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On the Chain

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

June.02.2020

FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the ...

On the Chain

Three IP Issues to Watch Out for When It Comes to NFTs

by Caroline Simons, Sheryl Koval Garko and Mark S. Puzella
April.15.2021

Seemingly overnight, non-fungible tokens (NFTs) have exploded onto the market and into the public consciousness. The eye-popping prices that some ...

On the Chain

Orrick Hosts Fireside Chat with SEC Commissioner Hester Peirce

March.11.2020

On March 2, Orrick had the pleasure of hosting SEC Commissioner Hester Peirce for a fireside chat discussion at our San Francisco office on the state ...

On the Chain

SEC Provides Expectations About Public Company Disclosures Regarding Crypto Ecosystem Impact

by Alice Hsu, Joseph Perkins and Soo Hwang
January.27.2023

What Happened The Division of Corporation Finance of the Securities and Exchange Commission (“SEC”) issued a sample letter on December 8, 2022, ...

On the Chain

Three Yards and a Cloud of Dust: SEC Staff Provides Its “Plain English” Framework to Guide Future Discussions

April.05.2019

The SEC chose a week that saw the price of Bitcoin spike by over $700 in an hour, kicking off a rally reminiscent of the go-go days of 2017, to issue ...

On the Chain

Still Waiting: SEC Again Delays Approvals of Bitcoin ETFs

August.19.2019

As further evidence of the SEC’s resistance to the development of a regulated secondary market in bitcoin, on August 12 it delayed making a decision ...

On the Chain

FinCEN Shows a Little Bite to Go with Its Bark

April.25.2019

Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) ...

On the Chain

SEC/FINRA Joint Statement on Digital Asset Securities Does Not Address Regulatory Log Jam

July.18.2019

Last week, the Staffs of the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) (collectively, the ...

On the Chain

Proof-of-Stake Rewards: Payment for Services or a Baked Cake?

by Nathaniel Reisenburg
February.22.2022

Against the backdrop of rapidly evolving blockchain technology, the IRS has oftentimes been slow to update its related tax guidance, leaving ...

On the Chain

The SEC’s Second No-Action Relief for Digital Tokens: Meaningful Relief or a Wolf in Sheep’s Clothing?

August.01.2019

Pocketful of Quarters, Inc. (PoQ) is the second-ever recipient of no-action relief from the Division of Corporation Finance of the Securities and ...

On the Chain

Blockchain in Banking: OCC Seeks Public Comment

by Jonas Robison
July.20.2020

For the first time in a dozen years, the Office of the Comptroller of the Currency (OCC) is seeking to update its regulations on digital activities ...

On the Chain

SEC Division of Enforcement 2019 Annual Report Shows Cryptocurrency Is Still Under the Microscope

December.04.2019

The SEC Division of Enforcement’s 2019 Annual Report, released earlier this month, shows a continuing focus on activities involving blockchain and ...