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Parting the Crypto Sea: Ripple’s XRP Ruled to be a Security When Sold to Private Investors, But Not When Sold on an Exchange

Judge Analisa Torres’ greatly anticipated Order in the SEC’s lawsuit against Ripple is a split decision.  The Order basically finds that Ripple’s digital token XRP is a security when sold privately to individuals and...more

FTX, Sam Bankman-Fried and the Risk of Unchecked Founder Control

“Never in my career have I seen such a complete failure of corporate controls and such a complete absence of trustworthy financial information as occurred here”.  Such was the lament of John Ray, the legendary restructuring...more

Crypto Reform Goes to Congress: Proposed Three-Year Safe Harbor for Distribution of Pre-“Network Maturity” Digital Tokens

Background: Crypto Catch 22 - Followers of the SEC’s efforts to regulate digital tokens will recall former SEC Corp Fin Director William Hinman’s speech at the June 14, 2018 Yahoo Finance Conference in which he introduced...more

First Ever SEC Registered Digital Token IPO May Bring Clarity to Blockchain Asset Industry

On May 3, 2021, blockchain-based trading platform operator INX Ltd. announced it had completed its initial public offering of digital tokens, raising approximately $85 million in the IPO from over 7,200 institutional and...more

SEC vs. Ripple Could Make Waves in Cryptocurrency Market

On December 2, the Securities and Exchange Commission filed a lawsuit against Ripple Labs, Inc. and two of its executives alleging they offered and sold over $1.38 billion of digital asset XRP without registration or...more

“Kik” in the Butt: Court Decision Against Initial Coin Offering Could be Opportunity for Others

On October 21, 2020, the United States District Court for the Southern District of New York entered a final judgment on consent against Kik Interactive Inc. to resolve the Securities and Exchange Commission’s charges that...more

Proposed Three-Year Digital Token Safe Harbor May Bridge Gap to Decentralization or Functionality

It’s not often that an SEC Commissioner quotes Bruce Springsteen – not once, but twice – in a speech on securities regulation. But SEC Commissioner Hester Peirce did just that in a February 6, 2020 speech in which she...more

What to Make of SEC Leniency in Block.one ICO Settlement?

On September 30, 2019, the Securities and Exchange Commission announced that blockchain developer Block.one had agreed to pay a $24 million fine to settle charges that it had engaged in an unregistered offering of securities...more

First Federal Ruling Against SEC on Whether Digital Token is a Security

On November 27, 2018, the United States District Court for the Southern District of California denied the Securities and Exchange Commission’s motion for a preliminary injunction to block an initial coin offering, finding the...more

Imitation Not Always Flattery: SEC Halts ICO Falsely Claiming Approval of SEC and Self-Created “Blockchain Exchange Commission”

If you were looking for a safe blockchain investment and had the chance to invest in the “first licensed and regulated tokenized cryptocurrency exchange and index fund based in the U.S.” and audited by a Big 4 accounting...more

“No Good Deed”: Free Tokens Issued in Airdrops, Bounty Programs Likely Violate Securities Laws

If you’re thinking of airdropping free tokens or implementing a cryptocurrency bounty program, be careful. The Securities and Exchange Commission just issued a cease and desist order (the “Order”) with respect to an initial...more

Can a Digital Token Evolve? Head of Corp Fin Says “Yes”, if Network Becomes Decentralized

“Can a digital asset that was originally offered in a securities offering ever be later sold in a manner that does not constitute an offering of a security?” ...more

First S-1 Filing for an ICO: Going Legit or Just a Crypto Head Fake?

Initial coin offerings so far have gone through two major phases in their brief lifespan. The initial phase flew under the regulatory radar in an explosion of deals that raised billions of dollars seemingly overnight and...more

Hand it Over: SAFT-Based ICOs Challenged by SEC Subpoenas

The Wall Street Journal ominously reported on February 28 that the Securities and Exchange Commission recently issued dozens of subpoenas to initial coin offering issuers and their advisors demanding information about the...more

Massachusetts’ First ICO Enforcement Action Offers Important Lessons for Offshore ICOs

Last month, Secretary of the Commonwealth of Massachusetts William Galvin made good on his promise to conduct an exam sweep of ICOs in Massachusetts. On January 17, the Enforcement Section of the Massachusetts Securities...more

SEC Provides Initial Coin Offering Guidance

On July 25, 2017, the SEC’s Division of Enforcement issued a Report of Investigation (the “Report”) that concluded that the tokens issued in an initial coin offering (“ICO”) by a decentralized autonomous organization called...more

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