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Disclosing Cryptocurrency Risks: SEC Comment Letter Puts Companies On Notice

The U.S. Securities and Exchange Commission (SEC) Division of Corporation Finance (CorpFin) recently issued guidance (Guidance), including a “Dear Issuer” Sample Letter (Sample Letter) to assist companies in meeting their...more

SEC Chair Stands Firm: ‘Vast Majority' of Cryptocurrency Tokens Are Securities

Takeaways - ..U.S. Securities and Exchange Commission (SEC, or Commission) Chair Gary Gensler reaffirmed his view that the “vast majority” of cryptocurrency tokens are securities, and recent agency enforcement actions...more

SEC Brings Flurry of Insider Trading Cases Using Market Analytics

On July 25, 2022, the Securities and Exchange Commission (SEC or the Commission) made headlines announcing insider trading charges against 10 individuals across four separate cases, signaling an increased and renewed focus on...more

2022 DSIR Deeper Dive: Increased Regulatory Scrutiny of Cybersecurity Incidents

Our 2022 Data Security Incident Response Report discussed the increased regulatory scrutiny of cybersecurity incidents and defenses following a year of high-profile and damaging cyberattacks, including the Russia-based...more

Banks and Retailers Embrace Crypto, Bitcoin Environmental Costs Debated, New NFT Initiatives Launch, Various Agencies Address...

According to reports, a major U.S.-based global investment bank has allowed a borrower to use bitcoin as collateral for a cash loan, for the first time in the bank’s history. In other financial news, according to reports, the...more

SEC Signals Ramp-Up in Crypto Enforcement by Nearly Doubling Its Crypto Assets Cyber Unit Staff

Key Takeaways - ..SEC enforcement actions related to crypto and cyber are expected to significantly increase with the additional 20 staff assigned to the Division of Enforcement unit dedicated to these industries....more

New Crypto Payment Initiatives; Regulators Address Crypto in Speeches; Lawmakers Propose Legislation; OFAC Sanctions Crypto...

Crypto Payment Initiatives Announced in Stablecoins, Lightning Network, Mining - Late last week, the issuer of USD Coin (USDC) announced that it had selected a major U.S. bank as a primary custodian for USDC reserves....more

Ripple Case Presses Forward as Court Denies Motions to Dismiss and Strike

Key Takeaways - ..The court denied Ripple’s senior executives’ motions to dismiss, finding that the SEC had met its pleading burden. ..The court also denied the SEC’s motion to strike Ripple’s fair-notice affirmative...more

SEC Proposes Rules on Disclosure of Material Cyber Incidents and Cybersecurity Practices for Public Companies

On March 9, 2022, the SEC released proposed rules intended to enhance and standardize disclosures regarding cybersecurity risk management, strategy, governance and cyber incident reporting by companies that are subject to the...more

Financial Firms Continue Expanding into Cryptocurrency Markets; Crypto Donations Reach Ukraine; DOJ Crypto Enforcement Continues;...

Traditional Financial Firms Expand Reach into Cryptocurrency Sphere - Early this week, a major investment bank announced that it plans to launch a digital asset custody platform later this year. This announcement follows...more

SEC Brings First Ever Securities Fraud Charges Against Alternative Data Provider

As one of its latest enforcement actions, the Securities and Exchange Commission (“SEC” or “Commission”) continued its push into the fintech space by charging an alternative data provider with securities fraud for the first...more

CBDC Initiatives Announced, NFTs Expand Across Markets, Token and Wallet Applications Evolve, SEC and DOJ Target Crypto Fraud,...

CBDC Initiatives Announced, Blockchain Trade Finance Platform Launches - This week, the Bank for International Settlements (BIS) announced Project Dunbar, an initiative in which BIS will collaborate with the Reserve Bank of...more

SEC Scrutinizes Use of Fintech by Broker-Dealers and Investment Advisers

The Securities and Exchange Commission (“SEC”) recently issued a request for information and public comment on the use of new and emerging technologies by investment advisers and broker-dealers that suggests potential...more

Cryptocurrency and NFT Market Growth Continues, Regulators Across Globe Target Crypto Industry as Threats Continue, Global...

Crypto Market Develops in DeFi, Payments, Compliance and Consumer Adoption - A large institutional financial and media conglomerate recently announced a partnership with a major financial services and investment management...more

Crypto, CBDC and Blockchain Supply Chain Initiatives Announced; More SEC and FinCEN Enforcement; Crypto Tax Amendment Fails; DeFi...

Crypto Firms Pursue Bank Charters, Traditional Financial Firms Integrate Crypto - This week, the Wyoming Division of Banking granted a new Special Purpose Depository Institution (SPDI) bank charter to Commercium Financial...more

SEC Doubles Down on Crypto Enforcement

In a speech before the Aspen Security Forum on August 3, 2021, Securities and Exchange Commission (“SEC” or “Commission”) Chair Gary Gensler urged lawmakers to provide him with the power to police cryptocurrency trading,...more

ESG Disclosures, Congress, and the SEC

The push on environmental, social, and governance (“ESG”) disclosures has increased in the past several years, with these disclosures becoming a particular focus of the Biden Administration, the Securities and Exchange...more

SEC Fines Broker-Dealer for Inconsistent Policies that Allegedly Could Stifle Whistleblowers

The Securities and Exchange Commission (“SEC” or “Commission”) recently issued a stark reminder to regulated persons that it will pursue enforcement actions if they prevent whistleblowers from communicating with the SEC or...more

‘An Offer You Can't Refuse': Best Practices for Responding to SEC ‘Voluntary' Requests

Many companies registered with the Securities and Exchange Commission (“SEC” or “Commission”), whether as a public company, an investment adviser, or a broker-dealer, will undergo an inquiry or a formal investigation by the...more

NFT Initiatives Continue, Blockchain Tracing Solutions Expand, SEC Targets ICO, Crypto Enforcement Data Published, Regulators...

NFT Initiatives Continue, Cryptocurrency Advertising Restrictions Ease - In New Dehli, a blockchain-powered platform is hosting an exhibition displaying 27 art pieces by Bengal-born artist Lalu Prasad Shaw. According to a...more

SEC Brings Charges for Cybersecurity Disclosure Failures

On June 14, 2021, the U.S. Securities and Exchange Commission (SEC or Commission) settled charges against an issuer for disclosure controls and procedures violations relating to a cybersecurity vulnerability that exposed...more

Reports Address CBDCs, Security Tokens; NFT Sales Continue; Blockchain Initiatives Announced; Regulators Address Crypto; SEC...

Reports Address CBDCs and Security Tokens, Banks Launch Crypto Initiatives - A recent report released by the Bank for International Settlements (BIS) analyzes results from a survey of 50 central banks in the first quarter of...more

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