has filed an application with the U.S. Supreme Court seeking a stay of the mandate pending potential review.

Apple is asking the Supreme Court to address two central questions. First, whether courts can hold a platform in contempt for conduct that allegedly defeats the purpose of an injunction, including a commission the injunction did not expressly address. Second, whether the injunction may apply nationwide to all developers, rather than only to Epic. On May 6, 2026, the Supreme Court declined Apple’s stay request; the case now returns to the district court to determine what limits apply to any commission Apple may charge.

Critically, while proceedings continue, Apple is currently operating under a zero-commission compliance posture for purchases made through external payment links in the United States, creating an operational window for developers and merchants to route iOS checkout outside the App Store. This arrangement remains subject to change as the district court proceedings on commission rates move forward.

Australia
In August 2025, an Australian federal court ruled that Apple and Google had each misused their market dominance over app distribution and in-app payments, in breach of Australian competition law. Google has since settled globally with Epic; the case against Apple is in the remedies phase.

In April 2026, the Australian competition regulator was granted leave to intervene to make submissions on public-interest issues related to the remedies. Epic is asking the court to require alternative app stores and third-party payment processors on iOS in Australia and to lower commissions. A favorable ruling could create DMA-like practical effects and meaningfully expand the addressable market for third-party payment infrastructure.

Online safety for minors: a regulator-led wave
Florida's youth social-media law moved into enforcement. The state attorney general confirmed that Meta will begin removing accounts belonging to Florida users under 14 in May, with steep penalties available against non-compliant operators. The state has called on additional platforms - including Snapchat, Discord, and TikTok - to follow suit. Covered operators are now expected to implement account removals, age checks, and parental-consent flows.

Card networks and interchange
A U.S. federal court is reviewing a revised $38 billion settlement between Visa, Mastercard, and a class of merchants alleging coordinated overcharging on interchange fees. An earlier $30 billion version of the deal was rejected as insufficient. The revised proposal includes changes to rules that currently restrict merchants from steering customers toward cheaper payment methods. This could result in up to $224 billion in projected savings if fully implemented. Major retailers are still pushing for more. Court approval remains pending, with a decision possible later this year. Any meaningful loosening of interchange rules could affect transaction costs across the card-payments chain, which is directly relevant to commerce platforms.

Stablecoins and AML reform
FDIC kicks off the GENIUS Act stablecoin framework
On April 7, 2026, the U.S. Federal Deposit Insurance Corporation approved a notice of proposed rulemaking implementing the GENIUS Act (Pub. L. No. 119-27) for FDIC-supervised stablecoin issuers and banks involved in stablecoin custody and reserve activities. The proposal would cover reserves, redemptions, capital, liquidity, risk management, and custody.

Two clarifying points stand out. First, deposits held as reserves backing payment stablecoins would not be insured on a pass-through basis to stablecoin holders. Second, tokenized deposits that legally qualify as bank deposits would be treated as deposits rather than as stablecoins. Public comments are open until June 9, 2026. This is one of the clearest signals yet of what compliant U.S. stablecoin structures look like in practice.

FinCEN proposes a major AML/CFT overhaul
On April 7, 2026, the U.S. Treasury's Financial Crimes Enforcement Network proposed a fundamental reform of how financial institutions design AML/CFT programs under the Bank Secrecy Act. The proposed rule supersedes and withdraws the July 2024 draft.

The proposal would shift the focus toward effectiveness, introduce a two-tiered framework that distinguishes between program establishment and implementation failures, and allow institutions to concentrate resources on higher-risk customers and activities. Comments are due by June 9, 2026. Expect downstream impact on bank onboarding, transaction monitoring, and the compliance standards that regulated counterparties require of their vendors.

Prediction markets versus sports betting
On April 23, 2026, the Wisconsin attorney general filed three parallel suits against five major prediction-market platforms, alleging that "event contracts" tied to sports outcomes are illegal, unlicensed gambling under state law. The Commodity Futures Trading Commission filed its own action against Wisconsin on April 28, 2026, asserting exclusive federal jurisdiction over event contracts traded on CFTC-regulated markets - mirroring earlier federal suits against Arizona, Connecticut, Illinois, and New York. Any payment infrastructure supporting outcome-based monetization should now be assessed against state gambling rules in every jurisdiction where it is offered, regardless of how the product is labeled at the federal level.

15. Mai 2026, von Thore Varga