The Office of the Comptroller of the Currency published an interpretive letter on September 21, 2020 (Letter), confirming that national banks and federal savings associations (together, banks) may hold “stablecoin” reserves...more
Community Development Financial Institution (CDFI) certification is awarded to “community-based organizations that seek to expand economic opportunity in low-income communities and provide financial products and services to...more
10/9/2020
/ Capital Requirements ,
Certifications ,
Community Development ,
Community Development Financial Institution (CDFI) ,
Community Reinvestment Act ,
Financial Institutions ,
Fund Managers ,
Investment Opportunities ,
Loans ,
Venture Capital ,
Volcker Rule
The Office of the Comptroller of the Currency (OCC) issued an interpretive letter (Letter) on July 22, 2020, stating that national banks and federal savings associations have the authority to provide custody services for...more
Blockchain technology continues to mature and gain acceptance for a wide range of potentially disruptive financial and commercial uses. In the wake of COVID-19, we have seen an increased focus on the research and development...more
8/18/2020
/ 3D Printing ,
Bank of England ,
Blockchain ,
China ,
Coronavirus/COVID-19 ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Currency ,
Financial Institutions ,
FinTech ,
Innovative Technology ,
Japan ,
Medical Devices ,
MiPasa ,
Popular ,
Stablecoins ,
UK ,
Virtual Currency ,
World Health Organization
The Commodity Futures Trading Commission published in the Federal Register on June 24, 2020 its final interpretive guidance concerning retail commodity transactions involving certain digital assets (2020 Guidance).1 The 2020...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more
5/22/2019
/ Anti-Money Laundering ,
ATMs ,
Bank Secrecy Act ,
Casinos ,
Compliance ,
Convertible Virtual Currencies (CVCs) ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Exemptions ,
Financial Institutions ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Money Laundering ,
Money Services Business ,
Money Transfer ,
New Guidance ,
Payment Processors ,
Peer-to-Peer ,
Risk Assessment ,
Terrorism Funding ,
Trading Platforms ,
Virtual Currency
Through two publications on April 3, 2018, the Staff of the Securities and Exchange Commission provided greater clarity on the application of the federal securities laws to blockchain-based “digital assets.”1 While the Staff...more
The U.S. Securities and Exchange Commission announced two settled enforcement actions on November 16, 2018, imposing registration requirements and civil penalties against issuers of initial coin offerings (ICOs) for failing...more
12/6/2018
/ Broker-Dealer ,
Civil Monetary Penalty ,
Compliance ,
Digital Assets ,
Enforcement Actions ,
Financial Industry Regulatory Authority (FINRA) ,
Howey ,
Initial Coin Offering (ICOs) ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
Settlement ,
Unregistered Securities
The U.S. Securities and Exchange Commission on July 26, 2018 formally disapproved the proposed rule change by Bats BZX Exchange, Inc. (BZX) seeking to list and trade shares of the Winklevoss Bitcoin Trust (Trust). In...more
The staff of the Divisions of Enforcement and Trading and Markets (collectively, Staff) of the U.S. Securities and Exchange Commission (SEC) on March 7, 2018 jointly issued a statement on digital asset trading platforms...more
3/28/2018
/ Alternative Trading System (ATS) ,
Broker-Dealer ,
CFTC ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Enforcement Actions ,
Initial Coin Offering (ICOs) ,
Investor Protection ,
Investors ,
Market Participants ,
Personal Liability ,
Registration Requirement ,
Securities ,
Securities and Exchange Commission (SEC) ,
Token Sales
The U.S. Commodity Futures Trading Commission’s (CFTC) LabCFTC office on October 17, 2017 issued A CFTC Primer on Virtual Currencies (Primer) indicating, among other things, that certain initial coin offerings (ICOs) within...more
10/23/2017
/ Bitcoin ,
CFTC ,
Commodities ,
Derivatives ,
FinTech ,
Initial Coin Offering (ICOs) ,
Jurisdiction ,
New Guidance ,
Popular ,
Risk Factors ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
Since January 2017, more than $2 billion has been raised through the rapidly growing market for so-called “token sales” or “initial coin offerings” (ICOs). The U.S. Securities and Exchange Commission (SEC) announced on July...more
10/7/2017
/ BaFin ,
Banking Restrictions ,
Banks ,
China ,
Corporate Counsel ,
Corporate Issuers ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Financial Conduct Authority (FCA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Germany ,
Hong Kong ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Initial Coin Offering (ICOs) ,
Investors ,
Monetary Authority of Singapore ,
People's Bank of China ,
Securities and Exchange Commission (SEC) ,
Singapore ,
Token Sales ,
UK ,
Unregistered Securities ,
Young Lawyers