As part of the implementation of the European Markets in Crypto-Assets Regulation (MiCA), the French Financial Markets Authority (AMF) has announced its compliance with six sets of guidelines adopted by European Supervisory...more
The European Securities and Markets Authority (ESMA) has published official translations of its guidelines on the conditions and criteria for the qualification of cryptoassets as financial instruments under Article 2(5) of...more
Our Unclaimed Property and State & Local Tax teams review the state legislation that impacted businesses’ gift card programs in 2024. Notably, Idaho now expressly exempts gift cards that do not expire or impose fees but...more
On January 16th, the IRS published Announcement 2024-4 (the “Announcement”), postponing certain reporting requirements for large crypto transactions which were set to go into effect for the 2024 tax year. Persons engaged in...more
While the blockchain universe continues to expand, the direction and pace of its development will continue to be influenced by a number of variables – including financial markets, regulatory environments and politics. While...more
In 2013, the International Swaps and Derivatives Association (“ISDA”) started publishing the General Disclosure Statement for Transactions document (“General Disclosure”) with annexes containing disclosures of risks that are...more
The Italian Ministry of Economy and Finance ("MEF") issued a new decree ("Decree") requiring that virtual asset/currency service providers promptly enroll in a soon-to-be established special section of the register held by...more
Final amendments to National Instrument 33-109 Registration Information (NI 33-109) and related instruments (the Final Amendments) clarify outside activity reporting requirements, among other things. The Ontario Securities...more
The Financial Services Agency of Japan (FSA) announced on November 6 that together with the local finance bureaus, it will establish a Financial Market Entry Office (FME Office upgraded from the current Financial Market Entry...more
SEC Commissioner Hester Peirce continues to be one of the most vocal persons in leadership positions at federal regulators who are promoting innovation in digital currency and the blockchain....more
On August 20, 2019, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) adopted final regulations (the “Amended Final Regulations”) revamping the regulations...more
The European Commission has published a series of draft Implementing Decisions on the equivalence with the EU Credit Rating Agencies Regulation of the credit rating regimes of certain non-EU countries. The Implementing...more
With the date for the United Kingdom to leave the European Union rapidly approaching, several recent developments concerning derivatives (both legal and political) are likely to be of interest to UK and EU27 counterparties....more
U.S. Developments - Flood of State Virtual Currency Legislation - Since the start of the new year there have been roughly nine virtual currency bills introduced or passed in four different states. Overall, the bills...more
The notion of distributed ledger (formally denominated “shared electronic recording system, or DEEP in French) was first introduced to French law in 2016 by Ordinance No. 2016-520 of April 28, 2016 (the “Minibon...more
There exists no uniformity with respect to how businesses that deal in virtual currencies (also known as "cryptocurrencies") such as Bitcoin are treated among the states....more
In the last month, UK and European politicians have been vocal about the regulation, or lack thereof, in the virtual currency sphere. ...more
In a regulatory first, the Securities and Exchange Commission (SEC) has issued a cease and desist order and imposed a $200,000 fine against a hedge fund that invested in digital assets and its founder. ...more
Add Connecticut, Ohio and Vermont to the list of states passing legislation focused on the potential disruptive impact of blockchain – the technology underlying cryptocurrencies such as Bitcoin. ...more
A lot of us in the sanctions compliance world were wondering whether and when OFAC would issue official guidance on its application of sanctions in the digital currency world. On March 18, OFAC issued five FAQs related to...more