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O'Melveny & Myers LLP | USA | 11 Dec 2018

The Presumption of Token Innocence: Not a Security Until Proven a Security?

On November 27, 2018, a judge in the Southern District of California denied the Securities and Exchange Commission’s (the “SEC”) motion for a


O'Melveny & Myers LLP | USA | 16 Mar 2018

Do All ICO Issuers Have to Register as Money Service Businesses with FinCEN?

ICO issuers commonly screen purchasers in initial token or "coin" offerings (ICOs) for anti-money laundering (AML) and "Know-Your-Customer" (KYC)


O'Melveny & Myers LLP | USA | 23 Jan 2018

Crypto Roundup: SEC and CFTC Chairs, Commissioners and Enforcement Directors Issue Stern Public Statements on Cryptographic and Virtual Assets

Over the past weeks, there has been a steady drumbeat of public statements from the leadership of the SEC and CFTC about cryptographic and virtual

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