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First Token Offering Qualified by the SEC Under Regulation A

On July 10, 2019, Blockstack Token LLC (“Blockstack”), a wholly-owned subsidiary of Blockstack PBC, a Delaware public benefit corporation, became the first company to have an offering of digital assets qualified by the U.S....more

SEC Issues Historic No-Action Letter and Releases Framework for “Investment Contract” Analysis of Digital Assets

On April 3, 2019, the Strategic Hub for Innovation and Financial Technology (“FinHub”) of the U.S. Securities and Exchange Commission (“SEC”) published two pieces of guidance on when a blockchain-enabled digital asset will,...more

First SEC Enforcement Action Against Unregistered Digital Token Exchange

Until November 8, 2018, the enforcement actions of the U.S. Securities and Exchange Commission (SEC) in the digital token (aka cryptocurrency) space have primarily focused on the primary issuances of tokens. However, on...more

The Journey from Security to Non-Security: SEC Director Comments on Mutability of Token Treatment

Many in the blockchain and cryptocurrency community were in a celebratory mood on June 14, 2018, following a landmark speech given by William Hinman, Director for the Division of Corporation Finance of the U.S. Securities and...more

The Monetary Authority of Singapore Clarifies Its Treatment of Token Offerings - To Regulate or Not to Regulate? – That Is No...

In a press release issued on Tuesday, August 1, the Monetary Authority of Singapore (“MAS”) provided its most direct guidance yet on how it intends to treat “token offerings.” For those looking for concrete rules,...more

Howey Got Here: SEC Issues Guidance on Token Offerings

The Howey test lives on—now in a lesson in what not to do when it comes to token offerings. Token offerings, also known as “initial token offerings,” “token launches,” “token sales,” “initial coin offerings,” or “ICOs,”...more

SEC Staff Provides Guidance on Conflict Mineral and Resource Extraction Disclosure Requirements

On May 30, 2013, the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “SEC”) published Frequently Asked Questions (“FAQs”) regarding certain disclosures required under the Dodd-Frank Wall Street Reform...more

SEC Approves New Compensation Committee and Adviser Independence Listing Standards

As discussed in two previous Client Alerts, on June 20, 2012, the U.S. Securities and Exchange Commission (the “SEC”) adopted Rule 10C-1 to implement the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection...more

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