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Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

Patchwork of Cryptocurrency Regulators Increasingly Stitch Together Cooperative Enforcement Efforts

Recent Enforcement Actions and Guidance from DOJ, FinCEN, and OFAC Demonstrate the Increased Commitment — and Cooperation — of Federal Regulators to Police Digital Currencies, Including Their Use in Ransomware Attacks - Amid...more

Why It’s Taking So Long: the SEC and FINRA Issue Guidance on Crypto Broker-Dealer Complexities

The SEC signaled last week that it appears to be growing more comfortable approving certain digital asset activities, qualifying the first two initial coin offerings ever to proceed as registered securities....more

Tying It All Together: FinCEN Consolidates Several Years of Cryptocurrency Guidance

For the past several years, advocates of crypto assets and other public uses of blockchain technology have sought guidance from U.S. regulators regarding the legal implications of new or novel uses of that technology....more

Recent SEC Settlements Reveal a Roadmap for Resolving Investigations of Unregistered Initial Coin Offerings

Since at least July 2017, when the Securities and Exchange Commission (SEC) announced it expected initial coin offerings (ICOs) to either register under U.S. securities laws or qualify for an exemption, crypto-market...more

The Next Shoe Drops: SEC Makes Clear Crypto Exchanges Must Register

The Securities and Exchange Commission (SEC) took an important step in its steady march of enforcement actions involving digital assets. On November 8, 2018, the SEC announced that Zachary Coburn, the founder of crypto token...more

Japan Continues to Embrace Cryptocurrency with Launch of Self-Regulatory Organization: Will the US or Other Countries Follow Suit?

On October 24, 2018, Japan’s Financial Services Agency (FSA) gave the country’s cryptocurrency industry self-regulatory status, allowing the Japan Virtual Currency Exchange Association (JVCEA) power to police and penalize...more

A Peek Behind the Curtain at the Largest Crypto Trading Platforms

New York Attorney General’s Office publishes a detailed report on policies and practices at virtual asset trading platforms, citing multiple common deficiencies - The New York Attorney General’s Office (“NYAG”) issued a...more

Dividing Up the Sandbox: Recent Actions and Public Statements Demonstrate How the SEC and CFTC Are Dividing up the Cryptocurrency...

EXECUTIVE SUMMARY – Following testimony February 6th before the U.S. Senate, as well as a series of recent enforcement actions, it is clear that both the SEC and CFTC are picking up steam in their efforts to command a...more

Bad Advice and Blockchain-R-US: Stern Warnings from the SEC and CFTC Chairmen on Unregistered ICOs, Cashing In on “Crypto-Mania”

SEC Chairman Jay Clayton has issued a broad warning to companies and individuals trying to “cash in” on the market frenzy surrounding Bitcoin and other cryptocurrencies. His prepared remarks at the Securities Regulation...more

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