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Working Through the Riddles of Tokenized Securities

Key Points: - The SEC’s Crypto Task Force cited past “hostility” toward digital assets and aims to create a regulatory framework. - Tokenized securities face complex regulatory challenges, including compliance with the...more

How Private Fund Managers Can Minimize the Risk of Government Probes in Volatile Markets

Key Points - - Periods of market volatility expose firms managing private funds to increased scrutiny from government agencies, regardless of the existence of any actual misconduct. - Government agencies may open an...more

Inside the Courts – An Update From Skadden Securities Litigators - February 2025

Key Points - - In 2024, securities litigation remained consistent with historical averages, with a slight increase in core filings and cases related to COVID-19 and artificial intelligence. - The U.S. Supreme Court had an...more

Cryptocurrencies Stand To Gain From New Regulators and a Receptive Congress

Key Points - - A Republican president and Congress are expected to be more supportive of digital assets than the current administration. - There is a reasonable chance that legislation creating a regulatory framework...more

How and When SEC Recordkeeping Rules May Apply to AI-Generated Content

AI has revolutionized the way many businesses operate. Firms in the financial sector are eager to take advantage of rapidly developing technologies but do not want to risk running afoul of relevant Securities and Exchange...more

Supreme Court Holding That SEC Actions Seeking Civil Penalties for Securities Fraud Must Be Heard by a Jury Calls Into Question...

In Securities and Exchange Commission v. Jarkesy, the U.S. Supreme Court held that “the Seventh Amendment entitles a defendant to a jury trial when the [Securities and Exchange Commission] seeks civil penalties against him...more

SEC Amends Reg S-P To Strengthen Data Breach Response Requirements and Protect Investor Information

On May 16, 2024, the Securities and Exchange Commission (SEC) announced the adoption of amendments to Regulation S-P (Reg S-P), which broadly track the changes originally proposed in March 2023. The revised Reg S-P requires...more

Inside the Courts – An Update From Skadden Securities Litigators - May 2024

Spotlight - Macquarie Ruling Raises the Bar for Securities Fraud Claims - Key Points - - On April 12, 2024, the U.S. Supreme Court unanimously reversed and vacated the Second Circuit’s decision in Macquarie...more

Understanding SEC’s Focus Amid Lack of Final AI Rules

Last year, the U.S. Securities and Exchange Commission (SEC) proposed ambitious rules relating to artificial intelligence (AI) that have drawn significant commentary and criticism. While it is unlikely that any changes in the...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - January 2024

SEC Wins Summary Judgment on Howey Issue in Terraform Litigation - On December 28, 2023, Judge Jed Rakoff in the Southern District of New York issued a summary judgment decision in SEC v. Terraform Labs Pte. Ltd., a...more

Fifth Circuit Reverses CFTC Penalty Judgment Under ‘Fair Notice’ Doctrine

On January 8, 2024, in a decision that underscores the potential viability of fair-notice defenses to U.S. regulators’ rule interpretations, the U.S. Court of Appeals for the Fifth Circuit reversed a $6.5 million penalty...more

SEC Enforcement Division Director Clarifies Approach to Compliance Officer Liability

In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...more

CFTC Charges DeFi Developers With Facilitating Off-Exchange Trading

On September 7, 2023, the Commodity Futures Trading Commission (CFTC) issued three enforcement settlement orders against developers of decentralized finance (DeFi) protocols. The orders charge Opyn, Inc., Deridex, Inc., and...more

Inside the Courts – An Update From Skadden Securities Litigators - September 2023

Two Sides of the Same Coin: Analyzing the Recent Ripple and Terraform Decisions - Key Points - - In July 2023, Judges Torres and Rakoff in the Southern District of New York issued rulings on whether digital asset sales...more

DOJ Relies on Traditional Statutes To Charge Defendants in Cryptoasset Fraud Cases

Two recent indictments highlight the Department of Justice’s (DOJ’s) continuing use of the traditional wire fraud, money laundering and identity theft statutes to pursue fraud involving digital assets, indicating that law...more

New Senate Crypto Bill Would Limit SEC Regulatory Role in Favor of CFTC

A bipartisan bill introduced in the U.S. Senate last week seeks “to bring crypto assets within the regulatory perimeter” by granting oversight responsibility to the Commodity Futures Trading Commission (CFTC) for most forms...more

Ripple Labs : District Court Holds That Direct Digital Token Sales Constituted Investment Contracts Under Howey, but Other...

On July 13, 2023, Judge Torres of the U.S. District Court for the Southern District of New York issued a much-awaited summary judgment decision in SEC v. Ripple Labs, Inc., No. 1:20-cv-10832-AT-SN (S.D.N.Y. July 13, 2023),...more

SEC Adopts Rules To Prohibit Fraud Related to Security-Based Swaps and Exertion of Undue Influence Over SBS Swap Dealer CCOs

On June 7, 2023, the Securities and Exchange Commission (SEC) adopted two new rules to address misconduct in the security-based swaps market. The first rule prohibits fraud, manipulation and deception in connection with...more

SEC Staff Raises the Bar for Broker-Dealers Under Regulation Best Interest

On April 20, 2023, the Securities and Exchange Commission (SEC) released a Staff Bulletin (Bulletin) on the care obligations for broker-dealers and investment advisors, pursuant to Regulation Best Interest (Reg BI) and the...more

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