Keith Miller

Keith Miller

Perkins Coie

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Latest Publications


Federal Authorities Announce Settlement with Ripple Labs Inc. Resolving Investigation

Federal authorities announced this week a settlement with Ripple Labs Inc. and its subsidiary, XRP Fund II, resolving an investigation by FinCEN and the Department of Justice into violations of the Bank Secrecy Act.  ...more

5/7/2015 - Bank Secrecy Act DOJ FinCEN Open Source Software Virtual Currency

2015 SEC Speaks Conference: SEC to Balance Broad Enforcement Agenda and Initiatives with Focus on Core Mission

The U.S. Securities and Exchange Commission (SEC) touted an expansive regulatory agenda at this year’s “SEC Speaks” conference, held February 20-21, 2015, in Washington, D.C. At this year’s Speaks, SEC representatives...more

2/24/2015 - Market Participants Regulatory Agenda SEC Strategic Enforcement Plan

NYDFS Releases Revised BitLicense Proposal

The New York State Department of Financial Services (“NYDFS”) released its revised proposed BitLicense regulatory framework earlier today. Once the revised framework is published in the New York State Register, it will...more

2/5/2015 - Bitcoin BitLicense NYDFS Proposed Regulation

Searching for Greener Pastures: SEC Insider Trading Enforcement in a Post-Newman Era

In United States v. Newman, the U.S. Court of Appeals for the Second Circuit dealt a substantial blow to federal prosecutors’ epic crackdown on insider trading by raising the bar for the government’s burden of proof in...more

12/17/2014 - Enforcement Actions Illegal Tipping Insider Trading Material Nonpublic Information Personal Benefit Popular Portfolio Managers Rule 10b-5 Securities Securities Fraud US v Newman

New York Federal Prosecutor Intensifies Scrutiny of Illegal Bitcoin Activity

The U. S. Attorney for the Southern District of New York, Preet Bharara, has issued several recent statements signaling a steady pursuit of criminal conduct related to bitcoin. First, on Thursday, November 6, 2014, Trendon...more

11/13/2014 - Bitcoin Investigations Popular Virtual Currency

Silk Road’s Ulbrecht Fails in Dismissal Bid, Court Strengthens Federal Bitcoin Enforcement

In another installment of the continuing saga surrounding the shuttering of the Silk Road online marketplace and arrest of its alleged creator and operator, Ross William Ulbricht (Ulbricht), a Southern District of New York...more

7/22/2014 - Bitcoin FinCEN Indictments IRS Motion to Dismiss Popular Silk Road

Government Brings Important Case Against Illegal Marketplace “Silk Road;” Government Acknowledges Lawful Uses Of Bitcoin

The virtual currency industry is in the news once again following the October 1, 2013, Federal Bureau of Investigation’s shutdown of the “Silk Road” website. As part of the shutdown of the well-known underworld bazaar, the...more

10/4/2013 - Bitcoin FBI Silk Road Virtual Currency

Virtual Currency: Government Scrutiny Continues To Grow

Riding the coattails of an August 6, 2013 federal court ruling that alleged Ponzi-schemer Trendon Shavers’ Bitcoin-based investment scheme constituted an investment contract, and therefore a “security” under the federal...more

8/21/2013 - Bitcoin Ponzi Scheme Virtual Currency

Court Maintains Bitcoin-Related Investment Scheme Is A Security Under The Federal Securities Laws

In response to the SEC’s first civil complaint arising from online virtual currency trading, alleged Bitcoin Ponzi schemer Trendon Shavers recently challenged the district court’s authority to hear the case. ...more

8/9/2013 - Bitcoin FinCEN Ponzi Scheme SEC Securities Virtual Currency

Bitcoin Under SEC Scrutiny: First Civil Prosecution Brought Against Alleged Virtual Currency Ponzi Scheme Company

On July 23, 2013, the SEC ventured into the electronic currency world by filing a civil complaint against virtual currency “trader” Trendon Shavers and his company, Bitcoin Savings and Trust, in the U.S. District Court for...more

7/30/2013 - Bitcoin Ponzi Scheme SEC Virtual Currency

Federal Government Crackdown On Virtual Currency Heats Up

Asset Seizures and Arrests Mark Recent Federal Virtual Currency Enforcement Actions - Federal authorities have initiated several recent enforcement actions that are indicative of continuing regulatory changes in the...more

5/31/2013 - Bitcoin Enforcement FinCEN Money Laundering Virtual Currency

SEC Speaks: Agency Takes Back-To-Basics Approach In Face Of Changing Leadership, Congressional Mandates And New Technologies

The annual “SEC Speaks” conference, in which Securities and Exchange Commission (SEC) representatives review the agency’s efforts over the past year and preview the year to come, was held on February 22-23, 2013. A...more

2/25/2013 - CFTC Citigroup Crowdfunding Dodd-Frank Enforcement FINRA FSOC Funding Portal Insider Trading Investor Protection JOBS Act Mary Jo White SEC Whistleblowers

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