On February 27, 2025, the Securities and Exchange Commission’s Division of Corporation Finance (“CorpFin”) issued a Staff Statement announcing its view that meme coin transactions do not involve the offer and sale of...more
3/6/2025
/ Compliance ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Fraud ,
Howey ,
Investment ,
Market Manipulation ,
Securities ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Token Sales
Federal and state regulators have taken an increased interest in regulating cryptocurrencies, digital assets, and the larger blockchain ecosystem. This landscape is opaque and rapidly evolving, and many industry participants...more
9/25/2023
/ Anti-Money Laundering ,
Bitcoin ,
Bitcoin Mining ,
Blockchain ,
CFIUS ,
CFTC ,
Coinbase ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Ethereum ,
FinCEN ,
Fraud ,
Insider Trading ,
Ponzi Scheme ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Unregistered Securities
The Attorney General Alliance (“AGA”) recently issued a collaborative White Paper that signals heightened scrutiny of digital asset businesses by state Attorneys General in coming years. Recognizing that it is “no longer...more
7/13/2022
/ Blockchain ,
Civil Monetary Penalty ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
FinCEN ,
Fraud ,
Injunctions ,
Money Laundering ,
Non-Fungible Tokens (NFTs) ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Restitution ,
Securities and Exchange Commission (SEC) ,
State Attorneys General ,
Uniform Commercial Code (UCC)
The Financial Institutions Reform, Recovery and Enforcement Act of 1989 (“FIRREA”) is a powerful tool in the prosecutorial arsenal. Due to its long statute of limitations, expansive penalty provision, and low civil burden of...more
3/19/2021
/ CARES Act ,
Civil Monetary Penalty ,
CMBS ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Financial Institutions ,
FIRREA ,
Fraud ,
Paycheck Protection Program (PPP) ,
SBA ,
U.S. Treasury
SEC Enforcement and Exams Likely to Focus More on Private Funds in the New Administration -
For the next several weeks and months, intense focus will be trained on determining the priorities of the Biden administration. We...more
2/2/2021
/ Annual Reports ,
Biden Administration ,
Confidential Information ,
Conflicts of Interest ,
Coronavirus/COVID-19 ,
Cybersecurity ,
EBITDA ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fees ,
Investigations ,
Investment Adviser ,
Investment Companies ,
Private Funds ,
Ransomware ,
Risk Alert
With the change of administration in Washington, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) is widely expected to assume a posture of aggressive enforcement of consumer protection laws. One area that we...more
1/15/2021
/ CARES Act ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Dodd-Frank ,
Enforcement Actions ,
Financial Institutions ,
Interest Rates ,
Payday Lending Rule ,
Title X
Every change in presidential administration results in shifts to agencies’ policy priorities and enforcement efforts. In a Biden Administration, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”), in particular,...more
12/18/2020
/ Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Disparate Impact ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
HUD ,
Protected Class ,
Racial Bias