“Decentralization” is a concept that has consistently vexed the entire blockchain-enabled ecosystem in the U.S., including its counsel and regulators, wherein a lack of clarity on the exact definition of decentralization has...more
4/22/2021
/ Bitcoin ,
Blockchain ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Howey ,
Information Commissioner's Office (ICO) ,
Investment Contract ,
Popular ,
Securities and Exchange Commission (SEC)
As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more
1/18/2021
/ Anti-Money Laundering ,
Banks ,
Blockchain ,
Comptroller ,
Cryptocurrency ,
Electronic Payment Transactions ,
Federal Savings Associations ,
Financial Institutions ,
Interpretive Letters ,
OCC ,
Popular ,
Stablecoins
Under the Bank Secrecy Act of 1970 (BSA), buoyed by the USA PATRIOT Act of 2001, the United States instituted a compliance regime where financial institutions are required to collaborate with the government in order to...more
The terms “revolution” and “disruption” in the context of technological innovation are probably bandied about a bit more liberally than they should. Technological revolution and disruption imply upheaval and systemic...more
Patients accumulate vast quantities of healthcare data over the course of their lives. Those data are generally housed in centralized servers operated by various unrelated industry participants, including government...more
Until November 8, 2018, the enforcement actions of the U.S. Securities and Exchange Commission (SEC) in the digital token (aka cryptocurrency) space have primarily focused on the primary issuances of tokens. However, on...more
On July 21, 2017, following last June’s announcement that the Delaware House of Representatives had passed (with near unanimity) blockchain-related provisions proposing to amend several sections of the Delaware General...more
The World Economic Forum threw a knockout punch this month when it released its report “The Future of Infrastructure: An Ambitious Look at How Blockchain Can Reshape Financial Services.”1 When Giancarlo Bruno, the World...more