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Client Update: OFAC “May” Include Virtual Currency Wallet Addresses on the SDN List

The Office of Foreign Asset Control of the Department of Treasury (OFAC) forecasted that it “may include as identifiers on the SDN List specific digital currency addresses associated with blocked persons.” SDN stands for...more

Rapidly Shifting Regulatory Landscape for Virtual Currencies | Market Participants: Stay Tuned

As US regulators have been active in terms of virtual currency regulation, there are three important updates to which attention should be paid. The New York State DFS guidance, the FinCEN letter to Senator Wyden and the...more

New York Department of Financial Services Guidance Complicates a Crowded Virtual Currency Regulatory Landscape

On February 7, 2018, the New York Department of Financial Services issued “Guidance on Prevention of Market Manipulation and Other Wrongful Activity” imposing stringent reporting requirements of which virtual currency...more

Five Regulatory Implications for Blockchain Tokens as an "Asset Class"

As 2017 fades in the rear view mirror of the speeding car that is blockchain, five significant regulatory issues will likely be speedbumps for blockchain tokens in 2018. Pundits spend much time talking about blockchain tokens...more

Recent SEC Enforcement Actions and Public Statement in the Blockchain Space

The SEC has recently taken significant public steps in the regulation of token sales (popularly known as initial coin offerings, or ICOs) relating to blockchain. While the SEC Guidance provides clarity for critical points and...more

Uniform Law Commission Addresses Virtual Currency Regulation

On October 9, 2017, the Uniform Law Commission released a proposed state statute, which, if adopted, will require a new type of state licensure for persons engaging in “virtual business activities.” The proposed regulation...more

LabCFTC Releases Primer on Virtual Currencies without Broadly Addressing Blockchain Tokens

On October 17, 2017, the Commodity Futures Trading Commission’s LabCFTC released “A CFTC Primer on Virtual Currencies.” The Primer provides an overview or virtual currencies and their potential uses, discusses the role of...more

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