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The Clock Is Ticking: File Now to “Complete” the Louisiana Virtual Currency Business Activity Application by the Statutory...

As the first state to follow New York’s lead in issuing a crypto-specific license, Louisiana began accepting Louisiana Virtual Currency Business Activity (VCBA) license applications as of January 1, 2023. All entities engaged...more

The Cryptocurrency Industry Breathes a Sigh of Relief Following President Biden’s Executive Order

On March 9, 2022, US President Joe Biden signed an unprecedented executive order directing federal agencies to coordinate their approach to clarifying cryptocurrency regulations. Sighs of relief were heard across the industry...more

OFAC Reaffirms Focus on Virtual Currency with Sanctions Law Guidance

On October 15, 2021, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) announced updated guidance for virtual currency companies in meeting their obligations under US sanctions laws. On the same day,...more

The SEC Takes Aim at Another Initial Coin Offering

A recent complaint concerning KIK Interactive Inc. filed in the US District Court of the Southern District of New York reveals some SEC priorities for cryptocurrency enforcement actions. The complaint indicates that the SEC...more

Blockchain Tokens: The SEC Staff Issues Its Framework for Determining Whether an ICO is an Issuance of Securities

In its long-awaited guidance, the Staff of the Securities and Exchange Commission recently provided a lengthy list of factors to consider when determining whether an initial coin offering (ICO) is a security. While the...more

The CFTC is Policing Virtual Currency Boiler Rooms

Following a three-day bench trial, US District Judge Jack B. Weinstein found in favor of the CFTC and ordered a permanent injunction banning Patrick K. McDonnell from dealing in virtual currency and ordering a judgment for...more

No Fraudulent Initial Coin Offering Is Too Small for the SEC

On August 14, 2018, the SEC announced a $30,000 fine and trading ban against a company and its founder, finding that the defendants carried out a fraudulent ICO to fund a speculative oil-drilling venture, and that such...more

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

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