Kari Larsen

Firm/Organization: Reed Smith LLP

Blogs: AdLaw By Request®, FinTech Update, Global Regulatory Enforcement Law Blog, Technology Law Dispatch

Latest Articles

Virtual Currencies and Digital Assets: NFA Disclosure Requirements Further Evidence of Increasing Attention from Self-Regulatory Organizations

By Kari Larsen, Herbert F. Kozlov & Le-el D. Sinai

September 28, 2018

In March of this year, the NFA issued a notice reminded futures commission merchants (“FCM”), introducing brokers (“IB”), commodity pool operators (“CPO”) and commodity trading advisors (“CTA”) that trade in, solicit or accept orders in virtual currency products (spot and derivatives) of their ongoing obligation to notify the NFA of such activities by amending the annual questionnaire (please see Reed Smith client alert here). More recently, the NFA issued an August 2018 Interpretive Notice…

FinTech Update

Regulation A+: A Path to Market for Crypto Companies?

By Herbert F. Kozlov, Kari Larsen & Wendy A. Grasso

August 21, 2018

Most companies considering an Initial Coin Offering to U.S. purchasers have resigned themselves to the fact that their proposed token or coin offering is likely to be considered an offering of securities by the Securities and Exchange Commission (“SEC”) and must be made in compliance with U.S. securities laws. The logical next question then becomes – “what are my options?” Traditional IPO A traditional initial public offering (“IPO”) of equity securities usually requires extensive meetings…

FinTech Update

CFPB Picks Paul Watkins to Lead Office of Innovation

By Herbert F. Kozlov, Kari Larsen, Maria B. Earley & Kelley Chittenden

August 6, 2018

On July 18, 2018, Acting Director Mick Mulvaney of the Consumer Financial Protection Bureau (“CFPB”) announced that Paul Watkins will head the CFPB’s new Office of Innovation. According to the press release, the office, which Mulvaney created to focus on consumer-friendly innovation, “will focus on creating policies to facilitate innovation, engaging with entrepreneurs and regulators, and reviewing outdated or unnecessary regulations.” Watkins previously managed the first state fintech regulatory sandbox in the United States…

FinTech Update

Digital Tokens and Coins Advisories and Regulatory Proposals – CFTC and Financial Stability Board Pronouncements

By Herbert F. Kozlov, Kari Larsen & Kelley Chittenden

July 20, 2018

CFTC Customer Advisory On Monday, the Commodity Futures Trading Commission (“CFTC” or “Commission”) issued its fourth virtual currency customer advisory, Customer Advisory 7756-18, as part of its outreach effort to educate market participants. Titled, Use Caution When Buying Digital Coins or Tokens, the advisory warns customers of the risks of speculation of future value and fraud; it ultimately advises that the best protection is to exercise caution and to extensively research digital tokens and…

FinTech Update

CFTC Issues Guidance on Listing Virtual Currency Derivatives

By Herbert F. Kozlov, Kari Larsen & Kelley Chittenden

June 1, 2018

Last week, the Market Oversight and Clearing and Risk Divisions of the Commodity Futures Trading Commission (“CFTC” or “Commission”) issued Staff Advisory No. 18-14 regarding virtual currency derivative product listings. The advisory serves as guidance to exchanges and clearinghouses in the context of listing derivative contracts based on virtual currency under Commission Regulations 40.2 (self-certification) or 40.3 (voluntary submission for Commission review and approval) in order to promote effectiveness and efficiency in the emerging area…

FinTech Update

The Chain Gang – FTC’s New Blockchain Working Group May be Good News for Marketers

By John P. Feldman & Kari Larsen

April 9, 2018

One of the greatest developments for marketers in 2018 is likely to be the proliferation of new and innovative applications on the blockchain in the context of marketing and promotion, particularly in connection with loyalty programs, ad fraud mitigation, and ongoing CRM activities that combine brand affinity and peer-to-peer influencing. The potential magnitude of the changes that the promotion marketing industry could see in the next 12 months, especially in the loyalty area, is simultaneously…

AdLaw By Request®

The Chain Gang – FTC’s New Blockchain Working Group May be Good News for Marketers

By John P. Feldman & Kari Larsen

April 9, 2018

FinTech Update

Massachusetts Enforces While Arizona Provides Flexibility to Fintech

By Herbert F. Kozlov, Kari Larsen & Kelley Chittenden

March 30, 2018

This week, the Massachusetts Secretary of State ordered five companies, 18Moons, Across Platforms, Mattervest, Pink Ribbon, and Sparko, to cease and desist from engaging in initial coin offering (“ICO”) campaigns as part of an ongoing government investigation of token sales. The companies allegedly offered and sold unregistered securities in violation of the Massachusetts Uniform Securities Act (Chapter 110A of Massachusetts’ General Laws) and corresponding regulations. The orders, among other things, (1) prohibit the companies from…

FinTech Update

Blockchain Backed International Dispute Resolution

By Ndidi Elue & Kari Larsen

March 16, 2018

Startups often are at the forefront of creating unique solutions with the ability to have a tremendous impact on various industries. The Miami Blockchain Group, a legal technology startup, has created a novel blockchain application specifically for the international dispute resolution community. The Smart Arbitration & Mediation Blockchain Application, SAMBA, debuted at the 2018 Global Legal Institute for Peace Conference at the University of São Paulo on March 14. Recent news about blockchain has focused…

FinTech Update

Berkeley to Use Blockchain for Tokenized Bonds

By Herbert F. Kozlov, Kari Larsen, Michael Selig & Kelley Chittenden

March 14, 2018

The City of Berkeley, California will be the first U.S. city to explore blockchain-based financing to tackle social issues such as affordable housing. Mayor Jesse Arreguin and Councilmember Ben Bartlett are collaborating with the UC Berkeley Blockchain Lab and San Francisco-based financial startup Neighborly for the Berkeley Blockchain Initiative (“BBI”) to develop a tokenized municipal bond. According to Forbes, Berkeley had a similar idea twenty years ago with a local currency called “Berkeley Bucks.” This…

Kari Larsen

Virtual Currencies and Digital Assets: NFA Disclosure Requirements Further Evidence of Increasing Attention from Self-Regulatory Organizations

Regulation A+: A Path to Market for Crypto Companies?

CFPB Picks Paul Watkins to Lead Office of Innovation

Digital Tokens and Coins Advisories and Regulatory Proposals – CFTC and Financial Stability Board Pronouncements

CFTC Issues Guidance on Listing Virtual Currency Derivatives

The Chain Gang – FTC’s New Blockchain Working Group May be Good News for Marketers

The Chain Gang – FTC’s New Blockchain Working Group May be Good News for Marketers

Massachusetts Enforces While Arizona Provides Flexibility to Fintech

Blockchain Backed International Dispute Resolution

Berkeley to Use Blockchain for Tokenized Bonds

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