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OCC Gives Banks Keys to the Crypto Kingdom

On July 22, 2020, the Office of the Comptroller of the Currency (“OCC”) published an Interpretive Letter (the “Letter”) declaring that national banks and federal savings associations (collectively, “national banks”) may...more

Return of the ICO? A Potential Pathway Forward

On February 6, 2020, SEC Commissioner Hester Peirce presented her proposal of a new regulatory scheme for legal ICOs in the United States (“Safe Harbor”). To date, token issuers have struggled with the U.S. Securities and...more

New York Proposed Guidance on Virtual Currencies

On December 11, 2019, the New York State Department of Financial Services ("DFS") issued two proposed changes to the regime that is in place in New York for the regulation and licensing of virtual currency ("VC") businesses....more

Ether Is…a Commodity

It is official. Finally. On October 10, 2019, the Commodity Futures Trading Commission (“CFTC”) Chairman Heath Tarbert announced that he believes ether is a commodity and thus falls under the jurisdiction of the CFTC....more

How Many Times Does the SEC Have to Repeat Itself Before the World Listens?

SEC Halts ICO After Finding that Tokens are Securities - Remember in July of this year when the Securities and Exchange Commission (SEC) said in its Decentralized Autonomous Organization (DAO) Report that "U.S. federal...more

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