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SEC Staff Clarifies That Certain Staking Activities Are Not Securities

Protocol Staking Under the Federal Securities Laws - Historically, the SEC has taken issue with certain staking activities under the federal securities laws. The SEC previously alleged that staking-as-a-service programs...more

A Step Forward for Broker-Dealers and Transfer Agents Engaged in Crypto Asset Businesses

The Staff noted that Securities Exchange Act (SEA) Rule 15c3-3(b) only applies to securities carried by a broker-dealer. Accordingly, if a broker-dealer carries non-security crypto assets (e.g., Bitcoin or Ether), a...more

CFTC Staff Seeks Public Feedback on Perpetual Contracts and 24/7 Trading

On April 21, 2025, the Commodity Futures Trading Commission’s (CFTC) Divisions of Market Oversight, Clearing and Risk, and Market Participants issued two requests for comments soliciting public feedback related to the...more

SEC Clarifies Stance on Disclosures Relating to Crypto Assets

The Guidance provides the Division’s views regarding certain disclosure requirements under Regulation S-K, specifically with respect to disclosures contained within Form S-1 (registration statements), Form 10-K (reporting...more

Crypto Brief - Newsletter - January 24, 2025

Lowenstein Crypto advises leading digital asset and cryptocurrency projects, exchanges, and trading firms. Our practice covers regulatory advice, transactions and structuring advice, investigations, and adversarial matters...more

Key Considerations When Adopting Artificial Intelligence as a CFTC-Regulated Firm

On December 5, 2024, the U.S. Commodities Futures Trading Commission (CFTC) staff (Staff) issued a staff advisory (Advisory) on the use of artificial intelligence (AI) by market participants in CFTC-regulated markets.1 Staff...more

SEC’s 2024 Examination Priorities for Broker-Dealers

On October 16, 2023, the U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) released its annual Examination Priorities for fiscal year 2024 (the (“Report”), marking the first time the...more

Not Today, Gary: Court Says XRP is Not a Security

On July 13, Judge Analisa Torres, district judge for the United States District Court for the Southern District of New York, issued a substantial order (the Order) on cross motions for summary judgment in the U.S. Securities...more

SEC Safeguarding Rule Proposal: What a Crypto Investment Adviser Needs to Know

On February 15, 2023, the U.S. Securities and Exchange Commission (SEC) released a proposed rule change (the Proposed Rule) redesignating the “custody rule” (i.e., Rule 206(4)-2 of the Investment Advisers Act of 1940, as...more

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