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SEC Seeks Additional Comment on Whether DeFi Systems Must Register as "Exchanges"

In Short - The Situation: The U.S. Securities and Exchange Commission ("SEC" or "Commission") has reopened the comment period for its January 2022 proposal to amend Exchange Act Rule 3b-16 to broadly expand the...more

EU and U.S. Regulatory Sandboxes: Groundbreaking Tools for Fostering Innovation and Shaping Applicable Regulations

In Short - The Situation: Regulatory "sandboxes" are trending. They represent a unique approach to regulation that permits selected companies to test and experiment with new and innovative products and services....more

Economic Report of the President to the Crypto Industry: Thanks, But No Thanks

In Short - The Situation: For the first time, the Economic Report of the President (the "Report") includes a chapter on digital assets....more

New York Department of Financial Services Issues Guidance on Virtual Currency Custodial Services

In Short - The Situation: Following a string of bankruptcies among virtual currency firms, the New York Department of Financial Services has issued guidance on the practices and procedures it expects from certain...more

"MetaBirkins" Bagged: NFT Creator Found Liable for Trademark Infringement

In a closely watched trademark infringement case involving non-fungible tokens ("NFTs"), a jury found that the sale of digital images of Hermès's Birkin bags as NFTs infringed and diluted Hermès's trademarks....more

Fed Policy Statement Adds Hurdles to Digital Asset Activities and Innovation by State Banks

In Short - The Situation: The Federal Reserve Board ("Board") has issued a new policy statement ("Policy Statement") imposing limits, including Board approval requirements, on digital asset activities and other novel...more

CFTC Partners with SEC and DOJ to Bring Coordinated DeFi Enforcement Action Targeting Oracle Manipulation

In Short - The Situation: Decentralized finance ("DeFi") is a rapidly growing sector that, by definition, eschews centralized financial institutions altogether. Misconduct that has accompanied that growth has drawn the...more

Bank Regulators Issue Joint Statement on Safety and Soundness of Crypto Activities

In Short - The Situation: Since clarifying the legal permissibility of certain crypto activities in 2020 and early 2021, the Federal banking agencies have begun to tighten regulatory scrutiny of such activities, warning...more

Digital Assets Defined: Writing Digital Assets into the Bankruptcy Code

As discussed in previous installments of this White Paper series, the Lummis-Gillibrand Responsible Financial Innovation Act (the "Bill") proposes a comprehensive statutory and regulatory framework in an effort to bring...more

A DAO Is No Defense: CFTC Says Decentralization Does Not Immunize DeFi from Regulation

In Short - The Situation: Under the existing legal regimes, decentralized autonomous organizations ("DAO" or "DAOs") have been viewed as a way to hedge against regulatory action by way of a decentralized structure. The...more

Digital Assets Defined: The Tax Code's Take

In June 2022, Senators Kirsten Gillibrand (D-NY) and Cynthia Lummis (R-WY) introduced the Responsible Financial Innovation Act (the "Bill"), one of most comprehensive responses by Congress to date with respect to digital...more

California Moves to Regulate Digital Asset Exchanges and Cryptocurrency Companies

California's new Digital Financial Asset Law ("DFAL") will impose a variety of regulatory requirements on digital asset companies and cryptocurrency exchanges. Governor Newsom is expected to sign the DFAL into law, and new...more

Digital Assets Defined: Consumer Protection and Cybersecurity Enter the Stage

In this latest White Paper on our Bill analysis, we underscore headline proposals in the Lummis-Gillibrand Responsible Financial Innovation Act (the “Bill”) regarding consumer protection standards (Title V) and cybersecurity...more

Digital Assets Defined: SEC, CFTC, and Ancillary (Illusory?) Assets

In "Digital Assets Defined: How Lummis-Gillibrand Will Shape the Coming Fintech Debate," we provided a high-level overview of the Responsible Financial Innovation Act (the "Bill") and examined some of its significant...more

Proposed Stabenow-Boozman Bill Falls Short in Bringing Regulatory Certainty to Digital Assets Space

In Short - The Situation: Following the release of the Responsible Financial Innovation Act (the "Lummis-Gillibrand Bill"), four senators on the Senate Committee on Agriculture, Nutrition, and Forestry released their own...more

Digital Assets Defined: How Lummis-Gillibrand Will Shore Up Stablecoins

In this latest White Paper on our Bill analysis, we underscore headline proposals in the Lummis-Gillibrand Responsible Financial Innovation Act (the "Bill") regarding the issuance and regulation of a "payment stablecoin,"...more

Digital Assets Defined: How Lummis-Gillibrand Will Shape the Coming Fintech Debate

On June 7, 2022, U.S. Senators Kirsten Gillibrand (D-NY) and Cynthia Lummis (R-WY) introduced the Responsible Financial Innovation Act (the "Bill"), which proposes a regulatory framework for digital assets across nine titles...more

JONES DAY PRESENTS®: The Metaverse - Opportunities, Markets and Regulation [Video]

Jones Day Financial Markets partner Mark Rasmussen explains how real-life regulations could cross over into the rapidly expanding metaverse space. He talks about the metaverse's current uses and potential advancements, and...more

NFTs: U.S., EU, and UK Key Trademark Considerations

NFTs are verifiable cryptographic tokens, which can act as a form of digital receipt. NFTs can also be used to evidence the authenticity, ownership, and provenance of real-world tangible items, such as artwork and real...more

JONES DAY PRESENTS®: Nonfungible Tokens and the Gamification of Markets [Video]

Nonfungible tokens, or NFTs, continue to grow in popularity as investors, artists, content developers, and other interested parties uncover new applications and opportunities. Jones Day partner Mark Rasmussen explains how...more

CFPB to Invoke "Dormant Authority" to Supervise Nonbank Fintech Companies

On Monday, April 25, 2022, the Consumer Financial Protection Bureau ("CFPB") issued a press release announcing its intent to utilize a "dormant authority" under the Dodd-Frank Act to examine nonbank "'fintechs'" that the...more

Texas and Alabama Securities Regulators File Enforcement Actions Against Online Casino Developer Selling NFTs to Operate Casinos...

In two first-of-their-kind enforcement actions relating to NFTs, securities regulators in Texas and Alabama ordered a Cyprus-based online casino developer and its founders to cease and desist selling NFTs that allegedly were...more

NFTs: U.S., EU, and UK Key Copyright Considerations

NFTs are verifiable cryptographic tokens, which can act as a form of digital receipt. NFTs can also be used to evidence the authenticity, ownership, and provenance of real-world items, such as artwork and real property, or...more

Policyholders Should Not Overlook Traditional Policies in Evaluating Coverage for Cryptocurrency-Related Risks

Introduction - Cryptocurrency, such as Bitcoin, is a decentralized and exclusively virtual currency that is secured through cryptography. Companies using or investing in cryptocurrency face various risks, such as market...more

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