News & Analysis as of

Howey Securities Regulation Investment Contract

DLA Piper

SEC Staff Concludes Protocol Staking Activities on Proof-of-Stake Networks Are Not Securities

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On May 29, 2025, the Division of Corporation Finance of the US Securities and Exchange Commission (SEC) issued a statement clarifying its views on the application of federal securities laws to certain proof-of-stake (PoS)...more

Latham & Watkins LLP

SEC Staff Clarifies That Certain Protocol Staking Activities Do Not Implicate the Registration Requirements of the US Federal...

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The Staff clarifies that protocol staking does not qualify as a security under the Howey Test, clearing the way for market participants to engage in staking....more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC: Certain ‘Protocol Staking Activities’ Are Not Securities Transactions

On May 29, 2025, the Securities and Exchange Commission’s (SEC’s) Division of Corporation Finance issued a statement providing that certain cryptoasset staking activities in connection with proof-of-stake (PoS) networks do...more

Morrison & Foerster LLP

SEC Concludes Certain Protocol Staking Activities Are Not Securities Offerings

On May 29, 2025, the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (SEC) issued a statement[1] (the “Staking Statement”) concluding that certain protocol staking...more

A&O Shearman

SEC staff takes a position on the securities status of protocol staking activities

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On May 29, 2025, the staff of the SEC’s Division of Corporation Finance (the “Staff”) issued a statement concluding that certain proof-of-stake blockchain “staking” activities do not involve the offer or sale of “securities”...more

Fenwick & West LLP

SEC Staff Statement Concludes Protocol Staking Is Not a Securities Transaction

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On May 29, 2025, the SEC’s Division of Corporation Finance (Corp Fin) released a Statement on Certain Protocol Staking Activities clarifying that certain crypto asset staking activities on proof-of-stake (PoS) blockchain...more

Lowenstein Sandler LLP

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

Morrison & Foerster LLP

U.S. SEC Issues Statement on Stablecoins

On April 4, 2025, the staff of the U.S. Securities and Exchange Commission (SEC or “Commission”) Division of Corporation Finance (“Staff”) issued a statement on stablecoins (the “Stablecoin Statement”), outlining the Staff’s...more

Fenwick & West LLP

SEC’s Corp Fin Says Most Stablecoins Are Not Exchanged in Securities Transactions

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On April 4, the SEC released a Statement on Stablecoins. In the statement, the Division of Corporation Finance provides its view that offers and sales of a certain subset of crypto assets commonly known as “stablecoins”...more

Stinson - Corporate & Securities Law Blog

SEC Staff Speaks to Stablecoins

The SEC staff has promulgated new views on stablecoins.   Specifically, the staff statement addresses stablecoins that are designed to maintain a stable value relative to the United States Dollar, or “USD,” on a one-for-one...more

Fenwick & West LLP

Looking Under the Hood of $TRUMP’s Legal Strategy

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On Friday, January 17, 2024, President Donald J. Trump announced the launch of the $TRUMP memecoin, which was organized and sold by CIC Digital, an affiliate of the Trump Organization. Within 60 hours, $TRUMP reportedly...more

Farrell Fritz, P.C.

SEC’s First Two NFT Enforcement Actions Cast Shadow of Ambiguity

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The Securities and Exchange Commission recently brought its first two enforcement actions against issuers of non-fungible tokens (NFTs), resulting in cease-and-desist orders, penalties and other remedies, finding that the...more

Jones Day

SEC Brings Its First Enforcement Action Against Non-Fungible Token Sellers

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Two SEC commissioners dissented and urged the Commission to provide further guidance on non-fungible tokens ("NFTs")....more

Mayer Brown Free Writings + Perspectives

For the First Time, the US SEC Sanctions an NFT Issuer for Selling Unregistered Securities in SEC v. Impact Theory

In a published settlement of the charges on August 28, 2023, the US Securities and Exchange Commission (“SEC”) stated that non-fungible tokens (“NFTs”) issued by Impact Theory, LLC (“Impact”) were “securities” under US...more

Ballard Spahr LLP

SEC Finds NFT to Be a Security in Landmark Action

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Summary - The SEC’s focus on the crypto industry expanded this week to include non-fungible tokens (NFTs). In its first NFT-enforcement action, the SEC settled with Impact Theory, a media and entertainment company, over...more

Jones Day

Ripple and Terraform Labs: Two New York District Courts Address the Status of Certain Crypto Assets as Securities

Jones Day on

In Short - The Situation: Recently, two judges in Southern District of New York were required to apply the Howey test in separate cases to decide whether sales of certain crypto assets were investment contracts, and thus...more

Jenner & Block

Client Alert: Ripple, and Terra, and Coinbase, Oh My!

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Three federal judges in the Southern District of New York sit at the center of the long-running battle between the SEC and the crypto industry, overseeing cases that may eventually bring clarity to the industry. After two...more

Mayer Brown Free Writings + Perspectives

Defining Digital Asset Securities: US District Court Issues Summary Judgment Rulings in SEC v. Ripple Labs

For the past several years, many have viewed “SEC v. Ripple” as one of the defining conflicts in the US crypto regulatory landscape. At the heart of this dispute is the question of whether digital tokens are “securities” for...more

Nelson Mullins Riley & Scarborough LLP

Dead Canary in the LBRY - Federal Judge Grants SEC’s Motion, Rules Digital Asset Is a Security

In a case watched by companies that offered and sold digital assets Federal District Court Judge Paul Barbadoro recently granted summary judgment for the Securities and Exchange Commission (“SEC”) against LBRY, Inc. This case...more

Polsinelli

Shhhh! – SEC Wins Summary Judgment Over Library

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While the blockchain crypto community is processing the latest round of “crypto contagion,” potentially lost in the busy news week was a significant legal development regarding what digital assets qualify as securities under...more

Eversheds Sutherland (US) LLP

SEC’s latest shot at the crypto industry: BlockFi sanctioned for its unregistered crypto-lending product

There is no love lost between the US Securities and Exchange Commission (SEC) and the crypto industry with tensions escalating over the past year. So it seems fitting that on Valentine’s Day, the SEC brought a...more

UB Greensfelder LLP

Comparing Apples To Orange [Groves]: How The SEC Defines Digital Assets As Securities

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In any classic securities regulation textbook, you’ll be sure to find a chapter called “Definition of a Security.” Besides your typical bonds and stocks, which are easily identifiable as securities, the most infamous (and a...more

Orrick - On the Chain

The SEC Gets its Kiks out of a Successful Application of the Howey Test

Orrick - On the Chain on

In a closely-watched cryptocurrency case, on September 30, the Southern District of New York ruled in favor of the SEC in SEC v. Kik Interactive, Inc., holding that the Kin tokens Kik had offered and sold through a pre-sale...more

Cozen O'Connor

Has the SAFT Been KIKed to the Curb?

Cozen O'Connor on

On September 30, 2020, SDNY Judge Alvin Hellerstein issued a decision of major significance for the digital token industry in Securities and Exchange Commission v. Kik Interactive, Inc. This is only the second federal court...more

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