Introduction: Small- and mid-cap companies seeking to gain access to capital markets and improved liquidity for their capital stock should consider the benefits that over-the-counter (“OTC”) markets can provide as a viable...more
On 2 March 2026, the European Commission published a targeted consultation on private equity exits and the possible development of multilateral intermittent trading platforms for private company shares....more
The Securities and Exchange Commission ("SEC") published a Frequently Asked Questions ("FAQs") page focusing on trade and settlement issues, requested feedback on how to improve the crypto regulatory landscape for alternative...more
On December 17, 2025, the staff of the Division of Trading and Markets (the “Staff”) of the Securities and Exchange Commission (“SEC”) released an update to its May 2025 FAQs relating to crypto asset activities and...more
Tokenization is the process of creating an asset, or a digital record of an asset, by issuing a blockchain-based token. It is gaining momentum at institutional and governmental levels by transforming access to public and...more
US Payments and Digital Asset Companies Announce Stablecoin Initiatives - On Oct. 28, a U.S.-based multinational money transfer company announced the launch of its stablecoin, the U.S. Dollar Payment Token (USDPT)....more
* [co-authors: Dan Carter, and Jason Carter] Companies that “go public” through nontraditional means—i.e., without an initial public offering (IPO) listed on a national securities exchange—face significant challenges to...more
The government just gave us a clearer picture of where crypto regulation is headed under the new Trump administration. On Sept. 4, the Office of Management and Budget released its Spring 2025 Unified Agenda, which is...more
On September 8, Nasdaq took a significant step towards revolutionizing the trading landscape by filing with the SEC to enable trading of tokenized securities listed on its exchange starting in 2026. This move, if approved,...more
The Securities and Exchange Commission (SEC) has unveiled its Spring 2025 Rulemaking Agenda, and it’s clear that the crypto market is a focal point. While some anticipated the new Administration would bring in a period of...more
What is PISCES? The Private Intermittent Securities and Capital Exchange System (PISCES) is a UK government–backed initiative designed to enable private companies to offer and trade their existing shares in a controlled,...more
On March 10, 2025, Acting Securities and Exchange Commission (SEC) Chair Mark Uyeda indicated in public remarks that he was directing the SEC staff to revisit a 2020 proposal under then-Chair Jay Clayton that, among other...more
The current SEC administration has expressed the view that most crypto assets are offered and sold as securities and has proposed several rules that address “digital asset securities” or “crypto asset securities.” In this...more
DeFi development carried quietly on throughout 2023, but DeFi protocols also faced significant hurdles. In the US, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) increased their...more
Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more
In April 2023, the SEC re-proposed amendments to Exchange Act Rule 3b-16 to expand the definition of what it means to be an exchange. When the SEC initially proposed these amendments in January 2022, there were zero direct...more
The Securities and Exchange Commission (SEC) proposes to amend Regulation Systems Compliance and Integrity (Reg SCI) to update and expand the regulatory oversight of the core technology of the U.S. securities markets.1 The...more
On April 14, 2023, the Securities and Exchange Commission (SEC) reopened the comment period on proposed amendments to Rule 3b-16 under the Securities Exchange Act of 1934 (the “Exchange Act”) (the “Amendments”). The...more
Recently, the SEC published a proposed new regulation (the “Proposed Rule”) to amend the definition of an “exchange” for purposes of the Securities Exchange Act. Any person whose conduct meets the Proposed Rule’s new...more
The SEC Division of Examinations recently published its list of priorities for 2022. While it was a bit late compared to a typical year, the priorities letter provides a roadmap for firms to better understand where the...more
The Securities and Exchange Commission (“SEC” or “Commission”) has released a proposal to amend Exchange Act Rule 3b-16, Regulation ATS, and Regulation SCI. Criticized by SEC Commissioner Hester Peirce as “too wide-ranging”...more
The amended definition could provide a new means for the SEC to regulate crypto platforms. We previously published a blog post on the set of proposed amendments (Proposal) issued on January 26, 2022, by the Securities...more
The U.S. Securities and Exchange Commission (SEC) recently issued proposed amendments to the Securities Exchange Act (the “Exchange Act”) that would significantly broaden the definition of “exchange” for purposes of...more
The proposal would require certain systems and platforms currently not subject to any registration requirements to register as broker-dealers and ATSs. On January 26, 2022, the Securities and Exchange Commission (SEC)...more
The US Securities and Exchange Commission (SEC) has proposed a sweeping expansion in how it defines securities exchanges to capture digital asset platforms, request-for-quote platforms, indication-of-interest platforms (IOI),...more