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Legislation Offers Long-Awaited Regulatory Clarity and Safeguards for Digital Assets — SEC and Securities

USA - June 21 2022 Securities issues are covered in Title III (Responsible Securities Innovation) of the Responsible Financial Innovation Act (RFIA). The RFIA would add…

Deric M. Behar, Jenny Cieplak, Marlon Q. Paz

Decentralized Autonomous Organizations: Piercing the Digital Veil

USA - May 10 2022 A complaint filed in federal court will test the boundaries of protection from liability for individuals behind decentralized autonomous organizations…

Deric M. Behar, Nima H. Mohebbi, Adam Zuckerman

SEC Proposes to Expand Interpretation of “Dealer” and “Government Securities Dealer” Definitions

USA - April 12 2022 On March 28, 2022, the US Securities and Exchange Commission (SEC) proposed rules (Proposing Release) that would require securities market…

Deric M. Behar, Naim Culhaci, Laura N. Ferrell, Marlon Q. Paz, Nabil Sabki

When Are CCOs on the Hook? FINRA Offers Guidance on CCO Liability

USA - March 31 2022 Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors…

Deric M. Behar, John J. Sikora Jr., Marlon Q. Paz

President Biden Issues Executive Order on Digital Assets

USA - March 14 2022 The order directs federal agencies to focus on six priority areas within the digital asset sector and potential development of a US CBDC…

Alan W. Avery, Deric M. Behar, Adam Bruce Fovent, Pia Naib, Yvette D Valdez