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No-Action Letters Cryptocurrency

Latham & Watkins LLP

EBA Publishes No Action Letter on Interaction Between MiCA and PSD2

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In the short term, firms are likely to face dual authorisation and significant regulatory requirements. On 10 June 2025, the European Banking Authority (EBA) issued a No Action letter on the relationship between 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

Wiley Rein LLP

Wiley Consumer Protection Download (June 21, 2022)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Pursues Its Next Steps, Posting its Priorities and Pondering a No-Action Process

The Financial Crimes Enforcement Network (FinCEN) has completed two of its early benchmark obligations arising out of the recently passed Anti-Money Laundering Act of 2020 (the “AML Act”)... First, pursuant to the AML Act,...more

Proskauer - Blockchain and the Law

SEC Responds to Wyoming’s Opinion on Custody of Digital Assets and Qualified Custodian Status

The U.S. Securities and Exchange Commission (“SEC”) issued a statement in response to the Wyoming Division of Banking’s No-Action Letter on Custody of Digital Assets and Qualified Custodian Status....more

Goodwin

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Polsinelli

Time to Do the Foxtrot (Three Step) SEC Establishes Improved Process for Settlement of Digital Asset Securities

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The U.S. Securities and Exchange Commission (“SEC”) Division of Trading and Markets recently issued a no action letter to FINRA that may help to streamline the settlement of digital asset securities transactions by...more

Latham & Watkins LLP

INSIGHT: Crypto - The Pursuit of Sufficient Decentralization

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Recent SEC guidance on digital assets cleared a path for at least certain stable coins or payment tokens to avoid securities regulation. However, Latham & Watkins attorneys say there are still a number of open questions that...more

Latham & Watkins LLP

2019 Digital Asset Regulatory Look Back (US Edition)

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It was a year filled with tantalizing tidbits and many loose ends. 2019 marked the 10th year since blockchain technology was released into the wild by its still unknown inventor, Satoshi Nakamoto, who mined the first bitcoin...more

Polsinelli

Wind of Change - The Year FinTech Came in From the Cold - Polsinelli BitBlog: Year End Edition

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Digital assets and Blockchain technologies which were once described as the tools of criminals, are now a key part of efforts by traditional financial services firms to transform their businesses and innovative firms looking...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - September 2019

In this issue of The Distributed Ledger, we discuss the IRS' warning letters for over 10,000 cryptocurrency holders, the SEC's settlement with a blockchain company regarding unregistered ICO transactions, and a European...more

Pillsbury Winthrop Shaw Pittman LLP

All Eyes Are on Regulation of Digital Assets as Federal Agencies and Lawmakers Seek to Bring Clarity: Part 1—The SEC, Utility...

Federal regulators start to address some of the recent questions about digital assets such as tokens and virtual currencies, though many questions remain. U.S. Regulators and Congress are grappling with how to manage the...more

Latham & Watkins LLP

Crypto - The Pursuit of Sufficient Decentralization

Latham & Watkins LLP on

Recent SEC guidance on digital assets cleared a path for at least certain stable coins or payment tokens to avoid securities regulation. However, Latham & Watkins attorneys say there are still a number of open questions that...more

McCarter & English, LLP

SEC No-Action Letter Clears Ambiguity Surrounding The Existence Of Utility Tokens

The SEC has issued its second-ever no-action letter to a token issuer. Pocketful of Quarters, Inc. (PoQ) sought the no-action letter in connection with the issuance of a cryptographically protected token (Quarters), which...more

Perkins Coie

Blockchain Week in Review - July 2019 #3

Perkins Coie on

U.S. Developments - Regulatory Developments - SEC Issues Second No Action Letter for Blockchain-Based Project - On July 25, 2019, the staff of U.S. Securities and Exchange Commission (SEC) issued its second ever...more

BakerHostetler

SEC Issues No Action Letter, Pilots Announced Across Industries, U.S. Enforcement Agencies Remain Active

BakerHostetler on

SEC Issues No-Action Letter, Financial Services Firms and Major Exchanges Make Moves, New Products Launched in Europe - This week, the U.S. Securities and Exchange Commission (SEC) issued to Pocket Full of Quarters Inc....more

McDermott Will & Emery

Capital Markets & Public Companies Quarterly: SEC Proposes Amendments to Accelerated and Large Accelerated Filer Definitions,...

McDermott Will & Emery on

During the previous quarter, the SEC proposed new rulemaking to reduce the number of smaller companies that become subject to enhanced reporting requirements through “accelerated filer” and “large accelerated filer” status....more

Herbert Smith Freehills Kramer

SEC Clarifies Rules, Enforcement Approach on Digital Assets

Amid increasing enforcement activity with respect to cryptocurrencies, coins and tokens, the SEC recently issued guidance intended to provide clarity to the markets. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Current State of Cryptocurrency Enforcement and Securities Litigation

On April 24, 2019, Skadden hosted a webinar titled “The Current State of Cryptocurrency Enforcement and Securities Litigation.” The presented topics largely focused on the SEC’s evolving regulatory approach to cryptocurrency...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions - April 2019

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REGULATORY UPDATES - Financial Industry Regulatory Authority (“FINRA”) Releases Its 2019 Priorities - On January 22, 2019, FINRA released its Annual Risk Monitoring and Examination Priorities Letter, which highlighted the...more

Katten Muchin Rosenman LLP

Bridging the Week - April 2019 #2

The New York State Department of Financial Services cancelled the temporary authority of a major cryptocurrency exchange to operate in New York, saying its failure to meet anti-money laundering, AML compliance officer quality...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - April 2019

In this issue, we examine the release of the much-anticipated Strategic Hub for Innovation and Financial Technology (FinHub) guidance for analyzing how U.S. federal securities laws apply to initial coin offerings, the...more

Perkins Coie

Blockchain Week in Review - April 2019

Perkins Coie on

U.S. Developments - Regulatory Updates - SEC Releases “No-Action Letter” Stating Turnkey Jet ICO Tokens Are Not Securities and Releases “Framework for ‘Investment Contract’ Analysis of Digital Assets” - The U.S....more

Katten Muchin Rosenman LLP

Bridging the Week - April 2019

(You Say Security, I Say Utility; Midtrial Acquittal) - The Securities and Exchange Commission’s FinHub group issued guidance last week, providing a checklist of characteristics to help determine whether a cryptoasset may...more

Perkins Coie

Blockchain Week in Review - January 2019

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U.S. Developments - Congressmen Introduce Legislation to Define “Digital Token” Under the Securities Laws - On December 20, 2018, two congressmen introduced the “Token Taxonomy Act” (H.R. 7356) before the 115th Congress...more

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