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D.C. Circuit Finds SEC Acted “Arbitrarily and Capriciously” in Disapproving Proposed Bitcoin ETP

The U.S. Court of Appeals for the D.C. Circuit (the “Court”) issued a major ruling against the Securities and Exchange Commission (“SEC”) on August 29, 2023, holding that the SEC acted arbitrarily and capriciously when it...more

SEC Brings First-Ever Enforcement Action Against Non-Fungible Cryptocurrency Tokens

The Securities and Exchange Commission (“SEC”) issued a cease-and-desist order on August 28, 2023, charging Impact Theory, LLC (“Impact Theory”) with conducting an unregistered offering of crypto asset securities in violation...more

The Southern District of New York Splits on Whether a Digital Token is a “Security”

In the latest decision evaluating the application of federal securities laws to the digital asset context, Judge Jed S. Rakoff of the United States District Court for the Southern District of New York (“SDNY”) ruled in favor...more

In Major Ruling Celebrated by Crypto Industry, Federal Court Holds That XRP Token is “Not Necessarily a Security”

On July 13, 2023, the United States District Court for the Southern District of New York (the “Court”) issued a major ruling in in a closely-followed lawsuit brought by the Securities and Exchange Commission (the “SEC”)...more

Compensation Clawback Crackdowns – an Emerging Enforcement Focus

DOJ and the SEC Enforcement Division have launched initiatives targeting executive compensation clawbacks. The SEC is aggressively pursuing SOX 304 compensation clawbacks from Chief Executive Officers and Chief Financial...more

DOJ Expands Cryptocurrency Enforcement with Formation of Prosecutors Network

In response to President Biden’s March 9, 2022 Executive Order on digital assets, the DOJ announced the formation of a new network of prosecutors tasked with becoming specialists in investigating and prosecuting alleged...more

SEC Brings First-Ever Insider Trading Action Involving Digital Assets in Parallel Civil Suit to SDNY’s Criminal Indictment

The Securities and Exchange Commission (the “SEC”) on July 21, 2022, filed a complaint (the “SEC Complaint”) alleging insider trading violations against an insider, his brother, and a friend, claiming that the trio engaged in...more

SEC Reported to Add Another Dimension to its Cryptocurrency Enforcement Push: Insider Trading

Key Takeaways - According to sources with firsthand knowledge, the SEC is conducting an industry-wide inquiry into alleged insider trading activities of cryptocurrency exchanges. Insider trading occurs when a corporate...more

SEC Tags Nvidia for Alleged Disclosure Insufficiencies in its Cryptocurrency Mining Business

Key Takeaways- The United States Securities and Exchange Commission announced a settlement against chip manufacturing company Nvidia Corporation, on May 6, 2022, for inadequate disclosures concerning the impact of...more

“Hashing” It Out: Federal Jury Decides Some Cryptocurrency Products are not Securities

Whether a cryptocurrency product is a security is an issue with serious regulatory consequences. In recent years, the Securities and Exchange Commission (“SEC”) has taken a broad position that various crypto assets are...more

The Cryptocurrency Market – Prepare for an Uptick in Enforcement Activity

Key Takeaways - The federal government has the cryptocurrency market in its crosshairs. Specifically, the DOJ, SEC and CFTC have all continued to make announcements and show interest in regulating cryptocurrency and enforcing...more

DOJ and SEC Release Second Edition of FCPA Resource Guide: Key Updates and Takeaways

...On July 3, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act. A link to the Second Edition is...more

Biotech Beware: Increased SEC Focus on COVID-Related Activities and Claims Amplifies the Enforcement Risks for the Unaware or...

Key Takeaways - As stocks surge in reaction to news about COVID-19-related products and solutions, the SEC is actively working to protect investors from misleading statements, fraud, and even investment scams relating to the...more

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