George Kostolampros

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As they say, everything’s bigger in Texas, including initial coin offerings. A Texas federal court recently unsealed a complaint filed by the Securities and Exchange Commission (SEC) against a Texas-based company (the “Company”) that presents itself as the “world’s first decentralized bank” and claims to have provided “the largest ICO to date.”1 Among other things, the Company is accused of engaging in the offering of securities without properly registering with the SEC and defrauding…
Deciding whether to voluntarily disclose information to the government is difficult. Any guidance from the government as to what it expects from organizations and how it will reward self-disclosures should thus be welcome. In a recent appearance at a conference on the Foreign Corrupt Practices Act, Deputy Attorney General Rod Rosenstein announced several changes to DOJ’s corporate enforcement policy. Notably, his statements rolled back some of the requirements set forth in the eponymous “Yates
The Wall Street Journal reported on Wednesday, February 28, 2017, that the Securities and Exchange Commission (SEC) has issued “scores of subpoenas and information requests to technology companies and advisers” in a sweeping probe of the Initial Coin offering (ICO) and Token Sale industry. By way of background, ICOs or “Token Sales” typically involve the offer and sale of digital assets utilizing distributed ledger or blockchain technology. According to the report, the SEC is seeking…
In this issue we discuss that under the cloud of speculation hanging over the CFPB they continue to launch supervisory examinations and enforcement investigations, and also held a public event on June 22 discussing the Public Student Loan Forgiveness Program. Also in this issue is commentary around a top state regulator issued a reminder to obtain prior approval of acquisitions or changes in control, the division between the courts on the ALJ Appointments issue and…