News & Analysis as of

Howey Enforcement Actions

Morrison & Foerster LLP

U.S. SEC Issues Statement on Stablecoins

On April 4, 2025, the staff of the U.S. Securities and Exchange Commission (SEC or “Commission”) Division of Corporation Finance (“Staff”) issued a statement on stablecoins (the “Stablecoin Statement”), outlining the Staff’s...more

Latham & Watkins LLP

SEC Staff Clarifies That Crypto Mining Does Not Implicate the Securities Laws

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The Staff Statement provides clarity that Proof-of-Work crypto mining does not involve securities, reducing regulatory uncertainty and enforcement risks for miners....more

Fenwick & West LLP

Crypto Litigation and Enforcement: Q1 2025 - Key Takeaways and Updates

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The cryptocurrency legal and regulatory environment is experiencing significant shifts in 2025, presenting both opportunities and ongoing risks for technology companies in this space....more

Fenwick & West LLP

SEC Statement on Crypto Mining Signals Shift Away from Securities Enforcement

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On March 20, the SEC released a Statement on Certain Proof-of-Work Mining Activities. In the statement, the Division of Corporation Finance (Corp Fin) provides its view that many proof-of-work mining activities are not...more

K&L Gates LLP

SEC Provides Welcome Clarity Regarding Meme Coins

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In welcome news, the US Securities and Exchange Commission (SEC) Division of Corporation Finance (Division) recently announced “[a]s part of an effort to provide greater clarity” that meme coins do not involve the offer and...more

Cooley LLP

Are meme coins securities? Corp Fin says no

Cooley LLP on

Last week, Corp Fin issued a new statement providing its views on whether “meme coins” were securities or, if offered and sold, involved securities transactions. Meme coins are more like collectibles, the staff explained,...more

King & Spalding

Meme Coins: Collectibles, Not Securities.

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On February 27, 2025, the Securities and Exchange Commission’s Division of Corporation Finance (“CorpFin”) issued a Staff Statement announcing its view that meme coin transactions do not involve the offer and sale of...more

Polsinelli

Staff Statement on Meme Coins Signals Significant Shift in SEC Position on Digital Assets

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In an action that could have broad implications, U.S. Securities and Exchange Commission Staff (Staff) issued a statement on February 27, 2025, through its Division of Corporation Finance, providing clarity on the application...more

Fenwick & West LLP

Entertainment or Investment? The SEC’s Stance on Meme Coins as Securities

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On February 27, 2025, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (Corp Fin) published a new staff statement intended to clarify the application of federal securities laws to meme coins....more

Seward & Kissel LLP

SEC v. Coinbase. SEC Leaves the Field.

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On February 27, 2025, the Securities and Exchange Commission formally abandoned its enforcement action against Coinbase. ...more

Ropes & Gray LLP

Meme Coins: SEC Staff Says “This is fine”*

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The SEC’s Division of Corporation Finance issued a statement on February 27, 2025 to clarify the application of federal securities laws to "meme coins," a type of crypto asset inspired by internet memes, characters, current...more

Latham & Watkins LLP

SEC Reels in Fishy NFT Project

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In its third action involving NFTs, the SEC targets a restaurant membership token tied to fundraising and promises of potential price appreciation for buyers....more

Fenwick & West LLP

Crypto Litigation & Enforcement: H1 2024  - Key Takeaways and Updates

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The beginning of this year brought several legal milestones in the world of crypto litigation and enforcement. In the first live installment of our quarterly update webinar, we discussed how...more

Wiley Rein LLP

Podcast: Is Cryptocurrency a Security (like an orange grove)?

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In the first episode of the CryptoCounsel at Wiley, hosts Josh Simmons and Frank Scaduto discuss the evolving landscape of cryptocurrency regulation, focusing on recent disputes and the challenges posed by the SEC's...more

Mintz

SEC’s Enforcement Authority Over Crypto Asset Transactions Upheld (Again) in Case Against Coinbase

Mintz on

On March 27, 2024, the SEC received a favorable—if at least somewhat split—decision when Judge Failla of the SDNY denied a motion by Defendants Coinbase, Inc. and Coinbase Global, Inc. (collectively, “Coinbase”) for judgment...more

Latham & Watkins LLP

Ruling for SEC Clears Path for Continued Litigation in SEC v. Coinbase

Latham & Watkins LLP on

The decision, which addresses a broad range of market activity by Coinbase relating to 13 third-party tokens, could have significant implications for market participants. On March 27, 2024, Judge Katherine Failla of the US...more

Cornerstone Research

SEC Enforcement of Cryptocurrency Reaches a New High

Cornerstone Research on

More than 50% increase in SEC cryptocurrency-related enforcement actions in 2023 over 2022. The Securities and Exchange Commission (SEC) continues to view cryptocurrency-related enforcement as a top priority, bringing 46...more

Barnea Jaffa Lande & Co.

SEC Signals Intent to Regulate NFTs

Barnea Jaffa Lande & Co. on

This past August, the US Securities and Exchange Commission took enforcement action against Impact Theory, a US media company that sold NFTs called “KeyNFTs.” It filed a second enforcement action shortly thereafter, against...more

Farrell Fritz, P.C.

SEC’s First Two NFT Enforcement Actions Cast Shadow of Ambiguity

Farrell Fritz, P.C. on

The Securities and Exchange Commission recently brought its first two enforcement actions against issuers of non-fungible tokens (NFTs), resulting in cease-and-desist orders, penalties and other remedies, finding that the...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - September 2023

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Ballard Spahr LLP

Second SEC NFT-Enforcement Action Finds Another NFT to Be a Security

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Summary - The SEC’s pursuit of the crypto industry continues with its second-ever settlement of a non-fungible token (NFT) enforcement action. The SEC settled with Stoner Cats 2 LLC (SC2), which sought to finance an...more

Sheppard Mullin Richter & Hampton LLP

The SEC’s Sudden Impact on NFTs!

On August 28, 2023, the Securities and Exchange Commission (“SEC”) instituted cease-and-desist proceedings under Section 8A of the Securities Act against Impact Theory, a Los Angeles media and entertainment company, alleging...more

Jones Day

SEC Brings Its First Enforcement Action Against Non-Fungible Token Sellers

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Two SEC commissioners dissented and urged the Commission to provide further guidance on non-fungible tokens ("NFTs")....more

McDermott Will & Emery

SEC Cracks Down on NFTs With First-Of-Its-Kind Enforcement Action

On August 28, 2023, the US Securities and Exchange Commission (SEC) announced an enforcement action against Impact Theory, LLC, alleging that Impact Theory’s public sale of approximately $30 million in crypto assets violated...more

Seward & Kissel LLP

NFT Issuer Gives SEC Easy Layup for First NFT Enforcement Action

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On Aug. 28. 2023, the SEC issued a settled Order against Impact Theory, LLC in connection with its offer and sale of non-fungible tokens (NFTs). It was the first SEC enforcement action involving NFTs....more

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